FIRE PROTECTION PROGRAM CRITERIA

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1 NOT MEASUREMENT SENSITIVE DOE STANDARD DOE-STD-1066-xx Month, 20xx FIRE PROTECTION PROGRAM CRITERIA U.S. Department of Energy Washington, D.C

2 This document has been reproduced directly from the best available copy. Available to DOE and DOE contractors from the Office of Scientific and Technical Information, P.O. Box 62, Oak Ridge, TN 37831; (423) Available to the public from the U.S. Department of Commerce, Technology Administration, National Technical Information Service, Springfield, VA 22161; (703)

3 DOE-STD-1066-xx FOREWORD This Department of Energy (DOE) Standard is approved for use by all DOE elements and their contractors. DOE Standards are part of the DOE Directives System and are issued to provide supplemental guidance regarding the Department's expectations for fulfilling its requirements as contained in rules, Orders, and notices. The Standards provide acceptable methods for implementing these requirements. Beneficial comments (recommendations, additions, deletions) and any pertinent data that may improve this document should be sent to the name and address below by letter, electronic mail, or by using the self-addressed Document Improvement Proposal (DOE F ) appearing at the end of this document. Jim Bisker (HS-21) Office of Health, Safety and Security Office of Nuclear Safety Policy and Assistance U.S. Department of Energy Germantown Road Germantown, MD Jim.bisker@hq.doe.gov iii

4 DOE-STD-1066-xx INTENTIONALLY BLANK 1. SCOPE PURPOSE REFERENCED CRITERIA DEFINITIONS GENERAL CRITERIA Protection to Limit Loss Potential Structural Considerations Fire Suppression Systems WATER SUPPLY AND DISTRIBUTION SYSTEM CRITERIA Demand System Arrangement AUTOMATIC SPRINKLER SYSTEM CRITERIA General Application Seismic Criteria FIRE ALARM SYSTEMS General Application Alarm Actuating Devices Alarm System Extensions STRUCTURAL FIRE PROTECTION CRITERIA General Application Fire Barriers Flame Spread Roofing Systems Penetrations Carpets and Rugs LIFE SAFETY CRITERIA General Application Hazardous Areas ELECTRICAL EQUIPMENT CRITERIA General Application PROTECTION CRITERIA FOR GENERAL PROCESS HAZARDS General Application PROTECTION CRITERIA FOR SPECIAL HAZARDS General Application Plutonium Processing and Handling Facilities (PPHF) Plutonium Storage Facilities (PSF) Enriched Uranium Storage Facilities (EUSF) Uranium Processing and Handling Facilities Reprocessing Facilities Uranium Conversion and Recovery Facilities NUCLEAR FILTER PLENUM FIRE PROTECTION Purpose and Scope Filter Plenum Construction Location of Final Filter Plenum Ventilation System Equipment Protection of Openings in Fire Rated Construction Materials and Special Hazards inside Plenum Prefilters, Duct Entrance Filters, and Fire Screens Detection Systems Deluge Spray Suppression Systems iv

5 DOE-STD-1066-xx 14.9 Special System Guidelines Fire Hazard Analysis GLOVEBOX FIRE PROTECTION Scope: Glovebox Construction: Automatic Fire Suppression and Inerting Systems: Manual Fire Suppression: Fire Detection Systems Glovebox Ventilation Appendices Appendix A. Nuclear Filtration and Air Cleaning Systems... A-1 Appendix B. Operating Temperatures for HEPA Filters... B-1 Appendix C. General Criteria Summary Table and Plan Diagram... C-1 Appendix D. Discussion on Evaluating Duct Openings When Penetrating 2-Hour Fire Walls... D-1 Appendix E. Example Glovebox Fire Detection Systems... E-1 Appendix F. Fire Extinguisher Quick Disconnect Coupling... F-1 Appendix G. Dry Powder Extinguishing Agent Holder... G-1 Appendix H. Limited Water Sprinkler Design... H-1 Appendix I. Glovebox Window Material Comparison... I-1 Appendix J. Glovebox Overpressure Protection Valves... J-1 Appendix K. Glovebox Fire Protection Survey... K-1 Appendix L. References... L-1 v

6 DOE-STD-1066-xx 1. SCOPE The provisions of this Standard apply as guidance to the following: a. All departmental elements as delineated in the scope of DOE O B, Facility Safety, and its respective Contractor Requirements Document (CRD); DOE B, Worker Protection Management Program for DOE (Including the National Nuclear Security Administration) Federal Employees; and, 10 CFR Part 851, Worker Safety and Health Programs b. The purchase and lease, as well as the design and construction, of all DOE facilities erected, modified, or renovated after the effective date of this Standard. Nothing in this Standard is intended to limit the application of other fire protection methods when unique situations or hazards warrant an alternate approach. The alternate approach should provide a comparable level of safety to that achieved by conformance with this Standard. Such alternate approaches should be approved by the Authority Having Jurisdiction (AHJ), after consultation with a qualified fire protection engineer. 2. PURPOSE The development of this Standard reflects the fact that national consensus standards and other design criteria do not comprehensively or, in some cases, adequately address fire protection issues at DOE facilities. This Standard provides supplemental fire protection guidance applicable to the design and construction of DOE facilities and site features (such as water distribution systems) that are also provided for fire protection. It is intended to be used in conjunction with the applicable building code, National Fire Protection Association (NFPA) Codes and Standards, and any other applicable DOE construction criteria. This Standard, along with the criteria delineated in Section 3, constitutes the basic criteria for satisfying DOE fire and life safety objectives for the design and construction or renovation of DOE facilities. 3. REFERENCED CRITERIA DOE facilities and their associated fire protection features are subject to the applicable sections of the current editions of the criteria listed below. Federal Criteria 10 CFR Part 851, Worker Safety and Health Programs Americans with Disabilities Act Accessibility Guidelines (ADAAG) Other statutory requirements, not listed above, that delineate criteria of a more limited extent relating to facility fire safety. 1

