NFPA 801 ROC Meeting 801 ROC... · NFPA 801 ROC Meeting ... Neal W. Krantz, Sr. ... Wayne and Kevin...

Technical Committee on Fire Protection for Nuclear Facilities

NFPA 801 ROC Meeting

Embassy Suites Airport

5055 International Boulevard

North Charleston, SC 29418

Tuesday, March 27, 2012 (8:30-5:00PM ET)

1. Call to Order at 8:30PM ET 2. Greetings and Self-Introductions 3. Comments and General Procedure

a. Exits b. Committee Membership Update c. Review of Revision Cycle and Procedures

4. Approval of Minutes of Last Meeting 5. Report of the Radiation Threshold Task Group 6. Review and Action on Public Comments for NFPA 801 7. Recess at 5:00PM ET

Wednesday, March 28, 2012 (8:30AM-12:00PM ET)

1. Reconvene at 8:30AM ET 2. Review and Action on Public Comments for NFPA 801 3. Reports and Formation of Committee Comments (Time Permitting) 4. Old Business 5. New Business 6. Adjourn at12:00PM ET

Address List No PhoneFire Protection for Nuclear Facilities FIF-AAA

Paul May03/09/2012

FIF-AAA

William B. Till, Jr.

ChairSavannah River Nuclear Solutions, LLC197 Till Hill RoadOrangeburg, SC 29115Alternate: James W. Naylor

U 4/17/1998FIF-AAA

Ivan Bolliger

PrincipalCanadian Nuclear Safety Commission280 Slater StreetOttawa, ON K1P 5S9 Canada

E 8/5/2009

FIF-AAA

Craig P. Christenson

PrincipalUS Department of EnergyRichland Operations Office825 Jadwin Avenue, A5-17, Room 586Richland, WA 99352Alternate: James G. Bisker

E 1/14/2005FIF-AAA

Stanford E. Davis

PrincipalPPL Susquehanna LLCSusquehanna Steam Electric Station769 Salem BoulevardBerwick, PA 18603Alternate: Frank S. Gruscavage

U 4/17/1998

FIF-AAA

Richard L. Dible

PrincipalAREVA NP, Inc.6100 Southwest Blvd., Suite 400Fort Worth, TX 76109

M 11/2/2006FIF-AAA

Edgar G. Dressler

Principal17812 SE 87th Bourne AvenueThe Villages, FL 32162-4804American Nuclear InsurersAlternate: Seth S. Breitmaier

I 4/1/1995

FIF-AAA

David R. Estrela

PrincipalOrr Protection Systems, Inc.38 Blanchard RoadGrafton, MA 01519

IM 10/28/2008FIF-AAA

Daniel J. Hubert

PrincipalJanus Fire Systems1102 Rupcich Drive, Millennium ParkCrown Point, IN 46307

IM 10/28/2008

FIF-AAA

Steven W. Joseph

PrincipalXtralis, Inc.11467 SW Foothill DrivePortland, OR 97225

M 10/18/2011FIF-AAA

Robert Kalantari

PrincipalEPM, IncorporatedEngineering Planning & Management959 Concord StreetFramingham, MA 01701Alternate: Paul R. Ouellette

SE 1/15/1999

FIF-AAA

Robert P. Kassawara

PrincipalElectric Power Research Institute3412 Hillview AvenuePalo Alto, CA 94309Alternate: John P. Gaertner

U 7/24/1997FIF-AAA

Elizabeth A. Kleinsorg

PrincipalKleinsorg Group Risk Services, LLCA Hughes Associates Company200 Brannan Street, Unit 208San Francisco, CA 94107Alternate: Andrew R. Ratchford

SE 10/10/1997

1


Paul May03/09/2012

FIF-AAA

Neal W. Krantz, Sr.

PrincipalKrantz Systems & Associates, LLC30126 BrettonLivonia, MI 48152Automatic Fire Alarm Association, Inc.Alternate: Fred M. Leber

M 1/1/1992FIF-AAA

Christopher A. Ksobiech

PrincipalWe Energies231 West Michigan, P378Milwaukee, WI 53203Alternate: Jeffery S. Ertman

U 7/17/1998

FIF-AAA

Paul W. Lain

PrincipalUS Nuclear Regulatory CommissionMS: O-10C15Washington, DC 20555Alternate: Daniel M. Frumkin

E 4/3/2003FIF-AAA

John D. Lattner

PrincipalSouthern Nuclear40 Inverness Center ParkwayBirmingham, AL 35201

U 8/9/2011

FIF-AAA

Charles J. March

PrincipalDefense Nuclear Facilities Safety Board625 Indiana AvenueWashington, DC 20004

E 10/20/2010FIF-AAA

Anca McGee

PrincipalOntario Power GenerationBox 4000, Internal Mail: D10-2Bowmanville, ON L1C 3Z8 Canada

U 8/9/2011

FIF-AAA

Frank Monikowski

PrincipalTyco/SimplexGrinnell230 Executive DriveCranberry Township, PA 16066National Fire Sprinkler AssociationAlternate: James Bouche

M 7/23/2008FIF-AAA

Bijan Najafi

PrincipalScience Applications International Corp.1671 Dell Avenue, Suite 100Campbell, CA 95008

SE 7/12/2001

FIF-AAA

Ronald Rispoli

PrincipalEntergy Corporation2414 West 5th StreetRussellville, AR 72801Nuclear Energy InstituteAlternate: Robert K. Richter, Jr.

U 4/4/1997FIF-AAA

Clifford R. Sinopoli, II

PrincipalExelon CorporationPeach Bottom Atomic Power Station1848 Lay Road, MS SMB3-4Delta, PA 17314Edison Electric Institute

U 1/1/1990

FIF-AAA

Cleveland B. Skinker

PrincipalBechtel Power Corporation5275 Westview DriveFrederick, MD 21703-8306Alternate: Arie T. P. Go

SE 1/15/2004FIF-AAA

Wayne R. Sohlman

PrincipalNuclear Electric Insurance Ltd.1201 Market Street, Suite 1100Wilmington, DE 19801Alternate: Thomas K. Furlong

I 1/1/1993

FIF-AAA

James R. Streit

PrincipalLos Alamos National LaboratoryPO Box 1663, Mail Stop K493Los Alamos, NM 87545Alternate: Neal T. Hara

U 1/16/1998

2


Paul May03/09/2012

FIF-AAA

Donald Struck

PrincipalSiemens Fire Safety8 Fernwood RoadFlorham Park, NJ 07932National Electrical Manufacturers AssociationAlternate: Daniel P. Finnegan

M 8/5/2009FIF-AAA

William M. Sullivan

PrincipalContingency Management Associates, Inc.109 Miller SreetMiddleboro, MA 02346

SE 4/17/1998

FIF-AAA

Ronald W. Woodfin

PrincipalTetraTek, Inc. Fire Safety Technologies18755 West Cool Breeze LaneMontgomery, TX 77356Alternate: David M. Hope

SE 1/15/2004FIF-AAA

James G. Bisker

AlternateUS Department of EnergyNuclear Safety Policy & Assistance (HS-21)1000 Independence Avenue, SWWashington, DC 20585-1290Principal: Craig P. Christenson

E 8/2/2010

FIF-AAA

James Bouche

AlternateF.E. Moran, Inc.Special Hazard Systems2265 Carlson DriveNorthbrook, IL 60062National Fire Sprinkler AssociationPrincipal: Frank Monikowski

M 7/23/2008FIF-AAA

Seth S. Breitmaier

AlternateAmerican Nuclear Insurers95 Glastonbury Boulevard, Suite 300Glastonbury, CT 06340Principal: Edgar G. Dressler

I 10/18/2011

FIF-AAA

Jeffery S. Ertman

AlternateProgress Energy410 South Wilmington StreetRaleigh, NC 27601Principal: Christopher A. Ksobiech

U 4/15/2004FIF-AAA

Daniel P. Finnegan

AlternateSiemens Industry, Inc.Building Technology DivisionFire Safety Unit8 Fernwood RoadFlorham Park, NJ 07932National Electrical Manufacturers AssociationPrincipal: Donald Struck

M 10/18/2011

FIF-AAA

Daniel M. Frumkin

AlternateUS Nuclear Regulatory Commission11555 Rockville Pike, MS 011A11Rockville, MD 20852Principal: Paul W. Lain

