NFPA 801 ROC Meeting

Transcription

1 Technical Committee on Fire Protection for Nuclear Facilities NFPA 801 ROC Meeting Embassy Suites Airport 5055 International Boulevard North Charleston, SC 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 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 Reports and Formation of Committee Comments (Time Permitting) 4. Old Business 5. New Business 6. Adjourn at12:00pm ET

2 Address List No Phone Fire Protection for Nuclear Facilities 03/09/2012 Paul May William B. Till, Jr. Chair Savannah River Nuclear Solutions, LLC 197 Till Hill Road Orangeburg, SC : James W. Naylor U 4/17/1998 Ivan Bolliger Canadian Nuclear Safety Commission 280 Slater Street Ottawa, ON K1P 5S9 Canada E 8/5/2009 Craig P. Christenson US Department of Energy Richland Operations Office 825 Jadwin Avenue, A5-17, Room 586 Richland, WA : James G. Bisker E 1/14/2005 Stanford E. Davis PPL Susquehanna LLC Susquehanna Steam Electric Station 769 Salem Boulevard Berwick, PA : Frank S. Gruscavage U 4/17/1998 Richard L. Dible AREVA NP, Inc Southwest Blvd., Suite 400 Fort Worth, TX M 11/2/2006 Edgar G. Dressler SE 87th Bourne Avenue The Villages, FL American Nuclear Insurers : Seth S. Breitmaier I 4/1/1995 David R. Estrela Orr Protection Systems, Inc. 38 Blanchard Road Grafton, MA IM 10/28/2008 Daniel J. Hubert Janus Fire Systems 1102 Rupcich Drive, Millennium Park Crown Point, IN IM 10/28/2008 Steven W. Joseph Xtralis, Inc SW Foothill Drive Portland, OR M 10/18/2011 Robert Kalantari EPM, Incorporated Engineering Planning & Management 959 Concord Street Framingham, MA : Paul R. Ouellette SE 1/15/1999 Robert P. Kassawara Electric Power Research Institute 3412 Hillview Avenue Palo Alto, CA : John P. Gaertner U 7/24/1997 Elizabeth A. Kleinsorg Kleinsorg Group Risk Services, LLC A Hughes Associates Company 200 Brannan Street, Unit 208 San Francisco, CA : Andrew R. Ratchford SE 10/10/1997 1

3 Address List No Phone Fire Protection for Nuclear Facilities 03/09/2012 Paul May Neal W. Krantz, Sr. Krantz Systems & Associates, LLC Bretton Livonia, MI Automatic Fire Alarm Association, Inc. : Fred M. Leber M 1/1/1992 Christopher A. Ksobiech We Energies 231 West Michigan, P378 Milwaukee, WI : Jeffery S. Ertman U 7/17/1998 Paul W. Lain US Nuclear Regulatory Commission MS: O-10C15 Washington, DC : Daniel M. Frumkin E 4/3/2003 John D. Lattner Southern Nuclear 40 Inverness Center Parkway Birmingham, AL U 8/9/2011 Charles J. March Defense Nuclear Facilities Safety Board 625 Indiana Avenue Washington, DC E 10/20/2010 Anca McGee Ontario Power Generation Box 4000, Internal Mail: D10-2 Bowmanville, ON L1C 3Z8 Canada U 8/9/2011 Frank Monikowski Tyco/SimplexGrinnell 230 Executive Drive Cranberry Township, PA National Fire Sprinkler Association : James Bouche M 7/23/2008 Bijan Najafi Science Applications International Corp Dell Avenue, Suite 100 Campbell, CA SE 7/12/2001 Ronald Rispoli Entergy Corporation 2414 West 5th Street Russellville, AR Nuclear Energy Institute : Robert K. Richter, Jr. U 4/4/1997 Clifford R. Sinopoli, II Exelon Corporation Peach Bottom Atomic Power Station 1848 Lay Road, MS SMB3-4 Delta, PA Edison Electric Institute U 1/1/1990 Cleveland B. Skinker Bechtel Power Corporation 5275 Westview Drive Frederick, MD : Arie T. P. Go SE 1/15/2004 Wayne R. Sohlman Nuclear Electric Insurance Ltd Market Street, Suite 1100 Wilmington, DE : Thomas K. Furlong I 1/1/1993 James R. Streit Los Alamos National Laboratory PO Box 1663, Mail Stop K493 Los Alamos, NM : Neal T. Hara U 1/16/1998 2