7 2 DOE - STD X-XX-XX DOE Requirements DOE O B, Facility Safety DOE O B, Worker Protection Program fordoe (Including the National Nuclear Security Administration) Federal Employees DOE M A, DOE Explosives Safety Manual Other DOE Orders, not listed above, that delineate criteria of a more limited extent that relate to facility fire safety. DOE Guidelines DOE G Implementation Guide for Use with 10 CFR Part 851, Worker Safety and Health Programs DOE G A Worker Protection Program for DOE (including the National Nuclear Security Administration) Federal Employees Guide for Use with DOE O 440.1B DOE-HDBK , Primer on Spontaneous Heating and Pyrophoricity DOE-STD , Natural Phenomenon Hazards Design and Evaluation Criteria DOE-HDBK-1169, Nuclear Air Cleaning Handbook (Chapter 10 Fire Protection) Other Criteria National Fire Protection Association Codes and Standards Building and Fire Code Models applicable to the State or local area. National Fire Protection Association Handbooks, Guides and Recommended Practices FM Global Data Sheets Society of Fire Protection Engineers Handbook NURG Fire Protection for Nuclear Power Plants Referenced Standards American Society for Testing and Materials (ASTM) ASTM E-84 Standard Test Method for Surface Burning Characteristics of Building Materials ASTM E-119 Standard Method of Fire Tests of Building Construction and Materials ASTM E-136 Tests of Behavior of Materials in a Vertical Tube Furnace at 750 Degrees Celsius ASTM E-176 Standard Terminology of Fire Standards ASTM E-814 Fire Tests of Through Penetration Stops American Society of Mechanical Engineers (ASME) ASME AG-1 Code on Nuclear Air and Gas Treatment Institute of Electronic and Electrical Engineers (IEEE) IEEE-399 Recommended Practice for Power System Analysis IEEE-493 Recommended Practice for the Design of Reliable Industrial and Commercial Power Systems

8 3 DOE - STD X-XX-XX Underwriter's Laboratories, Inc. (UL) Standards UL-555 UL-586 UL-900 Standard for Fire Dampers and Ceiling Dampers High Efficiency Particulate Air-Filter Units Test Performance of Air Filter Units 4. DEFINITIONS Acceptable - When applied to fire safety, "acceptable" is a level of protection which the Authority Having Jurisdiction, after consultation with the cognizant DOE fire protection engineer(s), considers sufficient to achieve the fire and life safety objectives defined in DOE Orders. In some instances, it is a level of protection necessary to meet a code or standard. In other instances, it is a level of protection that deviates (plus or minus) from a code or standard as necessary and yet adequately protects against the inherent fire hazards. Adsorber Systems - A system for removing gases or vapors from air by means of preferential physical condensation and retention of molecules on a solid surface. Adsorbers used in nuclear applications are often impregnated with chemicals to increase their activity for organic radioactive iodine compounds. Authority Having Jurisdiction (AHJ) - The decision making authority in matters concerning fire protection. The DOE Head of Field Organization or designee is the final AHJ unless otherwise directed by the Cognizant Secretarial Officer (DOE O 420.1B. 5. d. (10). Building Code Official (BCO) - The decision making authority in matters concerning construction. The DOE Head of Field Organization or designee is the final BCO unless otherwise directed by the Cognizant Secretarial Officer. Code of Record The installation requirements (code or standard) in effect at the time a facility or item of equipment was designed and constructed. Combustible Liquid - A liquid having a closed cup flash point at or above 100 of (38 oc). Combustible Material - Any material that will ignite and burn. Any material that does not comply with the definition of "noncombustible" as contained in this Standard is considered combustible. The term combustible is not related to any specific ignition temperature or flame spread rating. Cognizant Fire Protection Engineer - The fire protection engineer that is responsible for implementing this Standard for a given issue. This would normally be a representative of the management and operating (M&O) contractor, but would be the DOE fire protection engineer if no contractor was involved. (Extracted from DOE-STD ) Criticality Incident - The release of energy as a result of accidentally producing a self-sustaining or divergent neutron chain reaction. Deep Bed Fiberglass Filter - A ventilation filter made of deep beds of compacted fiberglass contained in stainless steel boxes having opaque sides and perforated screens at the top and bottom for the removal of particulate matter. Deep Bed Sand Filter - Particulate filter constructed of deep beds of rock, gravel, and sand,