E 11/2/2006FIF-AAA

Thomas K. Furlong

AlternateNuclear Service Organization1201 North Market Street, Suite 1100Wilmington, DE 19801Principal: Wayne R. Sohlman

I 1/12/2000

FIF-AAA

John P. Gaertner

AlternateElectric Power Research InstitutePO Box 217097Charlotte, NC 28221Principal: Robert P. Kassawara

U 10/23/2003FIF-AAA

Arie T. P. Go

AlternateBechtel National, Inc.50 Beale StreetSan Francisco, CA 94105Principal: Cleveland B. Skinker

SE 10/1/1993

3


Paul May03/09/2012

FIF-AAA

Frank S. Gruscavage

AlternatePPL Susquehanna LLC769 Salem BoulevardBerwick, PA 18603Principal: Stanford E. Davis

U 1/18/2001FIF-AAA

Neal T. Hara

AlternateIdaho National LaboratoryPO Box 1625Idaho Falls, ID 83415-3402Principal: James R. Streit

U 03/05/2012

FIF-AAA

David M. Hope

AlternateTetraTek Inc. Fire Safety Technologies204 Masthead DriveClinton, TN 37716Principal: Ronald W. Woodfin

SE 4/15/2004FIF-AAA

Fred M. Leber

AlternateLRI Fire Protection EngineeringYonge Eglinton Center2300 Yonge Street, Suite 2100PO Box 2372Toronto, ON M4P 1E4 CanadaAutomatic Fire Alarm Association, Inc.Principal: Neal W. Krantz, Sr.

M 10/20/2010

FIF-AAA

James W. Naylor

AlternateSavannah River Nuclear SolutionsBuilding 742-APO Box 616Aiken, SC 29801Principal: William B. Till, Jr.

U 3/15/2007FIF-AAA

Paul R. Ouellette

AlternateEPM, IncorporatedEngineering Planning & Management959 Concord StreetFramingham, MA 01701Principal: Robert Kalantari

SE 7/19/2002

FIF-AAA

Andrew R. Ratchford

AlternateRatchford Diversified Services, LLC346 Rheem Blvd. Suite 207DMoraga, CA 94556Principal: Elizabeth A. Kleinsorg

SE 4/16/1999FIF-AAA

Robert K. Richter, Jr.

AlternateSouthern California Edison Company5000 Pacific Coast Hwy, AWS D2JSan Clemente, CA 92672Nuclear Energy InstitutePrincipal: Ronald Rispoli

U 4/15/2004

FIF-AAA

Tzu-sheng Shen

Nonvoting MemberCentral Police University56 Shu-Jen RoadTa-kan-chun, Kuei-sanTaoyuan, 333 Taiwan

SE 7/29/2005FIF-AAA

Leonard R. Hathaway

Member Emeritus1568 Hartsville TrailThe Villages, FL 32162

I 1/1/1976

FIF-AAA

Walter W. Maybee

Member Emeritus2200 Lester Drive NE, Apt 475Albuquerque, NM 87112

1/1/1971FIF-AAA

Paul May

Staff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy, MA 02169-7471

6/29/2007

4

NFPA 1 Batterymarch Park, Quincy, MA 02269‐9101 USA

Phone: (617) 770‐3000 Fax: (617) 984‐0700 www.nfpa. org

NFPA 801 ROP Meeting

June 21‐22, 2011

ORR Protection Systems, Inc.

Louisville, KY

Tuesday, June 21, 2011:

1. Meeting called to order at 8:30AM ET by Chair, Bernie Till.

2. Meeting and web conference attendees and guests were self‐introduced and their attendance recorded.

ATTENDEE PRESENT ATTENDEE PRESENT

PRINCIPAL ALTERNATE

William “Bernie” Till Yes James Naylor No

Ivan Bollinger Yes

Craig Christenson Yes James Bisker Yes

Harry Corson No Donald Struck No

Stanford Davis Yes Frank Gruscavage No

Richard Dible No

Edgar Dressler Yes

David Estrela Yes

Arie Go No Cleveland Skinker Yes

Wayne Holmes No

Daniel Hubert Yes

Robert Kalantari No Paul Ouellette No

Robert Kassawara No John Gaertner No

Elizabeth Kleinsorg No Andrew Ratchford No

Neal Krantz Yes Fred Leber No

Christopher Ksobiech Yes Jeffery Ertman No

Paul Lain No Daniel Frumkin No

Frank Monikowski Yes James Bouche Yes

Bijan Najafi Yes

Ronald Rispoli Yes Robert Richter Yes

Clifford Sinopoli No

Wayne Sohlman Yes Thomas Furlong No

James Streit No

William Sullivan Yes

Ronald Woodfin Yes David Hope No

VOTING ALTERNATE

Charles March Yes

NONVOTING MEMBER

Tzu‐sheng Shen No

MEMBER EMERITUS

Leonard Hathaway No

Walter Maybee No

STAFF

Paul May Yes

GUESTS

Seth Breitmaier Yes

Paul Nelson Yes

3. The Chair made opening remarks relating to the need to hold a face to face meeting and cited several reasons why it was beneficial and important to the committee especially the new members. Bernie also reported that Wayne Holmes the former Chair had received the NFPA Standards Council Award in recognition for is long and outstanding service to the NFPA and the Fire Protection Community, Bernie also reported that Wayne and Kevin Austin are retiring, which led to a discussion on the status of the membership of the committee, hold list, and adding new members.

4. NFPA Staff Liaison, Paul May provided direction to the committee on the process and procedures that are appropriate for the ROP stage. He also discussed the NFPA Research Foundation’s “Code Fund” and its services as a resource for the committee. A review of the E‐Committee on‐line process planned for future implementation was also covered.

5. Minutes of the previous meeting (April 21, 2009 ROC via web conference) were approved as submitted.

6. The Chair noted that the report on “Glove Box Fire Protection” published by the NFPA

Research Foundation is available on their website. http://www.nfpa.org/assets/files//PDF/Research/RFLiteratureReview.pdf

7. On behalf of the Committee, the Chair presented plaques to the family of Brian Fabel and his employer ORR Protection Systems for Brian’s contribution to the technical committee.

8. The Committee reviewed and took action on Public Proposals to NFPA 801.

http://www.nfpa.org/assets/files//PDF/Research/RFLiteratureReview.pdf

9. A task group was formed to examine the applicable radiation thresholds that are listed in 1.3 of the 2008 edition of NFPA 801 and develop a recommendation. The task group consists of Bernie Till, Craig Christenson, Chuck March, and Ron Woodfin.

10. The Committee recessed at 6:00 PM ET.

Wednesday, June 21, 2011:

1. Meeting re‐convened at 8:30AM ET by Chair, Bernie Till.

2. The Committee reviewed and took action on Public Proposals to NFPA 801.

3. The Committee generated and approved 4 committee proposals.

4. Discussion took place that it might be appropriate to create a new standard that

addresses fire protection for Small Module Reactors (SMRs).

5. The next meeting is scheduled to take place in either Savannah, GA or Charleston, SC between March 2, 2012 and May 4, 2012 for the ROC.

6. The meeting was adjourned at 3:17PM ET.

Report on Comments – November 2012 NFPA 801_______________________________________________________________________________________________801- Log #32

_______________________________________________________________________________________________Andrew Minister, Battelle Pacific Northwest National Laboratory

801-7Revise text to read as follows:

These requirements shall be applicable to all locations where radioactive materials that meet thethresholds established in 10 CFR 30 are stored, handled, or used in quantities and under conditions requiring wherespecified by governmental regulations (e.g., those of the U.S. Nuclear Regulatory Commission, or U.S. Department ofEnergy, or other governmental nuclear regulatory body) applicable to non-power nuclear reactors or to the possessionor use these materials, and to all other locations with equal quantities or conditions.

The possession and use of radioactive materials is subject to government regulation at the federal or state leveldepending on the material and use. The regulations of the governing authority specify the applicability of the fireprotection requirements in this standard for those who possess, use, handle, or store radioactive materials or operatenon-power reactors.

The possession and use of radioactive material and the operation of processing, production, orutilization facilities, including non-power reactors is governed by governmental regulations, whether federal, state orgovernmental body in countries outside of the United States. The specific thresholds for regulation of materials can besubstantially different across the various agencies with authority over these materials. The requirements governingsafety or radioactive materials, including fire protection, are imbedded in the individual regulations of the governingauthority for a particular use or facility. This standard is subordinate to those regulations. Rather than attempt to definea common material threshold that is acceptable to each regulatory entity, the applicability should be deferred to theindividual agencies regulations and implementing requirements.

