DOE-STD-1066-99 (September 2010) Editor s Note: Need DOE Tech Standard Tool Kit disk for Cover and Concluding Material templates NOT MEASUREMENT SENSITIVE DOE-STD-1066-10 September 2010 Superseding DOE-STD-1066-99 DOE STANDARD FIRE PROTECTION DESIGN CRITERIA U.S. Department of Energy Washington, DC 20585 AREA FIRP DISTRIBUTION STATEMENT. Approved for public release; distribution is unlimited.
FOREWORD DOE-STD-1066 was originally a repository for requirements that were in DOE O 6430.1A, General Design Criteria, and DOE Order 5480.7A, Fire Protection. These Orders were abolished in an initiative to eliminate prescriptive requirements and replace them with goals. DOE-STD-1066 also contains criteria to address DNFSB concerns over such issues as fire protection of HEPA filters and seismic criteria for sprinkler systems. In 2010, several additional fire protection guidance directives were abolished and their contents added to DOE STD-1066: DOE-STD-1088, Fire Protection for Relocatable Structures; DOE G 420.1-3, Implementation Guide for DOE Fire Protection and Emergency Services Programs for Use with DOE O 420.1B, Facility Safety; and DOE G 450-1.4 IMPLEMENTATION GUIDE WILDLAND FIRE MANAGEMENT PROGRAM for Use with DOE 450.1, Environmental Protection Program; This Department of Energy Standard is approved for use by all DOE elements and their contractors. DOE Standards are part of the DOE Directives System and are issued to provide supplemental guidance regarding the Department's expectations for fulfilling its requirements as contained in rules, Orders, and notices. The Standards provide acceptable methods for implementing these requirements. Beneficial comments (recommendations, additions, deletions) and any pertinent data that may improve this document should be sent to the name and address below by letter or by using the self-addressed Document Improvement Proposal (DOE F 1300.3) appearing at the end of this document. Office of Environment, Safety and Health Office of Nuclear Safety Policy and Assistance U.S. Department of Energy 19901 Germantown Road Germantown, MD 20874-1290 iii
TABLE OF CONTENTS 1 SCOPE... 1 2 PURPOSE... 1 3 OBJECTIVES... 2 4 REFERENCED CRITERIA... 3 5 DEFINITIONS... 3 6 FIRE PROTECTION PROGRAM... 9 6.1 General... 9 6.2 National Standards... 9 6.3 Fire Protection Policy Statement... 10 6.4 Authority Having Jurisdiction... 10 6.5 Fire Protection Staff... 11 6.6 Fire Protection Program Documentation... 12 6.7 Inspection, Testing and Maintenance... 12 6.8 Fire Hazards Analysis... 13 6.9 D&D Facilities... 18 6.10 Fire Protection Assessments... 21 6.11 Corrective Action... 24 6.12 Exemptions Variances & Equivalencies (Approved Requirement Relief)... 24 7 EMERGENCY RESPONDER GUIDANCE... 29 7.1 Fire Department Resources... 30 7.2 Staff... 31 7.3 Training and Drills... 31 7.4 Pre-Incident Fire Activities... 32 7.5 Fire-fighting Activities involving special hazards... 32 7.6 Baseline Needs Assessment... 32 8 FIRE PROTECTION DESIGN GUIDANCE... 34 8.1 Protection to Limit Loss Potential... 35 8.2 New Facility Design Requirements... 36 9 WATER SUPPLY AND DISTRIBUTION SYSTEMS... 37 9.1 Demand... 37 9.2 System Arrangement... 38 1
10 AUTOMATIC SPRINKLER SYSTEMS... 39 10.1 General Application... 41 10.2 Seismic Criteria... 41 11 FIRE ALARM SYSTEMS... 41 11.1 General Application... 42 11.2 Alarm Actuating Devices... 42 11.3 Alarm System Extensions... 42 12 STRUCTURAL FIRE PROTECTION CRITERIA... 42 12.1 General... 42 12.2 Fire Barriers... 43 12.3 Flame Spread... 43 12.4 Roofing Systems... 44 12.5 Penetrations... 44 12.6 Carpets and Rugs... 44 13 LIFE SAFETY... 45 14 ELECTRICAL EQUIPMENT... 46 15 GENERAL PROCESS HAZARD FIRE PROTECTION... 46 16 SPECIAL HAZARDS... 47 16.1 Plutonium Processing and Handling Facilities (PPHF)... 47 16.2 Plutonium Storage Facilities (PSF)... 48 16.3 Enriched Uranium Storage Facilities (EUSF)... 48 16.4 Uranium Processing and Handling Facilities... 48 16.5 Reprocessing Facilities... 48 16.6 Uranium Conversion and Recovery Facilities... 49 17 NUCLEAR FILTER PLENUM FIRE PROTECTION... 49 17.1 Purpose and Scope... 49 17.2 Filter Plenum Construction... 50 17.3 Location of Final Filter Plenum Ventilation System Equipment... 50 17.4 Protection of Openings in Fire Rated Construction... 51 17.5 Materials and Special Hazards Inside Plenums... 52 17.6 Prefilters, Duct Entrance Filters, and Fire Screens... 53 18 Detection Systems... 54 18.1 Detectors... 54 2