9 4 DOE - STD X-XX-XX formed in layers graded with about two to one variation in granule size from layer to layer. Demister - A device used to protect the final filter in an air cleaning system from entrained moisture in the air. (Note: Demisters for fire protection purposes are usually perforated bent plate type mist eliminators fabricated by taking two flat perforated metal sheets spot-welded together and uniformly spacing them a few thousandths of an inch apart, with perforations in adjacent sheets offset so that air entering the holes in the first sheet impinges on the second sheet and must make two 90 degree turns before it can escape. The two perforated metal sheets are then bent or pleated with saw tooth angles of 45 degrees to increase the surface area per square foot of frontal area. Moisture from a perforated plate type mist demister is removed by impingement of droplets on the water film flowing down between the sheets and on the face of the first sheet. Perforated bent plate-type demisters must be installed with the pleats in the vertical position so that water can flow off them easily.) Documented Safety Analysis An analysis of the extent to which a nuclear facility can be operated safely with respect to workers, the public, and the environment, including a description of the conditions, safe boundaries, and hazard controls that provide the basis for ensuring safety (10 CFR 830.3). (Extracted from DOE G ) Duct Entrance Filter - A filter unit installed at the exhaust duct entrance(s) to prevent entrance and accumulation of combustible or flammable dusts and/or residues inside the exhaust ducts. (Note: This is a concern of particular interest to the nuclear industry because radioactive substances tend to deposit or "plate out" on ducts. Dust accumulation inside duct surfaces can create fires that are serious because they occur in the ventilation system leading directly to the final exhaust plenum filters.) Emergency Services Organization The performance of activities pertaining to the inherent responsibilities of the site fire department, brigade, or other organization that performs any or all of the following functions: Fire Suppression Hazardous Material (HAZMAT) Response Emergency Medical Services Technical Rescue Confined Space Entry Training Off-site Assistance to Other Emergency Services Organizations (Mutual Aid) Inspection, Testing and Maintenance of Fire Protection Equipment or Apparatus Facility Fire Prevention and Life Safety Inspections

10 5 DOE - STD X-XX-XX (Extracted from DOE G ) Exhaust Plenum Final Filter - The final filter unit in a set of filters arranged in a series for ventilation and effluent discharge in an air cleaning system. Fire - Unplanned destructive burning, including explosions (detonation or deflagration), as manifested by any or all of the following: light, flame, heat or smoke. Fire does not include the following unless they cause a fire or occur as a consequence of a fire: lightning or electrical discharge, rupture of a pressure vessel not caused by internal combustion, detonation of munitions, or overheat [without damage to initiating material.] Fire Area - A location bounded by construction having a minimum fire resistance rating of 2 hours with openings protected by appropriately fire-rated doors, windows, dampers, or penetration seals. The boundaries of exterior fire areas (yard areas) or other locations that represent unique conditions should be as determined by the cognizant fire protection engineer (contractor or DOE). (When relocated structures are grouped and are not separated as directed in this standard, they should be considered as being part of the same fire area. (Extracted from DOE-STD )) Fire Loss - The dollar cost of restoring damaged property to its pre-fire condition. When determining loss, the estimated damage to the facility and contents should include replacement cost, less salvage value. Fire loss should exclude the costs for: property scheduled for demolition; and decommissioned property not carried on books as a value. Fire loss should include the cost of: Replacement cost of building and building systems or contents within the fire area Replacement cost of contents Cost of lost time (considered mission interruption costs) Cost of environmental clean-up Exposure damage to other buildings, structures and property Costs for re-establishing operations; e.g., redesign approval and start-up (Indirect costs of fire extinguishment (such as fire department equipment) (Extracted from DOE-STD )) Fire Protection A broad term which encompasses the aspects of fire and life safety, concerned with minimizing the direct and indirect consequences of fire and other perils, such as explosions and natural phenomenon events as they relate to fire. Aspects of fire protection include, but are not limited to, fire suppression and detection systems, fire water systems and emergency process safety control systems, building construction and fixed building features such as fire doors, fire walls and barriers, and fire dampers. Also included are the fire department and emergency response forces. (Extracted from DOE G ) Fire Protection Assessment A formal documented review conducted by DOE or Contractors in accordance with DOE requirements that examine the essential fire protection elements as they relate to a specific facility or overall fire protection program. (Extracted from DOE G )