_______________________________________________________________________________________________801- Log #29

_______________________________________________________________________________________________Neal T. Hara, Idaho National Laboratory

801-7Accept Proposal 801-10 (Log#48) with the following revision to the original proposal: Revise the

fourth sentence within the substantiation to delete the word occupational: “The schedule B quantity was, roughlyspeaking, those levels for which continuous long term occupational exposure of the public to radioactive materials wouldnot exceed a predetermined dose levels.”

Federal Register, Volume 33, No.156 – Saturday, August 10, 1968 (pages 11413 through 11417)provided additional clarification of the basis for the 10 CFR 30, Schedule B threshold. The discussion within the federalregister describes the schedule B quantity basis (continuous exposure over one year for inhalation hazards and 1milliroentgen per hour for direct gamma radiation hazards). Since items with quantities of radioactive material less thanthose listed in schedule B are essentially uncontrolled after being supplied to the general public, the quantities arelimited and are not appropriate for determining exposure of the public or emergency response personnel during or aftera fire.

1Printed on 3/9/2012


_______________________________________________________________________________________________Marcelo M. Hirschler, GBH International


ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA19428-2959.ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials 2012 2010ASTM E814, 1994.

Standards update -

_______________________________________________________________________________________________801- Log #1

_______________________________________________________________________________________________John F. Bender, Underwriters Laboratories Inc.


Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062.UL 723, , 2008, Revised 2010.ANSI/UL 1479, 2003, revised 2006 2010.

Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062.UL 723, , 2008, Revised 2010.

Add ANSI approval designation to ANSI/UL 1479 and update referenced standards to most recentedition.

_______________________________________________________________________________________________801- Log #28



A relative measurement of the surface burning characteristics of building materials.Flame spread ratings are determined by ASTM E 84 or UL 723.

A comparative measure, expressed as a dimensionless number, derived from visualmeasurements of the spread of flame versus time for a material tested in accordance with ASTM E 84,

; or UL 723,. [NFPA 5000; 3.3.346.1]

The term “flame spread rating” is no longer in use. The appropriate term is “flame spread index”. Thepreferred NFPA definition of “flame spread index” is the one from NFPA 5000, and it is recommended that NFPA 801simply extracts it. With this definition the annex note is no longer needed.





The Fire Hazards Analysis shall be prepared by or under the supervision of a qualified fire protection engineeracceptable to the authority having jurisdiction.

A qualified fire protection engineer acceptable to the AHJ responsible for the preparation of a fire hazardsanalysis for facilities handling radioactive materials should have generally has knowledge based on a combination ofeducation and experience in the field of fire protection specific to these types of facilities. Examples of a qualified fireprotection engineer can include a licensed professional engineer specializing in the field of fire protection or qualified tobe a professional member of the Society of Fire Protection Engineers (SFPE).

The proposed word implies that the AHJ must approve the technical capabilities of regulated user ofradioactive materials. The authority having jurisdiction (i.e., regulatory agencies with authority for radioactive materials)should not determine the acceptability of the qualifications of engineering or other staff of the licensees, contractors, orother users governed by the AHJs. It is the role of the regulator to provide oversight with regard to meeting theserequirements.





A written fire protection plan program shall be established and implemented for all operational modes of the facility andshall include the following:(1) Management and policy direction as indicated in Section 4.1(2) Standards, procedures, processes and supporting documentation for fire protection design and operation of the

facility(3) Preparation and maintenance of a fire hazard analysis as indicated in Section 4.2(4) Management of changes to the facility that affect fire protection(5) Fire safety information for all employees and contractors, including familiarization with procedures for fire

prevention, emergency alarm response, and reporting of fires(6)* Documented facility inspections conducted at least monthly, including provisions for remedial action to correct

conditions that increase fire hazards(7)* A description of the general housekeeping practices and the control of transient combustibles(8)* Fire prevention surveillance(9) Control of flammable and combustible liquids and gases and oxidizers in accordance with the applicable documents

referenced in Section 7.1(10)* Control of ignition sources including, but not limited to, grinding, welding, and cutting(11) Restriction of smoking to designated and supervised areas of the facility(12) Inspection, testing and maintenance of fire protection design features and equipment as indicated in Section 4.4(13) Procedures for planned and unplanned impairments to fire protection design features and equipment as indicated

in Section 4.5(14)* Fire reports, including an investigation and a statement on the corrective action to be taken(15)* Construction, demolition, and renovating activities that conform to the requirements of NFPA 241,

(16) Emergency response requirements as indicated in Section 4.6(17) Provision of the facility fire emergency organization as indicated in Section 4.7(18) Preparation of pre-fire plans as indicated in Section 4.8(19) Quality assurance and self auditing of the above activities(20) Provision for staff and training to carry out the above activities

Preparation of the fire protection program should follow the requirements of Section 4.3 while taking intoconsideration the hazards and complexity of the facility and potential consequences of a fire to building occupants, thepublic or the environment. The level of detail to the fire protection program elements will depend on the risk of the facilityin relation to the fire protection objectives.

Pressure-impregnated fire-retardant lumber should be used in accordance with its listing and themanufacturer’s instructions. Where exposed to the weather or moisture (e.g., concrete forms), the fire retardant usedshould be suitable for this exposure. Fire-retardant coatings are not acceptable on walking surfaces or surfaces subjectto mechanical damage. Use of fire-retardant paint requires special care. Inconsistent application and exposure toweather can reduce the effectiveness of fire-retardant coatings. Large timbers are occasionally used to support largepieces of equipment during storage or maintenance. The size of these timbers makes them difficult to ignite, and they donot represent an immediate fire threat.

The reason for addition of the term “Plan” after program in the subsection title is unclear from the ROP.The elements described are the content of a comprehensive program and the term “Program” is familiar to many whoapply this standard (e.g., DOE regulations (10 CFR 851) and directives refer to a fire protection program). Thecombination of program and plan is confusing and implies two different elements without definition.The deleted text regarding operational modes eliminates ambiguity. Operational modes are not defined for many

facilities handling radioactive materials nor is the term defined in this standard. There is nothing in the standard to implythat fire protection would not apply at all times and to all conditions of facility operations.


Report on Comments – November 2012 NFPA 801

_______________________________________________________________________________________________801- Log #4

_______________________________________________________________________________________________Wayne Holmes, Burlington, NC

801-27Retain the original text of the first part of 5.2.1 to read, "Facilities having quantities of radioactive

materials that can become airborne In the event of a fire or explosion...".Not all facilities that contain radioactive materials need to be segregated from other buildings or

operations. Facilities with minor quantities do not need to be segregated. Nuclear materials such as a solid ingot ofuranium that has no potential to become airborne need not be segregated. It is important to retain the concept that thesegregation requirement applies only to quantities of materials that might become airborne due to fire exposure asdetermined by the FHA.

_______________________________________________________________________________________________801- Log #5


801-27Retain the word, "important", such that 5.2.1 reads, "Facilities having quantities of radioactive

materials that can become airborne in the event of fire or explosion shall be segregated from other importantbuildings...".

Segregation does need to be provided for all buildings. Small or unimportant buildings do not need tobe segregated. The analysis in the FHA will determine which buildings are important and need to be segregated.

_______________________________________________________________________________________________801- Log #7


801-38Revise proposed 5.9.5.3.5 to read: Filters in smoke exhaust systems shall be proved with fixed fire

suppression systems if required by the Fire Hazard Analysis.This absolute requirement to provide fixed protection for all filters that might collect combustible

materials unless justified by the FHA is unnecessary. The topic of this section is filters in smoke exhaust systems. Allfilters in such systems smoke exhaust systems will collect combustible materials. Enforcement of proposed 5.9.5.3.5would required that all filters, regardless of size or importance, be provided with fixed protection unless justified by theFHA. Typical nuclear ventilation systems, including those that might be used for smoke exhaust, often include multiplelevels of filters, including many that are quite small. Fire protection for all filters is unwarranted and, in some cases,might be detrimental to sound fire protection and radiological safety. The FHA should not need to provide an analysis ofall filters in smoke exhaust systems to justify the omission of fixed fire protection. Rather, the FHA should evaluate theventilation system and determine if and where, fixed fire protection is necessary for fire and radiological safety





Where required by the FHA, rooms for the storage of radioactive material, including radioactive gases and radioactivewaste shall be separated from the remainder of the building by a 2-hour fire separation, except where it is demonstratedby the fire hazard analysis that the fire protection objectives can be met by other fire protection measures.