4 Address List No Phone Fire Protection for Nuclear Facilities 03/09/2012 Paul May Donald Struck Siemens Fire Safety 8 Fernwood Road Florham Park, NJ National Electrical Manufacturers Association : Daniel P. Finnegan M 8/5/2009 William M. Sullivan Contingency Management Associates, Inc. 109 Miller Sreet Middleboro, MA SE 4/17/1998 Ronald W. Woodfin TetraTek, Inc. Fire Safety Technologies West Cool Breeze Lane Montgomery, TX : David M. Hope SE 1/15/2004 James G. Bisker US Department of Energy Nuclear Safety Policy & Assistance (HS-21) 1000 Independence Avenue, SW Washington, DC : Craig P. Christenson E 8/2/2010 James Bouche F.E. Moran, Inc. Special Hazard Systems 2265 Carlson Drive Northbrook, IL National Fire Sprinkler Association : Frank Monikowski M 7/23/2008 Seth S. Breitmaier American Nuclear Insurers 95 Glastonbury Boulevard, Suite 300 Glastonbury, CT : Edgar G. Dressler I 10/18/2011 Jeffery S. Ertman Progress Energy 410 South Wilmington Street Raleigh, NC : Christopher A. Ksobiech U 4/15/2004 Daniel P. Finnegan Siemens Industry, Inc. Building Technology Division Fire Safety Unit 8 Fernwood Road Florham Park, NJ National Electrical Manufacturers Association : Donald Struck M 10/18/2011 Daniel M. Frumkin US Nuclear Regulatory Commission Rockville Pike, MS 011A11 Rockville, MD : Paul W. Lain E 11/2/2006 Thomas K. Furlong Nuclear Service Organization 1201 North Market Street, Suite 1100 Wilmington, DE : Wayne R. Sohlman I 1/12/2000 John P. Gaertner Electric Power Research Institute PO Box Charlotte, NC : Robert P. Kassawara U 10/23/2003 Arie T. P. Go Bechtel National, Inc. 50 Beale Street San Francisco, CA : Cleveland B. Skinker SE 10/1/1993 3

5 Address List No Phone Fire Protection for Nuclear Facilities 03/09/2012 Paul May Frank S. Gruscavage PPL Susquehanna LLC 769 Salem Boulevard Berwick, PA : Stanford E. Davis U 1/18/2001 Neal T. Hara Idaho National Laboratory PO Box 1625 Idaho Falls, ID : James R. Streit U 03/05/2012 David M. Hope TetraTek Inc. Fire Safety Technologies 204 Masthead Drive Clinton, TN : Ronald W. Woodfin SE 4/15/2004 Fred M. Leber LRI Fire Protection Engineering Yonge Eglinton Center 2300 Yonge Street, Suite 2100 PO Box 2372 Toronto, ON M4P 1E4 Canada Automatic Fire Alarm Association, Inc. : Neal W. Krantz, Sr. M 10/20/2010 James W. Naylor Savannah River Nuclear Solutions Building 742-A PO Box 616 Aiken, SC : William B. Till, Jr. U 3/15/2007 Paul R. Ouellette EPM, Incorporated Engineering Planning & Management 959 Concord Street Framingham, MA : Robert Kalantari SE 7/19/2002 Andrew R. Ratchford Ratchford Diversified Services, LLC 346 Rheem Blvd. Suite 207D Moraga, CA : Elizabeth A. Kleinsorg SE 4/16/1999 Robert K. Richter, Jr. Southern California Edison Company 5000 Pacific Coast Hwy, AWS D2J San Clemente, CA Nuclear Energy Institute : Ronald Rispoli U 4/15/2004 Tzu-sheng Shen Nonvoting Member Central Police University 56 Shu-Jen Road Ta-kan-chun, Kuei-san Taoyuan, 333 Taiwan SE 7/29/2005 Leonard R. Hathaway Member Emeritus 1568 Hartsville Trail The Villages, FL I 1/1/1976 Walter W. Maybee Member Emeritus 2200 Lester Drive NE, Apt 475 Albuquerque, NM /1/1971 Paul May Staff Liaison National Fire Protection Association 1 Batterymarch Park Quincy, MA /29/2007 4

6 NFPA 1 Batterymarch Park, Quincy, MA USA Phone: (617) Fax: (617) 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

7 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

8 Leonard Hathaway Walter Maybee No No STAFF Paul May Yes GUESTS Seth Breitmaier Paul Nelson Yes 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 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.

9 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 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.