18.2 Deluge Spray Suppression Systems... 55 18.3 Design of Automatic Deluge and Water Spray Systems... 56 18.4 Design of Manual Spray Systems... 57 18.5 Water Supply Guidelines... 57 18.6 Special System Guidelines... 58 18.7 Fire Hazard Analysis... 59 19 GLOVEBOX FIRE PROTECTION... 59 19.1 Scope... 59 19.2 Glovebox Construction... 60 19.3 Automatic Fire Suppression/Inerting Systems... 62 19.4 Automatic Fire Suppression Systems... 63 19.5 Manual Fire Suppression... 65 19.6 Fire Detection Systems... 66 19.7 Glovebox Ventilation... 66 20 Safety Classification Fire Protection Systems... 67 20.1 Wet Pipe Automatic Sprinkler Installations... 67 20.2 Water Supply... 69 20.3 Fire Barriers... 71 21 Relocatable Structures... 73 21.1 General... 73 21.2 Location Restrictions... 76 21.3 Occupancy Considerations... 77 21.4 Fire Protection Requirements... 78 22 Wildland Fire Management... 79 22.1 Wildland/Urban Interface... 80 22.2 Wildland Fire Prevention... 81 22.3 Preparedness Actions... 82 22.4 Wildland Fuels Management... 84 Appendices 3
1 SCOPE The provisions of this Standard apply to the following: 1. All departmental elements as identified in the scope of DOE O 420.1 B, Facility Safety, and its respective Contractor Requirements Document (CRD); DOE 440.1 B, Worker Protection Management Program for DOE (Including the National Nuclear Security Administration) Federal Employees; and, 10 CFR Part 851, Worker Safety and Health Programs 2. The purchase and lease, as well as the design and construction, of all DOE facilities erected, modified, or renovated after the effective date of this Standard on or off a DOE site after the effective date of this Standard. This standard may not apply to non-government facilities or to facilities of other agencies on DOE sites where fire protection requirements are enforced by other Government agencies. Where criteria differ for new and existing installations, the term new means any installation after the date of the predecessor directive in which the new guidance first appeared. In other words, it is not acceptable to omit a feature during construction and then justify omission because the installation is existing. Furthermore, a feature may not be removed or disabled after the facility or installation becomes operational. Unless specifically required by a DOE contract, directive, or regulation, provisions of this standard provides guidance on acceptable methods that must be considered to meet DOE requirements. Nothing in this Standard is intended to limit the application of other fire protection methods when unique situations or hazards warrant an alternate approach. Any alternate approach should provide a level of safety equal to that achieved by conformance with this Standard. Such alternate approaches must be documented approved by the Authority Having Jurisdiction (AHJ), after consultation with a qualified fire protection engineer. 2 PURPOSE The purpose of this Standard is to facilitate implementation of requirements in Department of Energy (DOE) Order (O) 420.1, Facility Safety, by providing supplementary information that describes an acceptable approach to meet the DOE O 420.1B requirements for Fire Protection Programs. This document also addresses, in part and where appropriate, the relationship of fire protection requirements in DOE O 420.1B and the following DOE documents: 10 CFR Part 851, Worker Safety and Health Program DOE O 440.1B, Worker Protection Program for DOE (Including the National Nuclear Security Administration) Federal Employees DOE Guide (G) 440.1 8, Implementing Guide for Use with 10 CFR Part 851, Worker Safety and Health Programs DOE O 151.1C, Comprehensive Emergency Management System 1