11 6 DOE - STD X-XX-XX Fire Protection Engineer - A graduate of an accredited engineering curriculum and having completed not less than 4 years of engineering practice, 3 of which shall have been in responsible charge of diverse fire protection engineering work. If not such a graduate, a qualified engineer shall either: demonstrate a knowledge of the principles of engineering and have completed not less than 6 years engineering practice, 3 of which shall have been in responsible charge of diverse fire protection engineering projects; be a registered professional engineer in fire protection; or meet the requirements for a Grade 11 or higher Fire Protection Engineer as defined by the Office of Personnel Management. Fire Protection System - Any system designed to detect and contain or extinguish a fire, as well as limit the extent of fire damage and enhance life safety.(these include: Automatic suppression systems, such as fire sprinklers, foam, gaseous, explosion suppression, or other specialized extinguishing systems plus appropriate alarms. An adequate supply, storage, and distribution system is an essential element. Automatic fire detection, occupant warning, manual fire alarm, and fire alarm reporting systems combined with properly equipped and adequately trained fire departments or brigades. Fire barrier systems or combinations of physical separation and barriers for outdoor locations. Other systems, such as alternate process control systems, as approved by the AHJ. (Extracted from DOE-STD NOTE :this is the same as Redundant Fire Protection System described below) Fire Prevention The process of managing and regulating potential fire hazards (fuels and heat energy sources) and the mechanisms that bring them together to either eliminate the hazard(s) or reduce the risk associated with the hazard(s) to acceptable levels. (Extracted from DOE G ) Fire Resistance Rating - The time that a particular construction will withstand a standard fire exposure in hours as determined by ASTM E-119. Fire Screen - An item of equipment installed ahead of all HEPA filter banks intended to reduce flame propagation and glowing/burning ember products from reaching final high efficiency particulate air (HEPA) filters. Flammable Liquid - A liquid having a closed cup flash point below 100 F (38 oc) and having a vapor pressure not exceeding 40 psia (2068 mm Hg) at 100 of (38 oc). Flame Spread Rating - Flame spread rating is a numerical classification determined by the test method in ASTM E-84, which indexes the relative burning behavior of a material by quantifying the spread of flame of a test specimen. The surface burning characteristic of a material is not a measure of resistance to fire exposure. Glovebox - A sealed enclosure with viewing windows designed to separate the space in the enclosure from its surroundings and in which all items in the enclosure are handled using gloves that are sealed to the enclosure walls. Heat Resistant - A material having the quality or capability of withstanding heat for a specified period at a maximum given temperature without decomposing or losing its integrity.

12 7 DOE - STD X-XX-XX High Efficiency Metal Fiber (HEMF) Filter - A reusable metal filter composed of fine sintered stainless steel fibers together with a stainless steel wire and metal support housing and pleated to enhance strength, surface area, and particle holding capacity. High Efficiency Particulate Air (HEPA) Filter - A disposable extended pleated medium dry type filter with a rigid housing having a minimum particle removal efficiency of at least percent (maximum penetration of 0.03%) for particles of 0.3 microns or greater (by light scattering mean droplet diameter) when tested with monodisperse dioctylphthalate (DOP) smoke and maximum pressure drop of 1.0 inch (2.54 centimeters) of water when clean and operated at its rated airflow capacity. HEPA filters consist of a material that is a thin mat of fine intertwined glass fibers that are folded back and forth around separators, and then enclosed by a plywood or metal frame. HEPA filters are easily damaged by very high temperatures and aerosols, and can fail when subjected to moisture and/or structural loading. From ASME AG : A throwaway, extended-media dry-type filter with a rigid casing enclosing the full depth of the pleats. The filter shall exhibit a minimum efficiency of 99.7% when tested with an aerosol of essentially monodispersed 0.3 micron test aerosol particles. Hydrophoric Materials - Materials that react violently with water or water vapor (such as lithium and lithium hydride). Limited Supply Suppression System - A system installed in accordance with the applicable NFPA Standards and having a limited quantity of suppression agent. These systems typically include carbon dioxide, dry chemical, other gaseous agents, or water. Listed/Approved - Equipment or materials that have been tested, passed, and are included in a current list published by a nationally recognized testing laboratory which is concerned with product evaluation and is acceptable to the AHJ. The laboratory maintains periodic inspection of production of listed equipment or materials. Such lists state either that the equipment or material meets appropriate standards or has been tested and found suitable for use in a specified manner. This definition applies to products which are Underwriter's Laboratories (UL) listed or Factory Mutual (FM) approved. Maximum Possible Fire Loss (MPFL) - The value of property, excluding land value, within a fire area, unless a fire hazards analysis demonstrates a lesser (or greater) loss potential. This assumes the failure of both automatic fire suppression systems and manual fire fighting efforts. Noncombustible - A material that in the form in which it is used and under the conditions anticipated will not ignite, burn, support combustion, or release flammable vapors when subjected to fire or heat, as defined by fire protection industry standards on the basis of large scale fire tests performed by a nationally recognized independent fire test authority. Occupancy - The purpose for which a building, or portion thereof, is used or intended to be used. For DOE facilities, the occupancy classification for purposes of determining construction, protection and area limitations should be as determined under the provisions of the applicable local building code or the Uniform [International] Building Code unless otherwise specified by the AHJ. Prefilter - A filter that is located upstream from another filter. Prefilters, or roughing filters, remove and/or reduce the percentage of large particles that would reduce the life of the next-inline or final filters.