10 801- Log #32 Andrew Minister, Battelle Pacific Northwest National Laboratory These requirements shall be applicable to all locations where radioactive materials that meet the thresholds established in 10 CFR 30 are stored, handled, or used in quantities and under conditions requiring where specified by governmental regulations (e.g., those of the U.S. Nuclear Regulatory Commission, or U.S. Department of Energy, or other governmental nuclear regulatory body) applicable to non-power nuclear reactors or to the possession or 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 level depending on the material and use. The regulations of the governing authority specify the applicability of the fire protection requirements in this standard for those who possess, use, handle, or store radioactive materials or operate non-power reactors. The possession and use of radioactive material and the operation of processing, production, or utilization facilities, including non-power reactors is governed by governmental regulations, whether federal, state or governmental body in countries outside of the United States. The specific thresholds for regulation of materials can be substantially different across the various agencies with authority over these materials. The requirements governing safety or radioactive materials, including fire protection, are imbedded in the individual regulations of the governing authority for a particular use or facility. This standard is subordinate to those regulations. Rather than attempt to define a common material threshold that is acceptable to each regulatory entity, the applicability should be deferred to the individual agencies regulations and implementing requirements Log #29 Neal T. Hara, Idaho National Laboratory Accept Proposal (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, roughly speaking, those levels for which continuous long term occupational exposure of the public to radioactive materials would not exceed a predetermined dose levels. Federal Register, Volume 33, No.156 Saturday, August 10, 1968 (pages through 11417) provided additional clarification of the basis for the 10 CFR 30, Schedule B threshold. The discussion within the federal register describes the schedule B quantity basis (continuous exposure over one year for inhalation hazards and 1 milliroentgen per hour for direct gamma radiation hazards). Since items with quantities of radioactive material less than those listed in schedule B are essentially uncontrolled after being supplied to the general public, the quantities are limited and are not appropriate for determining exposure of the public or emergency response personnel during or after a fire. 1

11 801- Log #26 Marcelo M. Hirschler, GBH International ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials ASTM E814, Standards update Log #1 John F. Bender, Underwriters Laboratories Inc Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL UL 723,, 2008, Revised ANSI/UL 1479, 2003, revised Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL UL 723,, 2008, Revised Add ANSI approval designation to ANSI/UL 1479 and update referenced standards to most recent edition Log #28 Marcelo M. Hirschler, GBH International 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 visual measurements of the spread of flame versus time for a material tested in accordance with ASTM E 84, ; or UL 723,. [NFPA 5000; ] The term flame spread rating is no longer in use. The appropriate term is flame spread index. The preferred NFPA definition of flame spread index is the one from NFPA 5000, and it is recommended that NFPA 801 simply extracts it. With this definition the annex note is no longer needed. 2

12 801- Log #33 Andrew Minister, Battelle Pacific Northwest National Laboratory The Fire Hazards Analysis shall be prepared by or under the supervision of a qualified fire protection engineer acceptable to the authority having jurisdiction. A qualified fire protection engineer acceptable to the AHJ responsible for the preparation of a fire hazards analysis for facilities handling radioactive materials should have generally has knowledge based on a combination of education and experience in the field of fire protection specific to these types of facilities. Examples of a qualified fire protection engineer can include a licensed professional engineer specializing in the field of fire protection or qualified to be 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 of radioactive 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, or other users governed by the AHJs. It is the role of the regulator to provide oversight with regard to meeting these requirements. 3

13 801- Log #34 Andrew Minister, Battelle Pacific Northwest National Laboratory A written fire protection plan program shall be established and implemented for all operational modes of the facility and shall 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 into consideration the hazards and complexity of the facility and potential consequences of a fire to building occupants, the public or the environment. The level of detail to the fire protection program elements will depend on the risk of the facility in relation to the fire protection objectives. Pressure-impregnated fire-retardant lumber should be used in accordance with its listing and the manufacturer s instructions. Where exposed to the weather or moisture (e.g., concrete forms), the fire retardant used should be suitable for this exposure. Fire-retardant coatings are not acceptable on walking surfaces or surfaces subject to mechanical damage. Use of fire-retardant paint requires special care. Inconsistent application and exposure to weather can reduce the effectiveness of fire-retardant coatings. Large timbers are occasionally used to support large pieces of equipment during storage or maintenance. The size of these timbers makes them difficult to ignite, and they do not 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 who apply this standard (e.g., DOE regulations (10 CFR 851) and directives refer to a fire protection program). The combination 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 imply that fire protection would not apply at all times and to all conditions of facility operations. 4