The proposed 5.14.3 as presented in the ROP would require that all storage rooms that contain anyamount of radioactive material, including minor amounts of material, be provided with 2-hour fire-rated separation unlessjustified by the FHA This level of enclosure for all radioactive storage is unjustified. The need for enclosure should bedriven by analysis rather than prescription.

_______________________________________________________________________________________________801- Log #10


801-39Delete proposed 5.14.3.1 in its entirety.

The intent of this paragraph is unclear. It contains no requirements nor does it provide relief from anyrequirements. It states that needed materials are permitted to be available. It does not address whether the materialsneed to be enclosed or not enclosed. It does not address amounts or the significance of the material or hazard.Proposed 5.14.3.1 should not appear in NFPA 801.





A fire hazards analysis shall be performed to determine the fire protection requirements for the facility, using agraded approach based on the hazard presented by the facility.

Automatic sprinkler protection shall be provided unless the fire hazards analysis in Section 4.2 dictatesotherwise.

As determined by the fire hazards analysis, special hazards shall be provided with additional fixed fireprotection systems.

For locations where fissile materials might be present and could create a potential criticality hazard,combustible materials shall be excluded.

In handling fissile materials, precautions should be taken not only to protect against the normal radiationhazard but also against the criticality hazard caused by the assembly of a minimum critical mass. To avoid criticalityduring fire emergencies, fissile materials that have been arranged so as to minimize the possibility of a criticality hazardshould be moved only if absolutely necessary. If it becomes necessary to move such fissile materials, it should be doneunder the direction of a responsible person on the staff of the facility and in batches that are below the critical mass, orthe materials should be moved in layers that minimize the possibility of a criticality occurring.

If combustible materials are unavoidably present in a quantity sufficient to constitute a fire hazard, water oranother suitable extinguishing agent shall be provided for fire-fighting purposes.

Fissile materials shall be arranged such that neutron moderation and reflection by water shall not present acriticality hazard.

The requirement for a fire hazards analysis is specified in Section 4.2 and does not need to berepeated.

_______________________________________________________________________________________________801- Log #11


801-40Delete "using a graded approach" so that the final phrase in 6.1.1. reads "based on the hazard

presented by the facility."

The term "graded approach" is not defined in NFPA 801. The meaning of the term is subject to greatvariation depending on application The application of a "graded approach" as applied to a Department of Energy facilitymight not be available to, applicable to, or useful to other types of facilities handling nuclear materials such as a hospital.The phrase which is recommended to be deleted adds nothing to the existing requirement in 6.1.1. The intent of thisphrase might be better expressed in annex material.




801-44Insert "by the FHA" so that 6.8.2 reads: "Where automatic fire detectors are required by the

FHA...".The proposed committee action on 6.8.2 would delete "as required by the FHA." As a result, NFPA

801 would have no guidance or requirements for where fire detection is needed except where required by anotherreferenced standard such as the Life Safety Code NFPA 72 is an installation standard does not specify where detectionmust be installed It is important that NFPA 801 specifies that detection must be provided in accordance with the FHA.





Flammable and combustible liquids shall be stored and handled in accordance with NFPA 30,.

Flammable and combustible gases shall be stored and handled in accordance with NFPA 54,; NFPA 55, ; and NFPA 58,In As determined by fire hazards analysis, combustible gas analyzers shall be installed in enclosed spaces

with the potential for accumulation of combustible gases enclosed spaces in which combustible gas could accumulateoutside of the storage vessels, piping, and utilization equipment, combustible-gas analyzers that are designed for thespecific gas shall be installed.

Enclosed spaces refers to any enclosure within a building, including gloveboxes, hot cells, caves, plenums,etc.

As determined by fire hazards analysis, Fflammable and combustible liquids in enclosed spaces in whichvapors have the potential to accumulate outside of the storage vessels, piping, and utilization equipment shall beinstalled with combustible-vapor analyzers appropriate for the vapors generated.

See the explanation for enclosed spaces under A.7.1.1.3.The analyzer specified by Section 7.1.1.3 or Section 7.1.1.4 shall be set to alarm at a concentration no higher

than 25 percent of the lower flammable explosive limit.Safety controls and interlocks for combustible, flammable liquids and flammable gases and their associated

delivery systems shall be tested on a predetermined schedule and after maintenance operations.Hydraulic fluids used in presses or other hydraulic equipment shall be the fire-resistant fluid type.

Where a flammable or combustible solvent is used, it shall be handled in a system that does not allowuncontrolled release of vapors.

Approved oOperating controls and limits appropriate for the hazard shall be established.An approved fixed fire-extinguishing system shall be installed or its absence justified to the satisfaction of the

AHJ by fire hazards analysis.Solvent distillation and recovery equipment for flammable or combustible liquids shall be isolated from areas

of use by 3-hour fire barriers of appropriate rating for the hazard.In order to ensure the operation of process evaporators, such as Plutonium Uranium Reduction and

Extraction (PUREX), means shall be provided to prevent entry of water-soluble solvents into the evaporators.Specialized Processes and Equipment

Furnaces or Ovens used in facilities handling radioactive materials shall comply with the applicablerequirements of NFPA 86, , NFPA 86C,

or NFPA 86D, , asappropriate.

NFPA 115, shall apply to processes and systems utilizing lasers.Incinerators shall be in accordance with NFPA 82,

Combustible metals shall be stored and handled in accordance with NFPA 484,.

Operating controls and limits for the handling of pyrophoric materials shall be established to the satisfaction ofthe AHJ.

A supply of an appropriate extinguishing medium shall be available in all areas where fines and cuttings ofpyrophoric materials are present.

Solid and liquid oxidizing agents shall be stored and handled in accordance with NFPA 430,.

Fissile materials shall be used, handled, and stored with provisions to prevent the accidental assembly of fissile


Report on Comments – November 2012 NFPA 801material into critical masses.

Fissile materials shall be arranged such that neutron moderation and reflection by water shall not present acriticality hazard.

For locations where fissile materials might be present and could create a potential criticality hazard,combustible materials shall be excluded.

AllAs determined by fire hazards analysis, hot cells, caves, and glove boxes, and hoods shall be provided withfire detection in accordance with NFPA 72.

Sprinkler water flow indication can serve as a possible means of fire detection.As determined by fire hazards analysis, Ffire suppression shall be provided in all hot cells, caves, and glove

boxes, and hoodsThe preferred selected method of automatic suppression has to be compatible with the fire hazards and

consider interaction between the suppression agent and materials that are present (e.g., reactive metals). The selectionof a fire suppression system must address the potential for the spread of radioactive materials due to pressurization ofthe enclosure or by the flooding of the enclosure wil liquid fire suppression methods such as water. Accessibility forinspection, maintenance, and testing in radiation or contamination environments must also be considered in the design.Selected systems should be is an automatic sprinkler system, although other methods of suppression can also bepermitted when installed in accordance with the applicable NFPA standard. Refer to Section 5.10 for drainageprovisions.

Hot cells and caves shall be of noncombustible construction. Where combustible shielding is necessary forthe radiation hazard, appropriate fire protection features shall be installed as determined by fire hazards analysis.

Where hydraulic fluids are used in master slave manipulators, fire resistant fluids shall be used.Combustible materials inside the cells and caves shall be kept to a minimum.If explosive concentrations of gases or vapors are present, an inert atmosphere shall be provided, or the cell

or cave and its ventilation system shall be designed to withstand pressure excursions.

The glove boxes, including windows, and hoods shall be of noncombustible construction. Wherecombustible shielding is necessary for the radiation hazard, appropriate fire protection features shall be installed asdetermined by fire hazards analysis.

The number of gloves shall be limited to the minimum necessary to perform the operations.Gloves are typically the most easily ignitable component of gloveboxes and, therefore, should be

minimized. When gloves fail, potential loss of confinement can result.When the gloves are not being used, they shall be withdrawn and secured outside the box if fire hazards

are present inside the box.Securing of the gloves outside the box positions them such that fixed fire suppression in the room can be

more effective and that they do not contribute to the fuel loading in the glovebox or provide a source of ignition to otherfuels in the glovebox. Positioning them outside also reduces potential for gloves contributing to fires inside the glovebox.