13 8 DOE - STD X-XX-XX (Note: Although final HEPA filters are excellent collectors of very small particles, they are likely to plug when subjected to high loads of dust and large smoke particles generated in a fire. Prefilters help remove the large particles and dust that would accumulate on the HEPA filters. Prefilters can generally be located at any point in the exhaust ventilation system before the final HEPA filters and sometimes are located in the final filter plenum enclosure.) Pre-Incident Plan A document owned and developed by a fire department which provides information to responding personnel that will help them safely and effectively manage emergencies with available resources at a specific facility or area. (Extracted from DOE G ) Pyrophoric Material - A material with an autoignition temperature in air at or below 130 degrees F (54.4 degrees C) and 50% relative humidity. Redundant Fire Protection System - A fire protection system that is designed and installed to function in the event of the failure of a primary fire protection system. Where redundant fire protection systems are specified, any two of the following are considered satisfactory: Automatic suppression systems, such as fire sprinklers, foam, gaseous, explosion suppression, or other specialized extinguishing systems plus appropriate alarms. An adequate supply, storage, and distribution system is an essential element. Automatic fire detection, occupant warning, manual fire alarm, and fire alarm reporting systems (considered together) combined with a sufficiently-staffed, properly-equipped and adequately-trained fire department or brigade that is able and committed to respond in a timely and effective manner. Fire barrier systems or combinations of physical separation and barriers for outdoor locations. Other systems, such as alternate process control systems, as approved by the AHJ. Redundant fire protection systems may include dual water supplies to sprinkler systems, dual piping risers, or valving systems such that adequate redundancy in water supply to the sprinkler heads is provided to cover maintenance or emergency outages of either of the water supply systems or may include multiple types of automatic fire suppression systems (e.g., water sprinklers and a gaseous fire suppression system). Portable fire extinguishers, interior fire hose systems, or interior fire detection and alarm systems do not meet the definition of a redundant fire protection system. Relocatable Structure - Manufactured structures, mobile homes, trailers, semi-trailers, modular type structures, factory assembled structures, cargo containers, hazardous materials or flammable liquid storage containers, air supported/inflated structures, tent/membrane and cloth/rib structures. This term does not apply to trailers and cargo containers that are being used in the transportation mode for conveying materials while onsite, or to prefabricated buildings that are permanently located, such as "Butler" or "Strand Steel" buildings. Structures not specifically identified herein should be referred to the AHJ for categorization. (Extracted from DOE-STD ) Smoke Developed Rating - Smoke developed rating is a numerical classification determined by

14 9 DOE - STD X-XX-XX ASTM E-84, which indexes the smoke generation rate of a given material to those of two standard materials ( inorganic reinforced cement board and select grade red oak). Special Facilities - As used in this standard, the term "special facilities" includes the following: Emergency Preparedness Facilities Explosives Facilities Fusion Facilities Hazardous Waste Incinerator Facilities Irradiated Fissile Material Storage Facilities Laboratory Facilities (Including Hot Laboratories) Nonreactor Nuclear Facilities Plutonium Processing and Handling Facilities Plutonium Storage Facilities Radioactive Liquid Waste Facilities Radioactive Solid Waste Facilities Reprocessing Facilities RCRA Storage Facilities Secure Conference Rooms Telecommunications, Alarm, Central Data Processing Centers and Radio Repeater Stations Tritium Facilities Unirradiated Enriched Uranium Storage Facilities Uranium Conversion and Recovery Facilities Uranium Enrichment Facilities Uranium Processing and Handling Facilities Vaults and Vault-type Rooms for Storage of Classified Matter Other Facilities as Defined by the AHJ 5. IMPLEMENTATION GUIDANCE FOR DOE FIRE PROTECTION AND EMERGENCY SERVICES PROGRAMS FOR USE WITH DOE O 420.1B, FACILITY SAFETY 5.1 INTRODUCTION The purpose of this Guide is to facilitate implementation of requirements in Department of Energy (DOE) Order (O) 420.1B, Facility Safety, by providing supplementary information that describes an acceptable approach to meet the DOE O 420.1B requirements for Fire Protection Programs. This document also addresses, in part and where appropriate, the relationship of fire protection requirements in DOE O 420.1B and the following DOE documents: 10 CFR Part 851, Worker Safety and Health Program DOE O 440.1B, Worker Protection Program for DOE (Including the National Nuclear Security Administration) Federal Employees

15 10 DOE - STD X-XX-XX DOE Guide (G) , Implementing Guide for Use with 10 CFR Part 851, Worker Safety and Health Programs 1 DOE O 151.1C, Comprehensive Emergency Management System These additional documents are available at the DOE Fire Protection Website: ( and/or at the DOE Directives Website ( and/or at the DOE Technical Standards Website ( 5.2 APPLICABILITY DOE and contractor fire safety programs include all activities pertaining to fire hazards and related perils including: emergency services, operations and maintenance activities such as hot work or combustible material handling or storage; construction activities related to fire safety; installation and testing of fire protection systems; water supply and distribution systems; fire safety training; assessments; facility and site walk downs; and other fire protection activities that are not explicitly identified here. This Guide applies to all Departmental Elements and Contractors as delineated in DOE O 420.1B. It provides an acceptable means to implement the fire protection requirements detailed in Chapter II and associated Attachment 2, Contractor Requirements Document (CRD) of DOE O 420.1B. Implementation of alternate or innovative fire safety configurations and practices that will meet the requirements of DOE O 420.1B and achieve a level of fire protection and emergency response determined to be equal to that attained by conformance with this Guide is allowed according to Sections 4c and 5b(5) of DOE O 420.1B. 6. IMPLEMENTATION INSTRUCTIONS DOE O 420.1B establishes facility and programmatic safety requirements for a comprehensive fire protection program for DOE sites, facilities, and emergency service organizations to minimize: (1) the potential for occurrence of a fire or related event; (2) fires that cause an unacceptable onsite or offsite release of hazardous or radiological material that could impact the health and safety of employees, the public, or the environment; (3) unacceptable interruption of 1 DOE G states that Complete guidance on the development, adoption and maintenance of a fire safety and emergency response program that satisfies the provisions of the Rule can be found in DOE G , Fire Safety Program for use with DOE O and DOE O This Guide (DOE G ) is based upon and replaces DOE G and includes some additional guidance on the development, adoption and maintenance of a fire safety and emergency response program to support implementation of the 10 CFR 851 rule. However, as experienced is gained in implementing 10 CFR 851, further guidance may be determined to be needed to support its implementation; and either DOE G or DOE G will be updated as appropriate.