14 801- Log # Retain the original text of the first part of 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 of uranium that has no potential to become airborne need not be segregated. It is important to retain the concept that the segregation requirement applies only to quantities of materials that might become airborne due to fire exposure as determined by the FHA Log # Retain the word, "important", such that reads, "Facilities having quantities of radioactive materials that can become airborne in the event of fire or explosion shall be segregated from other important buildings...". Segregation does need to be provided for all buildings. Small or unimportant buildings do not need to be segregated. The analysis in the FHA will determine which buildings are important and need to be segregated Log # Revise proposed 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. All filters in such systems smoke exhaust systems will collect combustible materials. Enforcement of proposed would required that all filters, regardless of size or importance, be provided with fixed protection unless justified by the FHA. Typical nuclear ventilation systems, including those that might be used for smoke exhaust, often include multiple levels 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 of all filters in smoke exhaust systems to justify the omission of fixed fire protection. Rather, the FHA should evaluate the ventilation system and determine if and where, fixed fire protection is necessary for fire and radiological safety 5

15 801- Log # Where required by the FHA, rooms for the storage of radioactive material, including radioactive gases and radioactive waste shall be separated from the remainder of the building by a 2-hour fire separation, except where it is demonstrated by the fire hazard analysis that the fire protection objectives can be met by other fire protection measures. The proposed as presented in the ROP would require that all storage rooms that contain any amount of radioactive material, including minor amounts of material, be provided with 2-hour fire-rated separation unless justified by the FHA This level of enclosure for all radioactive storage is unjustified. The need for enclosure should be driven by analysis rather than prescription Log # Delete proposed in its entirety. The intent of this paragraph is unclear. It contains no requirements nor does it provide relief from any requirements. It states that needed materials are permitted to be available. It does not address whether the materials need to be enclosed or not enclosed. It does not address amounts or the significance of the material or hazard. Proposed should not appear in NFPA

16 801- Log #35 Andrew Minister, Battelle Pacific Northwest National Laboratory 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. Automatic sprinkler protection shall be provided unless the fire hazards analysis in Section 4.2 dictates otherwise. As determined by the fire hazards analysis, special hazards shall be provided with additional fixed fire protection 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 radiation hazard but also against the criticality hazard caused by the assembly of a minimum critical mass. To avoid criticality during fire emergencies, fissile materials that have been arranged so as to minimize the possibility of a criticality hazard should be moved only if absolutely necessary. If it becomes necessary to move such fissile materials, it should be done under the direction of a responsible person on the staff of the facility and in batches that are below the critical mass, or the 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 or another 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 a criticality hazard. The requirement for a fire hazards analysis is specified in Section 4.2 and does not need to be repeated Log # Delete "using a graded approach" so that the final phrase in 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 great variation depending on application The application of a "graded approach" as applied to a Department of Energy facility might 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 The intent of this phrase might be better expressed in annex material. 7

17 801- Log # Insert "by the FHA" so that reads: "Where automatic fire detectors are required by the FHA...". The proposed committee action on 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 another referenced standard such as the Life Safety Code NFPA 72 is an installation standard does not specify where detection must be installed It is important that NFPA 801 specifies that detection must be provided in accordance with the FHA. 8

18 801- Log #36 Andrew Minister, Battelle Pacific Northwest National Laboratory 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 accumulate outside of the storage vessels, piping, and utilization equipment, combustible-gas analyzers that are designed for the specific 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 which vapors have the potential to accumulate outside of the storage vessels, piping, and utilization equipment shall be installed with combustible-vapor analyzers appropriate for the vapors generated. See the explanation for enclosed spaces under A The analyzer specified by Section or Section 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 allow uncontrolled 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 applicable requirements of NFPA 86,, NFPA 86C, or NFPA 86D,,as appropriate. 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 of the AHJ. A supply of an appropriate extinguishing medium shall be available in all areas where fines and cuttings of pyrophoric 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 9