When the gloves are no longer needed for operations, they shall be removed and glove port coversinstalled if fire hazards are present inside the box.

Gloves should be removed if work has been completed and no additional work requiring access to theglovebox via use of the specific gloves is identified, the glove box will not remain in-service, or fire hazards remaining inthe glovebox dictate that the gloves be removed. Gloves should not be removed strictly because immediate or shortterm use is unnecessary. Unnecessary removal of gloves creates unnecessary generation of radioactive wastes as wellas potential exposures to radioactive materials during change-out activities.

Doors shall remain closed when not in use.The concentration of combustibles shall be limited to the quantity necessary to perform the immediate task.

* Fixed inerting systems shall not be utilized in lieu of fire suppression systemFire suppression should be considered in addition to fixed inerting systems to address potential concerns

during glovebox maintenance or failure of inerting systems.If fixed extinguishing systems are utilized, the internal pressurization shall be calculated in order to prevent

gloves from failing or being blown off effects of system discharge on glovebox integrity shall be considered in evaluatingthe design of the system.

As determined by fire hazards analysis, Aa means shall be provided to restrict the passage of flamebetween glove boxes and hoods that are connected.

Fume hoods containing radioactive materials shall meet the requirements of NFPA 45,


Report on Comments – November 2012 NFPA 801. Lining materials shall be compatible with the chemical environment, and

capable of decontamination.Fume hoods provide minimal capability to confine radioactive materials. The fire hazard is generally

associated with the chemicals in-use and NFPA 45 provides the necessary requirements for design and fire protectionof fume hoods.

Combustible materials shall not be stored in fume hoods and should be the minimum necessary to supportthe work activity.

Radioactive contaminated combustible waste shall not be stored or allowed to accumulate in fume hoods.Procedures for timely waste characterization and removal shall be established.

Construction, demolition, and renovating activities that conform tothe requirements of NFPA 241, , such asthe following:(a) Scaffolding, formworks, decking, temporary enclosures, temporary containment structures, and partitions used

inside buildings shall benoncombustible or fire retardant treated.(b) If wood is used, it shall be one of the following:

i. Listed, pressure-impregnated, fire-retardant lumberii. Treated with a listed fire-retardant coatingiii. Timbers 15.2 cm × 15.2 cm (6 in. × 6 in.) or larger

(c) Tarpaulins (fabrics) and plastic films shall be certified to conform to the weather-resistant and flame-resistantmaterials described in NFPA 701,

The use of noncombustible or fire-retardant concrete formwork is especially important for large structureswhere large quantities of forms are used. Pressure-impregnated fire-retardant lumber should be used in accordancewith its listing and the manufacturer’s instructions. Where exposed to the weather or moisture (e.g., concrete forms), thefire retardant used should be suitable for this exposure. Fire-retardant coatings are not acceptable on walking surfacesor surfaces subject to mechanical damage. Use of fire-retardant paint requires special care. Inconsistent application andexposure to weather can reduce the effectiveness of fire-retardant coatings. Large timbers are occasionally used tosupport large pieces of equipment during storage or maintenance. The size of these timbers makes them difficult toignite, and they do not represent an immediate fire threat.

The appropriate form of fire protection for areas where radioactive materials exist in hospitals shall be based onthe fire hazards analysis.

Precautions shall be taken, as required, if the radioactive materials are stored or used in ways that cause them tobe more susceptible to release from their containers.

Special hazards related to protection from fire shall be controlled by a defense in depth strategy thatutilizes a combination of the following:(1) Location and separation(2) Safe operating procedures(3) Fixed detection and suppression systems(4) Inerting(5) Any other methods acceptable to the AHJ

The requirements of Sections 7.1.1 and 7.1.3 are applicable to laboratories where the requirements of NFPA 45do not provide sufficient fire protection and control of the material hazards or when determined by fire hazards analysis.

Laboratories, such as those involved in research and development, often work with small quantities ofchemicals and radioactive materials in any given operation or work activity. Laboratories frequently changeconfigurations of hazardous and radioactive materials as well as associated laboratory equipment and confinement insupport of constantly changing projects. These often changing conditions and the quantities of materials present do notlend themselves to the controls specified in Sections 7.1.1 and 7.1.3 for gas and vapor analyzers, safety controls andinterlocks, control of solvents, and control of handling and storage of combustible metals. NFPA 45 provides adequatecontrols for most laboratory operations involving chemical hazards in the presence of radioactive materials. Additionalfire protection that may be required is determined by fire hazards analysis.

The requirements of NFPA 45 shall also be applicable.Laboratories which handle pyrophoric materials shall comply with 7.1.3.

Laboratory enclosures shall comply with the requirements for hot cells, gloveboxes and hoods unless otherwisejustified in thea FHA concludes that the amount of radioactive material is inconsequential.


Report on Comments – November 2012 NFPA 801

Reactivity control shall be capable of inserting negative reactivity to achieve and maintain subcritical conditions inthe event of a fire.

Inventory and pressure control shall be capable of controlling coolant level such that fuel damage as a result of afire is prevented.

Decay heat removal shall be capable of removing heat from the reactor core such that fuel damage as a result offire is prevented.

Vital auxiliaries shall be capable of performing the necessary functions in the event of a fire.Process monitoring shall be capable of providing the necessary indication in the event of a fire.

The term nuclear facilities as applicable to NFPA 801 represents an extremely broad spectrum offacilities with tremendous variation in mission, function, design, operations, hazardous chemicals, radioactive materialinventories, fire risks and protection needs. The types of facilities covered by NFPA 801 and the requirements of thischapter may include small research and development laboratories, large processing facilities, or non-power reactors.The fire protection needs for these facilities are as varied as the facilities themselves. For this reason, inflexible,prescriptive fire protection requirements do not meet the specific facility and hazard protection needs and the firehazards analysis becomes paramount in defining and evaluating the appropriate level of protection for the hazards andconfigurations unique to the facility. The importance of the FHA and flexibility in the application of requirements for thevariability in nuclear facility hazards is the primary basis for the proposed changes and this approach is consistent withChapter 4 and 6 of this standard. Additional discussion of the specific changes follows:Sections 7.1.1.3 and 7.1.1.4 is revised to indicate that gas- or vapor-analyzers should be installed if determined by fire

hazards analysis. There are options to designing protection against combustible gases and vapors that do not involvethe complexities of installing and maintaining analyzers. The standard is not clear on the conditions that must beassumed for installation of the analyzers (e.g., normal operation, upset conditions, ventilation on or off). The standardprovides no guidance relative to the design, installation, operation, or response to analyzer output or alarms. In thecase of laboratory operations, the types of gases or vapors may change frequently with work activities or new projects.The changing configuration of the work space, equipment, and materials does not support use of these types of devicesin most cases.Section 7.1.1.5 The use of the term “lower flammable limit” is consistent with the terminology that is used in NFPA 30.

Although both terms have the same meaning, the reference to flammable limits when referring to hazards associatedwith flammable liquids should follow NFPA 30. If “lower flammable limit” is not used, “lower explosive limit” needs to bedefined.Section 7.1.1.8.2 is revised to provide flexibility to implement appropriate level of control if necessary. “Approved” is

deleted as this implies the AHJ must accept the limits that are established, which is not consistent with typical practice.Controls and limits on use solvent is typically established in user procedures. The exception may be where permitting isrequired for quantities that exceed fire code or other similar regulatory thresholds.Section 7.1.1.8.4 is revised to allow flexibility. Arbitrarily establishing a 3-hour separation does not allow for

consideration of the magnitude of the hazard. Solvent distillation can be as small as 0.25 liter or on a much larger scale.Fire protection should be provided at a level appropriate for the hazard.Section 7.1.3.5 is deleted on the basis that control of fissile materials is governed by its own set of regulatory

requirements and national standards. These criticality specific requirements and standards encompass the issues ofneutron moderation or configuration changes that might occur as a result of automatic or manual suppression actions.These requirements in NFPA 801 for criticality are not appropriate for a fire protection standard, are not sufficientlycomplete to address the criticality hazard, and are covered in other governing regulations.Sections 7.1.4.1, 7.1.4.2 and associated Annex A content is revised to base the selection and installation of fire

detection and suppression on the basis of the fire hazards analysis. The committee’s substantiation for the significantchange to require “ALL” hot cells, caves, and gloveboxes to have automatic fire suppression systems was notsubstantiated based on number of fires, significant fires, or any other data that justified the change to require “all” hotcells, caves, and gloveboxes to have automatic fire suppression systems. There has to be a graded approach todetermining which hot cells, caves, and gloveboxes need to have automatic fire suppression systems. The fire hazardsanalysis is the correct tool for evaluating the hazards and determining the whether or not a hot cell, cave, or gloveboxneeds automatic fire suppression. The variability of hot cell, cave, and glovebox design and operations demands thecapability to engineer appropriate protection based on the specific configuration, use, and hazards. Our laboratoryoperates may caves that have not fire hazards associated with them and it would be very expensive to install and