These additional documents are available at the DOE Fire Protection Website: (http://www.hss.energy.gov/nuclearsafety/nsea/fire//) and/or at the DOE Directives Website (http://www.directives.doe.gov/) and/or at the DOE Technical Standards Website (http://www.hss.energy.gov/nuclearsafety/techstds/) 3 OBJECTIVES FIRE PROTECTION GOALS- - DOE O 420.1B establishes facility and programmatic safety requirements for a comprehensive fire protection program for DOE sites, facilities, and (1) minimize the potential for occurrence of a fire or related event, i.e, prevent fires and related accidents; (2) minimize fires that cause an unacceptable onsite or offsite release of hazardous or radiological material that could impact the health and safety of employees, the public, or the environment, i.e. if a fire occurs, limit its growth to a size that does not challenge thresholds; (3) minimize unacceptable interruption of DOE missions, especially vital DOE programs as a result of fire and related hazards, i.e. provide sufficient barriers to prevent loss of essential production or analysis capability, failure to meet compliance agreements, Congressional mandates, WIPP delivery schedules, etc; (4) minimize property loss from fire exceeding limits established by DOE; and (5) minimize fire damage to safety basis credited process controls and safety systems structures and components (as documented by appropriate safety analysis) FIRE PROTECTION PROGRAM DOE O 420.1X requires a comprehensive fire protection program. Comprehensive fire safety and emergency response programs at DOE sites and facilities include, but are not limited to, 1. appropriate policies, requirements, technical criteria, analyses, administrative procedures, and related documentation. 2. adequately designed, installed and maintained fire safety systems, hardware, structural features, and related devices 3. access to fully capable emergency response forces with trained personnel and adequate apparatus and equipment that enable these forces to respond in a timely and effective manner. Where the l emergency response capability is deemed insufficient, appropriate compensatory measures are implemented to address baseline needs. 4. The professional staff, general worker population, student interns and visiting scientist and researchers at these sites and facilities are appropriately trained on the fire hazards and related conditions that they are likely to encounter. The visiting public is provided with escorts and safety briefings when exposed to fire and safety hazards to which the generally public is not typically exposed. 5. A staff of qualified and experienced fire safety professionals. 2
Additional guidance on how to meet DOE expectations for the above-referenced programs is delineated below. This guidance supplements general industry criteria, and contractual obligations. This additional guidance is referenced to the specific sections of the DOE O 420.1X where additional guidance was deemed warranted by DOE and DOE contractor fire safety professionals. 4 REFERENCED CRITERIA DOE facilities and their associated fire protection features are subject to the applicable sections of the current editions of the criteria listed below: Federal Criteria DOE Requirements Department of Energy (DOE) Order (O) 420.1, Facility Safety DOE Guidelines Other Criteria National Fire Protection Association (NFPA) NFPA 1710, Standard for the Organization and Deployment of Fire Suppression Operations, Emergency Medical Operations, and Special Operations to the Public by Career Fire Departments NFPA 801 NFPA 30, Flammable and Combustible Liquids Code NFPA Standard 1143, Wildland Fire Management International Building Code Referenced Standards DOE-STD-1088-95 DOE-STD-1137-2007, Fire Protection Engineering Functional Area Qualification Standard 5 DEFINITIONS Acceptable - When applied to fire safety, "acceptable" is a level of protection which the Authority Having Jurisdiction, after consultation with the cognizant DOE fire protection engineer(s), considers sufficient to achieve the fire and life safety objectives defined in DOE Orders. In some instances, it is a level of protection necessary to meet a code or standard. In other 3