16 11 DOE - STD X-XX-XX vital DOE programs as a result of fire and related hazards; (4) property loss from fire exceeding limits established by DOE; and (5) fire damage to critical process controls and safety systems structures and components (as documented by appropriate safety analysis) Comprehensive fire safety and emergency response programs at DOE sites and facilities include, but are not limited to, appropriate policies, requirements, technical criteria, analyses, administrative procedures, and related documentation. In addition they feature adequately designed, installed and maintained fire safety systems, hardware, structural features, and related devices. These programs include access to fully capable emergency response forces featuring trained personnel and an adequate inventory of apparatus and equipment that enable these forces to respond in a timely and effective manner. Where the local emergency response capability is deemed insufficient, appropriate compensatory measures are implemented to address baseline needs. The professional staff, general worker population, and visiting public at these sites and facilities are appropriately trained on the fire hazards and related conditions that they are likely to encounter Additional guidance on how to meet DOE expectations for the abovereferenced programs is delineated below. This guidance supplements general industry criteria, and contractual obligations and should be implemented by qualified and experienced fire safety professionals. Where confusion exists as to their intent or application, it is expected that the Authority Having Jurisdiction 2 (AHJ) be consulted. This additional guidance is referenced to the specific sections of the DOE O 420.1B where additional guidance was deemed warranted by DOE and DOE contractor fire safety professionals. 6.2 Program Objectives Information in this section pertains to Section 1 of Chapter II in DOE O 420.1B (and the corresponding CRD Section in Attachment 2 of DOE O 420.1B). The following paragraphs describe in broad terms the approach to achieve the objectives of a DOE fire protection and emergency response program: 1. Contractors can achieve a comprehensive, multi-faceted emergency response capability in a number of ways. They can rely on an on-site emergency services organization, such as what currently exists at many DOE sites; or they can rely completely on off-site fire departments to meet DOE determined response objectives. Contractors can also combine the capabilities of both on-site and off- 2 The Authority Having Jurisdiction (AHJ) is defined by Section 5.d.10 of DOE O 420.1B and Section 4 of DOE-STD-1066 as the decision making authority in matters concerning fire protection as defined by the National Fire Protection Association Codes and Standards. The DOE head of field organization or designee is the AHJ unless otherwise directed by the Secretarial Officer.

17 12 DOE - STD X-XX-XX site emergencies services organizations so as to assure the timely and effective response to the spectrum of emergency conditions (fires, medical emergencies, technical rescue, hazardous material response, etc.) that they may encounter (e.g. mutual aid agreements). a. If an on-site fire department will be relied upon to provide complete emergency services, the full scope of its capabilities including: mission responsibilities, personnel, apparatus, equipment, facilities, programs, incident reporting, etc. should be delineated in a Baseline Needs Assessment (BNA) as further explained below. The BNA should address compliance with the National Fire Protection Association (NFPA) codes and standards and other requirements that define the character of its mission and responsibilities. (This does not mean that the BNA has to be written to confirm code conformance on the basis of line-by-line comparisons. A reasonable degree of documentation is expected.) It should also address applicable contract provisions and aid agreements with other contractors on site as well as off-site organizations. The goal is to capture in one document information that will confirm that the fire department is fully capable of meeting emergency response requirements and needs. Note that there is a model BNA that can be downloaded and edited, available on the DOE fire protection website at ml. b. If a contractor will rely completely on (non-doe) off-site emergency services organizations to satisfy the emergency response requirement, then the contractor should first define completely its emergency services needs against the services available by the off-site organization. This can be done via a BNA or comparable document, commensurate with the offsite organization s responsibilities. This document should delineate what is required (capability), why is it required (hazards, accident potential, code requirements, etc), and how this capability is assured by the off-site emergency services organization. c. If a contractor will rely on a combination of on-site and off-site emergency services organizations, the contractor should comprehensively demonstrate that an adequate emergency response capability exists on the basis of some combination of the efforts described in a and b, above. 2. Contractors can achieve and maintain a comprehensive site and facility fire protection program through implementation of applicable industry codes and standards (principally from the NFPA), as modified by DOE fire safety criteria. Site and facility fire protection programs are characterized by defense-in-depth. This means that adequate safety is assured by reliance on multiple levels of fire protection (fire safety policies, administrative procedures, active fire protection systems, passive fire safety features, trained people, and an adequate emergency response capability, among other possible facets). Additionally, the long-term adequacy of site and facility fire safety programs required routine selfassessments with a corrective action program that facilitates the timely remediation of significant fire protection and emergency response deficiencies.