Report on Comments – November 2012 NFPA 801maintain automatic fire suppression systems when there is no value added. Spread of radioactive materials associatedwith the activation of a fire suppression system also has to be considered in the selection of an automatic firesuppression system. Hoods have been separated from these requirements into a separate section (discussed later)because they do not serve the same purpose or function relative to radioactive material confinement and shielding. Theapplication of suppression systems must be done with consideration for material compatibilities, hazards, post-actuationcleanup, and inspection testing and maintenance of the systems in radiation environments.Sections 7.1.4.3.1 and 7.1.4.4.1 are revised to note that combustible shielding may be necessary in some applications,

particularly where neutron shielding is necessary. Fire protection for these applications should be based on the firehazards analysis.Section 7.1.4.4.2 is deleted because regulating the necessary number of gloves is impractical and isn’t considered in

an integrated manner with the other fire hazards that are present. Gloveboxes are generally designed to place gloveswhere they are needed. This level of control should be left to the operating entity as part of overall fire hazardsmanagement.Section 7.1.4.4.2 (renumbered) and Section 7.4.4.3 are similarly revised to provide a more practical level of control for

gloves. Not all gloveboxes necessarily have significant fire hazards.Section 7.1.4.4.7 (renumbered) is revised to focus the requirement on evaluating the extinguishing system effects on

glovebox integrity, not simply over-pressurization. Under fire conditions, glove failure may occur prior to systemactuation so glove failure from over-pressurization is not necessarily governing. The extinguishing system is designedaccording the hazard present and the appropriate rate of application of agent. The objective to extinguish the fire maynot support the objective of protecting the box, but the impacts on box integrity should be understood and the designshould consider these impacts appropriately.Section 7.1.4.4.8 (renumbered) is revised to base the design of restrictions between gloveboxes on the fire hazards

analysis. Gloveboxes come in all sizes and connection restrictions are not always necessary relative to the hazardspresent. There is usually an air lock with 2 doors between the glovebox and any other connected hoods, so properoperation of the air lock would prevent direct passage of flames.Section 7.1.4.5 is a new proposed section on hoods. Hoods in the context of radioactive material handling and use are

significantly different than hot cells, gloveboxes, and caves. Hoods provide no shielding or significant confinementcapability for work with radioactive materials and the hazards associated with radioactive materials in hoods aregenerally dominated by the hazards of the chemicals. Hoods are designed and tested to remove vapors and not toconfine radioactive materials. On this basis, NFPA 45, which has extensive requirement for hoods, should be thegoverning standard. Where additional protection is necessary, the fire hazards analysis required elsewhere in thisstandard will govern the determination. The placement of detection and/or fire suppression in most fume hoods has notbeen established as being necessary unless operations with open containers of flammable liquids are performed. Dueto the nature of the operations that are typically performed in fume hoods, there are no specific types of fire detection orfire suppression that would provide reliable detection and /or suppression for all types of hazardous materials that aretypically used in fume hoods. NFPA 45 8.10 does not require automatic fire suppression for fume hoods unless there isa hazard present that warrants automatic fire suppression.Section 7.4.1 and A.7.4.1 are revised to identify NFPA 45 as the governing standard for fire protection in laboratories

using chemicals in the presence of radioactive materials as opposed to the requirements in Sections 7.1.1 and 7.1.3unless NFPA 45 is not sufficient in its requirements or additional protection is specified by a fire hazards analysis.Protection against the chemical hazards in laboratory-scale work activities will generally provide the necessaryprotection against loss of control or confinement of radioactive materials. The requirements for hot cells, gloveboxesand hoods are followed unless otherwise justified.





7.1.1.3 In enclosed spaces in which combustible gas could accumulate to hazardous levels as demonstrated by theFHA outside of the storage vessels, piping, and utilization equipment, combustible-gas analyzers that are designed forthe specific gas shall be installed.

Enclosed spaces in which minor or de minimis quantities of flammable gas might be present do notnecessarily required the installation of a combustible gas analyzer. For example, a lecture size bottle of gas located in avery large volume space might never have the potential to create a mixture that would approach the lower explosive limitin the space. A combustible gas analyzer, in this case, would provide no safety benefit. Paragraph 7.1.1 3 should onlyrequire combustible gas analyzers where significant, hazardous quantities or concentrations of gas might be created, asdemonstrated in the FHA.

_______________________________________________________________________________________________801- Log #14



7.1.1.4 Flammable and combustible liquids in enclosed spaces in which vapors have the potential to accumulate inhazardous amounts or concentrations as demonstrated by the FHA outside of the storage vessels, piping, and utilizationequipment shall be Installed with combustible-vapor analyzers appropriate for the vapors generated

Enclosed spaces In which minor or de minimis quantities of flammable vapors might be present do notnecessarily required the installation of a combustible vapor analyzer. For example, a small volume of flammable liquidlocated in a very large volume space might never have the potential to create a mixture that would approach the lowerexplosive limit in the space. A combustible vapor analyzer, in this case, would provide no safety benefit. Paragraph7.1.1.4 should only require combustible vapor analyzers where significant, hazardous quantities or concentrations of gasmight be created as demonstrated in the FHA.

_______________________________________________________________________________________________801- Log #15



7.1.1.8.3 An approved fixed fire-extinguishing system shall be installed or its absence justified to the satisfaction of theFHA to provide fire protection for flammable or combustible solvents where required by the FHA.

The topic of 7.1 is "General." The topic of 7.1.1 is "Flammable and Combustible Liquids and Gases."The topic of 7.1.1.8 is "Solvents." As such, the requirements of 7.1.1.8 will apply to all solvents, in any amount, and inany location.It is important to specify some qualification to clarify when the requirements will apply. Minor amount of solvents will not

require fixed protection and should not necessarily require evaluation 'in the FHA. Significant, hazardous quantitiesmight need protection as demonstrated in the FHA.





7.1.1.8.4* Solvent distillation and recovery equipment for flammable or combustible liquids shall be isolated from areasof use by 3 hour fire barriers as required by the FHA.

Delete the asterisk from 7.1.1.8.4 since the proposed change no longer has an annex paragraphassociated with it and none is needed.Not all solvent recovery processes using combustible solvents need to be isolated by fire barriers Where isolation by

fire barriers is desirable, the hazard might not warrant at 3-hour fire rating. The need for isolation and the rating of anynecessary fire barrier should depend on the degree of hazard as determined by analysis in the FHA.

_______________________________________________________________________________________________801- Log #17



7.1.2.3 Incinerators shall be in accordance with NFPA 82,as determined as applicable by the FHA.

Special incinerators as might be used in nuclear facilities are quite different than the waste and linenhandling systems address by NFPA 82. Much of what is contained in NFPA 82 is just not applicable to radioactivematerial incinerators.Those parts of NFPA 82 that might be applicable to special radioactive material incinerators should be limited to those

which have been analyzed and specified in the FHA.

_______________________________________________________________________________________________801- Log #18


801-47Delete 7.1.3.5.2 in its entirety.

The requirement expressed in 7.1.3.5.2 is an absolute. All combustible materials must be excludedwhere fissile material might be present. This is not necessary, is difficult to achieve, and, in many cases might beimpossible. The intent of this paragraph is adequately covered by other requirements in NFPA 801 and will beaddressed in any FHA that evaluates requirements for protection of combustible materials.

_______________________________________________________________________________________________801- Log #19



7.1.4.1 All hot cells, caves, glove boxes, and hoods shall be provided with fire detection in accordance with NFPA 72as determined by the FHA.

Not all enclosures need fire detection. The need for detection depends on the degree of hazard. Firedetection should be provided for enclosures based on the hazard as determined by the FHA.