19 material into critical masses. Fissile materials shall be arranged such that neutron moderation and reflection by water shall not present a criticality 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 with fire 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 hoods The 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 selection of a fire suppression system must address the potential for the spread of radioactive materials due to pressurization of the enclosure or by the flooding of the enclosure wil liquid fire suppression methods such as water. Accessibility for inspection, 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 be permitted when installed in accordance with the applicable NFPA standard. Refer to Section 5.10 for drainage provisions. Hot cells and caves shall be of noncombustible construction. Where combustible shielding is necessary for the 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. Where combustible shielding is necessary for the radiation hazard, appropriate fire protection features shall be installed as determined 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 other fuels 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 covers installed if fire hazards are present inside the box. Gloves should be removed if work has been completed and no additional work requiring access to the glovebox via use of the specific gloves is identified, the glove box will not remain in-service, or fire hazards remaining in the glovebox dictate that the gloves be removed. Gloves should not be removed strictly because immediate or short term use is unnecessary. Unnecessary removal of gloves creates unnecessary generation of radioactive wastes as well as 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 system Fire 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 evaluating the design of the system. As determined by fire hazards analysis, Aa means shall be provided to restrict the passage of flame between glove boxes and hoods that are connected. Fume hoods containing radioactive materials shall meet the requirements of NFPA 45, 10

20 . 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 protection of fume hoods. Combustible materials shall not be stored in fume hoods and should be the minimum necessary to support the 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 to the requirements of NFPA 241,, such as the following: (a) Scaffolding, formworks, decking, temporary enclosures, temporary containment structures, and partitions used inside buildings shall be noncombustible or fire retardant treated. (b) If wood is used, it shall be one of the following: i. Listed, pressure-impregnated, fire-retardant lumber ii. Treated with a listed fire-retardant coating iii. 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-resistant materials described in NFPA 701, The use of noncombustible or fire-retardant concrete formwork is especially important for large structures where large quantities of forms are used. Pressure-impregnated fire-retardant lumber should be used in accordance with its listing and the manufacturer s instructions. Where exposed to the weather or moisture (e.g., concrete forms), the fire retardant used should be suitable for this exposure. Fire-retardant coatings are not acceptable on walking surfaces or surfaces subject to mechanical damage. Use of fire-retardant paint requires special care. Inconsistent application and exposure to weather can reduce the effectiveness of fire-retardant coatings. Large timbers are occasionally used to support large pieces of equipment during storage or maintenance. The size of these timbers makes them difficult to ignite, 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 on the fire hazards analysis. Precautions shall be taken, as required, if the radioactive materials are stored or used in ways that cause them to be more susceptible to release from their containers. Special hazards related to protection from fire shall be controlled by a defense in depth strategy that utilizes 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 and are applicable to laboratories where the requirements of NFPA 45 do 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 of chemicals and radioactive materials in any given operation or work activity. Laboratories frequently change configurations of hazardous and radioactive materials as well as associated laboratory equipment and confinement in support of constantly changing projects. These often changing conditions and the quantities of materials present do not lend themselves to the controls specified in Sections and for gas and vapor analyzers, safety controls and interlocks, control of solvents, and control of handling and storage of combustible metals. NFPA 45 provides adequate controls for most laboratory operations involving chemical hazards in the presence of radioactive materials. Additional fire 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 Laboratory enclosures shall comply with the requirements for hot cells, gloveboxes and hoods unless otherwise justified in thea FHA concludes that the amount of radioactive material is inconsequential. 11

21 Reactivity control shall be capable of inserting negative reactivity to achieve and maintain subcritical conditions in the event of a fire. Inventory and pressure control shall be capable of controlling coolant level such that fuel damage as a result of a fire is prevented. Decay heat removal shall be capable of removing heat from the reactor core such that fuel damage as a result of fire 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 of facilities with tremendous variation in mission, function, design, operations, hazardous chemicals, radioactive material inventories, fire risks and protection needs. The types of facilities covered by NFPA 801 and the requirements of this chapter 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 fire hazards analysis becomes paramount in defining and evaluating the appropriate level of protection for the hazards and configurations unique to the facility. The importance of the FHA and flexibility in the application of requirements for the variability in nuclear facility hazards is the primary basis for the proposed changes and this approach is consistent with Chapter 4 and 6 of this standard. Additional discussion of the specific changes follows: Sections and 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 involve the complexities of installing and maintaining analyzers. The standard is not clear on the conditions that must be assumed for installation of the analyzers (e.g., normal operation, upset conditions, ventilation on or off). The standard provides no guidance relative to the design, installation, operation, or response to analyzer output or alarms. In the case 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 devices in most cases. Section 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 associated with flammable liquids should follow NFPA 30. If lower flammable limit is not used, lower explosive limit needs to be defined. Section 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 is required for quantities that exceed fire code or other similar regulatory thresholds. Section 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 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 of neutron 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 sufficiently complete to address the criticality hazard, and are covered in other governing regulations. Sections , 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 significant change to require ALL hot cells, caves, and gloveboxes to have automatic fire suppression systems was not substantiated based on number of fires, significant fires, or any other data that justified the change to require all hot cells, caves, and gloveboxes to have automatic fire suppression systems. There has to be a graded approach to determining which hot cells, caves, and gloveboxes need to have automatic fire suppression systems. The fire hazards analysis is the correct tool for evaluating the hazards and determining the whether or not a hot cell, cave, or glovebox needs automatic fire suppression. The variability of hot cell, cave, and glovebox design and operations demands the capability to engineer appropriate protection based on the specific configuration, use, and hazards. Our laboratory operates may caves that have not fire hazards associated with them and it would be very expensive to install and 12