18 13 DOE - STD X-XX-XX Such programs include appropriate notification, reporting, and tracking and trending of findings. 3. Subcontractors can achieve compliance with DOE fire safety objectives through an established and appropriately documented relationship with a prime contractor s fire protection and emergency response program. 6.3 Highly Protected Risk Status Information in this section pertains to Section 3a(1) of Chapter II in DOE O 420.1B (and the corresponding CRD section in Attachment 2 of DOE O 420.1B) Highly Protected Risk (HPR) is a rating given to property that qualifies for insurance coverage by the Factory Mutual System, the Industrial Risk Insurers, and other industrial insurance companies that limit their insurance underwriting to the bestprotected class of industrial risk. The requirement of the applicable building code and NFPA codes and standards are considered minimum levels of protection and do not necessarily meet the HPR status. DOE facilities are expected to meet or exceed the applicable building code and NFPA codes and standards. DOE facilities may also need to meet criteria in DOE-STD to minimize: 1) unacceptable onsite or offsite release of radiological or hazardous materials, 2) interruptions of vital programs and 3) property damage. A means to achieve HPR status or the best-protected class of industrial risks includes compliance with insurance industry standards such as those published by the Factory Mutual Global (Loss Prevention Data Sheets and technical advisory bulletins). A graded approach and experience in the application of insurance industry standards is necessary to determine the appropriate HPR provisions for a given facility or process. 6.4 Maintaining Safety Systems Information in this section pertains to Section 3a(2) of Chapter II in DOE O 420.1B (and the corresponding CRD section in Attachment 2 of DOE O 420.1B) Refer to Section 4.21 of this Guide for information related to this topic. 6.5 Program Policy Statements Information in this section pertains to Section 3b(1) in Chapter II in DOE O 420.1B (and the corresponding CRD section in Attachment 2 of DOE O 420.1B). 1. The intent of documenting policy statements is to have the uppermost levels of DOE and Contractor management state in writing their fire protection program expectations. Such policy statements should not conflict with regulatory, DOE, or contractual obligations. For site emergency services organizations, this policy statement should include fundamental statements regarding the level of service that DOE expects and the level of capability that the contractors intend to provide. (For example: DOE expects that the site fire department will maintain a capability to provide Advanced Life Support, as defined in the State of or will provide an emergency services capability that fully conforms with the

19 14 DOE - STD X-XX-XX requirements of the State of, DOE directives, and NFPA codes and standards, unless explicit relief has been granted by DOE. ) 2. Section 5d(10) of DOE O 420.1B assigns the responsibilities for the AHJ, in most cases, to the DOE heads of field elements under advisement of a qualified fire protection engineer (as defined in DOE-STD ) as the subject matter expert (SME). The AHJ may designate a contractor as the site s Fire Marshall to act as his representative for day-to-day activities such as: issuing of permits; reviewing and approving construction documents and shop drawings (new construction, modification, or renovation); approving routine fire protection equipment, materials, installation, and operational procedures (fire system inspection and testing), interpretation of building codes or standards; and other activities that would require formal approval. Fire Marshall activities, inclusive of this authority, should be well documented and available for AHJ review. 6.6 Program Documentation Information in this section pertains to Section 3b(2) of Chapter II in DOE O 420.1B (and the corresponding CRD section in Attachment 2 of DOE O 420.1B). 1. The program should be completely documented. This includes a description of applicable fire safety requirements in contracts and leases, where appropriate. 2. Documentation should also include a description of the fire protection organization and its roles and responsibilities in relation to other organizational entities. It is preferable, although not always essential, to have all fire protectionrelated line activities under a single line manager to avoid unnecessary duplication and costs. 3. Training and qualification records of individuals having fire protection program responsibilities should be readily available and in an auditable form. 4. Appropriate fire protection documentation includes copies of all fire hazard analyses (FHAs) and at least the two most recent facility assessment reports in a continually updated filing system. The FHAs and facility assessment reports may be combined, provided that they address all essential elements as defined below. The DOE Fire Protection Web Site contains copies of "models" of separate and combined FHAs and assessment reports. Facility documentation should also include copies of any exemptions, equivalencies or deviations that have been approved by DOE. 5. Construction projects should feature a file in which all significant decisions and reports concerning fire protection can be found. Supporting documents in this file should be maintained for future reference.