7.1.4.2* Fire suppression shall be provided in all hot cells, caves, glove boxes, and hoods as determined by the FHA.Not all enclosure need fire suppression. In some cases, it may be necessary to prohibit fire

suppression in some enclosures. The need for detection depends on the degree of hazard. Fire suppression should beprovided for enclosures based on the hazard as determined by the FHA.

_______________________________________________________________________________________________801- Log #30

_______________________________________________________________________________________________Neal T. Hara, Idaho National Laboratory

801-47Comment to Accept in Principle and revise proposed new section 7.1.4.2 as follows:

“ Fire suppression shall be provided in all hot cells, caves, glove boxes, and hoods as determined by the firehazard analysis”

Per the accepted ROP 801-52, a Fire Hazards Analysis (FHA) will be required to analyze hazardsassociated with all hot cells, caves, glove boxes, and hoods. The FHA determines what type of suppression isnecessary for these enclosures. This same analysis should also be allowed to determine if internal suppression isnecessary.The requirement for providing fire suppression for the inside of an enclosures listed in the proposed section 7.1.4.2 is

overly conservative. Application of the rigid requirement has and will continue to result in substantial costs for systemsthat may only provide a negligible increase in protection, especially for those small systems with minimal amounts ofradioactive materials or other fire hazards.The committee’s stance concerning the intention that all glove boxes, caves, hot cells, and hoods require fire

suppression systems is highly prescriptive and requires application of the requirements without an allowance to evaluatethe risk to personnel and facilities from fire and/or release of radioactive materials.The following two existing sections indicate that it is the intent of the standard is to base the protection on risk and not a

prescriptive requirement:4.2.3 The evaluation shall consider acceptable means for separation or control of hazards, the control or elimination of

ignition sources, and the suppression of fires.6.7.1* Fire suppression systems and equipment shall be provided in all areas of a facility as determined by the fire

hazards analysis.The following newly proposed and accepted section 6.1.1 also indicates that a graded approach commensurate with

the hazard is appropriate (ROP 801-40):6.1.1 A fire hazards analysis shall be performed to determine the fire protection requirements for the facility, using a

graded approach based on the hazard presented by the facility.The substantiation supporting this section goes on to state that a one-size-fits-all approach is not the best approach for

facilities that span a wide spectrum of risk. This same approach should be used for hot cells, caves, glove boxes andhoods.The committee stance is also not consistent with many other portions of the standard that base the level of protection

on the risk as analyzed by the FHA. Other examples within the current version of NFPA 801, where fire protectionfeatures are determined by the fire hazard analysis, include but are not limited to the following sections 5.4, 5.7.2,5.9.2.1, 5.9.3.3, 5.9.4.2, 5.9.4.3, 5.9.5.5, 5.9.5.9, 5.9.5.12, 6.1.1, 6.1.2, 6.1.3, 6.2.2, 6.4.1, 6.4.2, 6.5.1, and 6.8.2.




801-66Revise 7.1.4.3.4 as follows:

7.1.4.3.4 During normal or abnormal operating conditions, if there is potential for are combustible flammable gases orvapors to be present in excess of 25 percent of the lower flammability limit in explosive concentrations, then an inertingatmosphere shall be provided where required by the FHA.And delete 7.1.4.3.4.1 in its entirety:7.1.4.3.4.1 During normal or abnormal operating conditions involving hot cells, hoods, or caves, if there is potential for

combustible gases or vapors to be present in excess of 25 percent of the lower flammability limit, then ventilation shallbe permitted as an alternative method to 7.1.4.3.

The original proposal addresses the need for an inert atmosphere where an explosive concentration ispresent in a glovebox The intent was significantly changed by the committee action to include any glovebox whereunder abnormal conditions (for example, loss of ventilation), there is a potential for approaching 25% of LFL. This is ahuge difference which is not likely necessary in most instances. Take for example, a small glovebox in which there is asmall bottle of acetone. With loss of ventilation and a spill of the acetone, it is possible that the vapor concentrationmight approach 25% of LFL but never be capable of approaching an explosive concentration. The text of 7.1.4.3.4 aspublished in the ROP would require an inert atmosphere in nearly all gloveboxes which contain small amounts offlammable liquids or gases. There are more appropriate means of dealing with potential flammable vapors or gases ingloveboxes than always requiring an inert atmosphere. Inert atmospheres are warranted where normal operations areconducted within the flammable range. The FHA will determine protection required.Proposed 7.1.4.3.4.1 does not make sense and should be deleted. If loss of ventilation is one of the abnormal

conditions that could lead to a concentration in excess of 25% LFL, then ventilation would not be the appropriatealternative to be permitted.

_______________________________________________________________________________________________801- Log #21



7.1.4.4.1 The glove box, windows, and hoods shall be of noncombustible construction or of acceptable alternatematerial as evaluated in the FHA and approved by the Authority Having Jurisdiction ..

It is not reasonable, in all cases, to use noncombustible construction for viewing windows Ingloveboxes and hoods. Alternate, low hazard materials might be used as an acceptable alternative. Paragraph 7.1.4.4.1should allow for approved alternative materials.

_______________________________________________________________________________________________801- Log #22


801-47Delete 7.1.4.4.3 in its entirety.

It might not be practical or necessary for adequate fire safety to secure gloves outside of gloveboxeswhen the gloves are not in active use. Withdrawing the gloves might also subject them to increased damage.





7.1.4.4.7* Fixed inerting systems shall not be utilized be permitted to be used in lieu of fire suppression systems whereallowed by the FHA.

There may be cases where inerting systems are a very appropriate alternative to a fixed firesuppression system NFPA 801 should allow for fixed inerting systems In accordance with the FHA.

_______________________________________________________________________________________________801- Log #3


801-6Delete proposed A.1.3.2.2(3).

The scope of NFPA 801 includes all facilities handling radioactive materials including facilities such asresearch reactors, nonreactor research facilities, production reactors, production facilities, other non reactor nuclearfacilities, hospitals, and others facilities. The standard specifically excludes light water reactor electric generating plantswhich are covered by NFPA 804 and 805. The explanatory material included in proposed A.1.3.1.2(3) is not particularlyapplicable to the type of facilities covered by this standard "Essential Safety Functions" are not defined in this standard.Many of the facilities covered by this standard will not have any essential safety functions, decay heat removal needs, orfission product boundaries. There is no need for this standard to attempt to apply reactor safety concepts to facilities forwhich they are not applicable.

_______________________________________________________________________________________________801- Log #2


801-3Delete proposed A.4.2.(1) and proposed A.4.2.(4)

.The committee has proposed a new annex section to 4.2 on Fire Hazard Analysis for nuclear facilities.

The scope of the document includes all facilities handling radioactive materials including facilities such as researchreactors, nonreactor research facilities. production reactors, production facilities, other non reactor nuclear facilities,hospitals, and othersThe standard specifically excludes light water reactor electric generating plants which are covered by NFPA 804 and

805. The Radioactive and Hazardous Materials Release Goal and Objectives and The Life Safety Goal and Objectivesare appropriate for all types of nuclear facilities. However, the Nuclear Safety Goal and Objectives proposed in A.4.2 areapplicable only to certain types of nuclear reactors (covered by other NFPA standards) and are not applicable to thevast majority of facilities that are subject to NFPA 801 and should be deleted from this annex section.





An FHA, in the context used in this standard, should serve as an evaluation tool for design and therefore shouldinclude a goal-oriented approach, particularly when discussing topics when there are no deterministic requirements inthis standard. The evaluation should address goals and objectives that include the following:

The nuclear reactor safety goal should be to provide assurance that radioactivematerials a fire during any operational mode or configuration will not prevent the reactor from achieving and maintainingthe fuel should be maintained in a safe and stable condition in the event of a fire.

The radioactive and hazardous material release goal shouldbe to provide reasonable assurance that a fire will not result in the release of radiological or hazardous material thatadversely affects the public, plant personnel, or the environment.

The life safety goal should be to provide reasonable assurance that loss of life in the event of firewill be prevented for facility occupants.