22 maintain automatic fire suppression systems when there is no value added. Spread of radioactive materials associated with the activation of a fire suppression system also has to be considered in the selection of an automatic fire suppression 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. The application of suppression systems must be done with consideration for material compatibilities, hazards, post-actuation cleanup, and inspection testing and maintenance of the systems in radiation environments. Sections and 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 fire hazards analysis. Section 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 gloves where they are needed. This level of control should be left to the operating entity as part of overall fire hazards management. Section (renumbered) and Section are similarly revised to provide a more practical level of control for gloves. Not all gloveboxes necessarily have significant fire hazards. Section (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 system actuation so glove failure from over-pressurization is not necessarily governing. The extinguishing system is designed according the hazard present and the appropriate rate of application of agent. The objective to extinguish the fire may not support the objective of protecting the box, but the impacts on box integrity should be understood and the design should consider these impacts appropriately. Section (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 hazards present. There is usually an air lock with 2 doors between the glovebox and any other connected hoods, so proper operation of the air lock would prevent direct passage of flames. Section 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 confinement capability for work with radioactive materials and the hazards associated with radioactive materials in hoods are generally dominated by the hazards of the chemicals. Hoods are designed and tested to remove vapors and not to confine radioactive materials. On this basis, NFPA 45, which has extensive requirement for hoods, should be the governing standard. Where additional protection is necessary, the fire hazards analysis required elsewhere in this standard will govern the determination. The placement of detection and/or fire suppression in most fume hoods has not been established as being necessary unless operations with open containers of flammable liquids are performed. Due to the nature of the operations that are typically performed in fume hoods, there are no specific types of fire detection or fire suppression that would provide reliable detection and /or suppression for all types of hazardous materials that are typically used in fume hoods. NFPA does not require automatic fire suppression for fume hoods unless there is a hazard present that warrants automatic fire suppression. Section and A 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 and unless 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 necessary protection against loss of control or confinement of radioactive materials. The requirements for hot cells, gloveboxes and hoods are followed unless otherwise justified. 13

23 801- Log # In enclosed spaces in which combustible gas could accumulate to hazardous levels as demonstrated by the FHA outside of the storage vessels, piping, and utilization equipment, combustible-gas analyzers that are designed for the specific gas shall be installed. Enclosed spaces in which minor or de minimis quantities of flammable gas might be present do not necessarily required the installation of a combustible gas analyzer. For example, a lecture size bottle of gas located in a very large volume space might never have the potential to create a mixture that would approach the lower explosive limit in the space. A combustible gas analyzer, in this case, would provide no safety benefit. Paragraph should only require combustible gas analyzers where significant, hazardous quantities or concentrations of gas might be created, as demonstrated in the FHA Log # Flammable and combustible liquids in enclosed spaces in which vapors have the potential to accumulate in hazardous amounts or concentrations as demonstrated by the FHA outside of the storage vessels, piping, and utilization equipment 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 not necessarily required the installation of a combustible vapor analyzer. For example, a small volume of flammable liquid located in a very large volume space might never have the potential to create a mixture that would approach the lower explosive limit in the space. A combustible vapor analyzer, in this case, would provide no safety benefit. Paragraph should only require combustible vapor analyzers where significant, hazardous quantities or concentrations of gas might be created as demonstrated in the FHA Log # An approved fixed fire-extinguishing system shall be installed or its absence justified to the satisfaction of the FHA to provide fire protection for flammable or combustible solvents where required by the FHA. The topic of 7.1 is "General." The topic of is "Flammable and Combustible Liquids and Gases." The topic of is "Solvents." As such, the requirements of will apply to all solvents, in any amount, and in any 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 quantities might need protection as demonstrated in the FHA. 14