20 15 DOE - STD X-XX-XX 6. The inspection, testing and maintenance (ITM) program for fire protection features, apparatus and equipment should be based on industry standards, such as those established by the NFPA unless an alternative has been approved by the AHJ. The organizations responsible for ITM of fire protection features should maintain system inspection and test records according to Section 11.4 of DOE Administrative Records Schedule 18, Security, Emergency Planning and Safety Records or, if not specifically addressed in the Schedule 18 document, for a minimum of three review cycles. In addition, responsible authorities should retain records of all ITM procedures for as long as such equipment remains in service. 7. Site fire departments and other related emergency response organizations (such as brigades or emergency squads) should maintain a current file with all standard operating procedures and fire pre-incident plans, firefighter training and certification programs, and appropriate documentation governing related activities. The level of documentation should be reasonable and commensurate with the contractor s responsibilities. A program should be in place to ensure that this documentation is updated at appropriate intervals. Pre-incident plans should be developed on the basis of NFPA 1620, Recommended Practice for Pre- Incident Planning, with input from the site fire protection engineering staff as well as emergency responders. 8. Emergency response records must conform to DOE reporting requirements in DOE O 231.1A, Environment, Safety, and Health Reporting, and should be based on standard fire incident reporting practices, such as the National Fire Incident Reporting System (NFIRS) or NFPA 901, Standard Classifications for Incident Reporting and Fire Protection Data, in lieu of state or site-specific reporting formats. 9. Computerized information management techniques for the creation, maintenance and dissemination of relevant documentation pertaining to the fire protection program are acceptable. 10. Access to classified matter during an emergency must be documented after the emergency and individuals who were provided access must complete nondisclosure forms as required by DOE Manual (M) , Information Security. 6.7 Fire Hazards Analyses Information in this section pertains to Section 3b(5) of Chapter II in DOE O 420.1B (and the corresponding CRD section in Attachment 2 of DOE O 420.1B). 1. A FHA is required for all Hazard Category 1, 2 and 3 nuclear facilities (as defined in DOE Standard 1027), high-hazard facilities (as determined by the AHJ), significant new facilities and facilities that store or process significant quantities of hazardous materials in excess of the allowances described in NFPA 1,

21 16 DOE - STD X-XX-XX Uniform Fire Code. These examples include planned facilities as well as significant renovations to existing facilities as determined necessary by the AHJ. NFPA 801 also requires a graded FHA for radiological facilities that exceed the thresholds in 10 CFR Part 30. Examples of facilities not generally requiring an FHA include small utility buildings, trailers, and office buildings. 2. The purpose of an FHA is to conduct a comprehensive, qualitative assessment of the risk from fire within individual fire areas in a DOE facility to ascertain whether the DOE fire safety objectives of DOE O 420.1B are met. This should include an assessment of the risk from fire and related hazards (wildland fire exposure, direct flame impingement, hot gases, smoke migration, fire-fighting water damage, etc.) in relation to existing or proposed fire safety features to ensure that the facility can be safely controlled and stabilized during and after a fire. In accordance with the "graded approach" concept, the level of detail necessary for an acceptable FHA is directly related to the complexity of the facility and the potential risk to the public and facility operators. The scope and content of an FHA should be limited to only those issues that are significant and relevant to the facility. To facilitate the development of graded fire hazards analyses, "model" FHAs have been developed. These models are located at the following URL: 3. Analysis of significant planned facilities included in the FHA process should begin early in the design phase to ensure that an acceptable level of protection is being incorporated in the evolving design. This project or preliminary FHA should be updated whenever significant changes occur within an individual fire area and should form the basis for post-construction FHA included in the review and revision schedule per Chapter II, Section 3b(5)(b) and 3b(5)(c) of DOE O 420.1B. The analysis shall also support the conclusions of a preliminary Documented Safety Analysis (DSA) where required. In situations where the AHJ has determined that an FHA is necessary for a significant new facility that is not considered hazardous; then post-construction FHA reviews and revisions are not required. 4. In accordance with DOE O 420.1B, the FHA must be performed under the direction of a qualified fire protection engineer (Reference DOE-STD and DOE-STD , Fire Protection Engineering Functional Area Qualification Standard.) This should include directing all of the technical aspects of an FHA s development including support from emergency services, systems, electrical, and mechanical engineers, as well as operations staff as needed. 5. An FHA should contain, but not be limited to, a conservative assessment of the following fire safety issues: Description of construction Description of critical process equipment

22 17 DOE - STD X-XX-XX Description of high-value property Description of fire hazards Description of operations Potential for a toxic, biological and/or radiological incident due to a fire Natural hazards (earthquake, flood, wind, lightning, and wildland fire) impact on fire safety Damage potential: Include both the Maximum Possible Fire Loss (MPFL) as defined in DOE-STD and the DSA of the design basis fire scenario Fire protection features Protection of essential safety class systems Life safety considerations Emergency planning Fire Department/Brigade response Recovery potential Security and Safeguards considerations related to fire protection Exposure fire potential and the potential for fire spread between two fire areas Effect of significant fire safety deficiencies on fire risk Environmental impacts from a fire including suppression system run-off considerations 6. The FHA should evaluate the consequences of a single, worst-case automatic fire protection system malfunction; i.e., a detection system that also activates a pre-action type sprinkler system, but fails to transmit an alarm to the site emergency response force. This FHA evaluation may also include the failure of a valve in the underground main that could impair multiple systems, either in the same building or in adjacent buildings evaluated as an exposure. 7. In determining the value of the MPFL, which is used in part to assess the need for fire protection systems, the basic assumption should be that there is no automatic or manual fire suppression. This loss determination should include all direct and indirect costs associated with the fire and clean-up operations. In addition, there may be intangible costs such as mission interruption, erosion of public support, and local economic impact. All of these may need to be considered to ensure that appropriate levels of fire protection are included in a facility. Direct and indirect costs that should be included are: a. Replacement cost of building and building systems or contents within the fire area b. Replacement cost of contents c. Cost of lost time (considered mission interruption costs) d. Cost of environmental clean-up

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