In the event of a fire during any operational mode and process configuration,the nuclear safety objectives should be as follows:(a) Reactivity control — capable of achieving and maintaining subcritical conditions(b) Cooling — capable of achieving and maintaining decay heat removal(c) Fission product boundary — capable of maintaining fundamental fuel geometry(d) Heat transfer medium inventory control — capable of maintaining the necessary quantity of heat transfer medium(e) Preventing subcritical fissionable material becoming critical by the introduction of water and concurrent violation

with safe separation ofsubcritical masses(fe) Maintain monitoring of safety functions

The radiological and hazardous material releaseobjective should be as follows:(a) Prevent exposure, uncontrolled release, or unacceptable dispersion of hazardous substances, nuclear material, or

radioactive material, due to fires(b) Prevent subcritical fissionable material becoming critical by the introduction of water and concurrent violation with

safe separation of subcritical massesThe life safety objectives should be to protect occupants not intimate with the initial fire

development from loss of life and improve the survivability of those who are intimate with the fire development, as wellas to provide protection for Ppersonnel required to carryout manual actions to achieve the nuclear safety and radioactiverelease objectives and the associated emergency personnelresponse.

The proposed adoption of goals and objectives from NFPA 805 and 806 does not translate well to thebroader spectrum of facilities subject to the requirements of NFPA 801, which includes non-power reactors, largeprocess operations, research and development laboratories or small industrial users. For example, changing theNuclear Safety Goal to apply the term “safe and stable” to radioactive materials creates ambiguity. This term hasspecific meaning to reactors, but it’s uncertain how this term would be applied to the infinite types, forms, quantities, andconfigurations of radioactive materials in spectrum of facilities covered by this standard. For reactors the primary fireprotection goals and objectives are to protect the integrity of the fuel. For other facilities, the primary objectives are toprotect against radioactive material release. The changes maintain consistency with NFPA 805 and 806 bydifferentiating the safety goals and objectives for reactors from the safety objectives facilities handling radioactivematerials.




801-38Add a new A.5.9 5. as follows: Smoke Control Systems in nuclear facilities might have additional

functions to serve as confinement ventilation systems to prevent the release of radioactive materials Because of theunique nature of Smoke Control Systems in nuclear facilities, it is not the intent of NFPA 801 that smoke ventilationsystems in these facilities be required to be installed in accordance with NFPA standards on smoke control or smokemanagement systems such as NFPA 92, , NFPA 92A,

, NFPA 92B,, or NFPA 204,

should be provided, designed, and installed in accordance with the FHA with due consideration of theradiological implications of the ventilation system.Other NFPA standards may be applied as referenced by the FHA. NFPA 801 does not specifically reference or require

compliance with these other smoke-related NFPA standard for application to nuclear facilities.NFPA 801 should make it clear that compliance with other smoke-related NFPA standards is not

necessarily required due to the unique nature of nuclear ventilation systems. Full compliance with the requirements ofthe other NFPA standards might not be possible due to confinement system limitations. The ventilation systemsprovided for smoke ventilation should be per the FHA.

_______________________________________________________________________________________________801- Log #8


801-38Revise A.5.9.5.4.3 to replace the text that is proposed to be deleted which would read:

A.5.9.5.4.3 Smoke infiltration into enclosed stairwells can be accomplished by providing passive fire barriers inaccordance with NFPA 801 and NFPA 101 which, in addition to providing fire separation, restrict the movement ofsmoke. Active smoke control for stairwells or the construction of smokeproof towers may be necessary only if the needis demonstrated by the FHA.

The committee action on proposed 5 9.5.4.3 proposes to delete the former annex material related toenclosed stairwells. This public comment proposes some clarifying text for A.5.9.5.4.3 to confirm that a special smokecontrol system for enclosed stairwells is not necessarily required. NFPA 801 requires that NFPA 101, ,be applied to nuclear facilities. Enclosed exit stairways must comply with NFPA 101. NFPA 101 requires that where exitstairways must be enclosed, the stairways are enclosed by fire barriers. Both NFPA 801 and NFPA 101 define firebarriers as having inherent qualities to limit the spread of fire and restrict the movement of smoke. By definition, anystairwell that IS enclosed for means of egress will restrict smoke infiltration.





A.5.13.2 Electrical circuits and components in reactor facilities present the same type of fire protection problems as inother industrial facilities. The prime concern in the reactor facility handling radioactive materials is directed toward thosecircuits and components essential to continued operation of the reactor facility and particularly to those essential to asafe shutdown and stable configuration radiological confinement under emergency conditions. For these reasons,special care is devoted to redundancy of systems, emergency power supplies, separation, physical protection, andreliability.

"Safe shutdown" and "safe and stable conditions" are well defined terms for different types of reactors."Safe shutdown and stable configuration" do not necessarily apply to non-reactor nuclear facilities. However,radiological confinement is critical to all type of nuclear facilities. It is recommended that "radiological confinement" besubstituted for "safe shutdown and stable configuration."

_______________________________________________________________________________________________801- Log #27



American Society for Testing and Materials, 100 Barr Harbor Drive, West Conshohocken,PA 19428-2959.ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials 2012 2010ASTM E 136, Standard Test Method for Behavior of Building Materials in a Vertical Tube Furnace at 750°C, 2011.ASTM E 380, Rev. A-89.

Also revise A.1.6 to replace ASTM E380 by IEEE/ASTM SI 10.Standards update -


2012 FALL REVISION CYCLE

*Proposal Closing Dates may vary according to documents and schedules for Revision Cycles may change. Please check the NFPA Website for the most up-to-date

information on Proposal Closing Dates and schedules at www.nfpa.org/document# (i.e. www.nfpa.org/101) and click on the Next Edition tab.

PROCESS

STAGE PROCESS STEP DATES

FOR TC

DATES FOR TC

WITH TCC

1 PRELIMINARY 1.0 Notification of intent to enter cycle 1/7/11 1/7/11

2 REPORT ON

PROPOSALS (ROP)

2.1 Proposal closing date* 5/23/11* 5/23/11* 2.2 Final date for ROP meeting 8/26/11 8/5/11 2.3 Final date for mailing TC ballots 9/16/11 8/19/11 2.4 Receipt of (TC) ballots by staff liaison 10/21/11 9/9/11 2.5 Receipt of TC recirculation ballots 11/4/11 9/16/11 2.6 Final date for TCC meeting 10/14/11 2.7 Final date for mailing TCC ballots 10/21/11 2.8 Receipt of TCC ballots 11/11/11 2.9 Receipt of TCC recirculation ballots 11/18/11 2.10 Final copy (w/ ballot statements) to Secretary, Standards Council 11/11/11 11/25/11 2.11 Completion of Reports 11/18/11 12/2/11 2.12 ROP Published and Posted 12/23/11 12/23/11

3 REPORT ON

COMMENTS

(ROC)

3.1 Comment closing date 3/2/12 3/2/12 3.2 Final date for ROC meeting 5/4/12 4/6/12 3.3 Final date for mailing TC ballots 5/18/12 4/20/12 3.4 Receipt of (TC) ballots by staff liaison 6/1/12 5/11/12 3.5 Receipt of TC recirculation ballots 6/8/12 5/18/12 3.6 Final date for TCC meeting 6/15/12 3.7 Final date for mailing TCC ballots 6/22/12 3.8 Receipt of TCC ballots 7/13/12 3.9 Receipt of TCC recirculation ballots 7/20/12 3.10 Final copy (w/ ballot statements) to Secretary, Standards Council 6/22/12 7/27/12 3.11 Completion of Reports 7/13/12 8/3/12 3.12 ROC Published and Posted 8/24/12 8/24/12

4 TECH SESSION

PREPARATION

(& ISSUANCE)

4.1 Notice of Intent to Make a Motion (NITMAM) Closing Date 10/5/12 10/5/12 4.2 Posting of Filed NITMAM (Motions Committee Report) 11/2/12 11/2/12 4.3 Appeal Closing Date for Consent Documents or without NITMAM 11/17/12 11/17/12

4.4 Council Issuance for Consent Documents or without NITMAM 11/27/12 11/27/12

5 TECHNICAL

SESSION 5.0 Association Meeting for Documents with Certified Amending Motions (CAMs)

6/9-13/13 6/9-13/13

6 APPEALS &

ISSUANCE 6.1 Appeal closing date for Documents with CAMs 7/3/13 7/3/13 6.2 Council issuance date for Documents with CAMs 8/1/13 8/1/13

NFPA 801 ROC Meeting 801 ROC... · NFPA 801 ROC Meeting ... Neal W. Krantz, Sr. ... Wayne and Kevin...

Documents

Transcript of NFPA 801 ROC Meeting 801 ROC... · NFPA 801 ROC Meeting ... Neal W. Krantz, Sr. ... Wayne and Kevin...