instances, it is a level of protection that deviates (plus or minus) from a code or standard as necessary and yet adequately protects against the inherent fire hazards. Adsorber Systems - A system for removing gases or vapors from air by means of preferential physical condensation and retention of molecules on a solid surface. Adsorbers used in nuclear applications are often impregnated with chemicals to increase their activity for organic radioactive iodine compounds. Authority Having Jurisdiction (AHJ) - The decision making authority in matters concerning fire protection. The DOE Head of Field Organization or designee is the final AHJ unless otherwise directed by the Cognizant Secretarial Officer (DOE O 420.1B. 5. d. (10). Routine AHJ functions which do not involve deviation from codes, standards, guides, or other requirements may be delegated to qualified contractors. Building Code Official (BCO) - The decision making authority in matters concerning the building code. The DOE Head of Field Organization or designee is the final BCO unless otherwise directed by the Cognizant Secretarial Officer. Code of Record The installation requirements (code or standard) in effect at the time a facility or item of equiptment was designed and constructed. Combustible Liquid - Any liquid that has a closed cup flash point at or above 100 F (37.8 C), as determined by the test procedures and apparatus set forth in Section 4.4 of NFPA 30, Flammable and Combustible Liquids Code. Combustible liquids are classified according to Section 4.3 of NFPA 30. Combustible Material - Any material that will ignite and burn. Any material that does not meet the definition of "noncombustible" as contained in this Standard is considered combustible. The term combustible is not related to flame spread rating. Combustible materials as defined in NFPA 101 includes a material that, in the form in which it is used and under the conditions anticipated, will ignite and burn; a material that does not meet the definition of noncombustible or limited-combustible. Criticality Incident - The release of energy as a result of accidentally producing a self-sustaining or divergent neutron chain reaction. Deep Bed Fiberglass Filter - A ventilation filter made of deep beds of compacted fiberglass contained in stainless steel boxes having opaque sides and perforated screens at the top and bottom for the removal of particulate matter. Deep Bed Sand Filter - Particulate filter constructed of deep beds of rock, gravel, and sand, formed in layers graded with about two to one variation in granule size from layer to layer. Demister - A device used to protect the final filter in an air cleaning system from entrained moisture in the air. Documented Safety Analysis An analysis of the extent to which a nuclear facility can be operated safely with respect to workers, the public, and the environment, including a description 4
of the conditions, safe boundaries, and hazard controls that provide the basis for ensuring safety (10 CFR 830.3). Duct Entrance Filter - A type of pre-filter unit installed at the exhaust duct entrance(s) to prevent entrance and accumulation of combustible or flammable dusts and/or residues inside the exhaust ducts. (Note: This is a concern of particular interest to the nuclear industry because radioactive and other substances tend to deposit or "plate out" on ducts. Dust accumulation on interior duct surfaces can spread fires directly to the final exhaust plenum filters.) Emergency Services Organization The site fire department, brigade, or other organization that performs any or all of the following functions: Fire Suppression Hazardous Material (HAZMAT) Response Emergency Medical Services Technical Rescue Confined Space Entry Training Off-site Assistance to Other Emergency Services Organizations (Mutual Aid) Inspection, Testing and Maintenance of Fire Protection Equipment or Apparatus Facility Fire Prevention and Life Safety Inspections Exhaust Plenum Final Filter - The final High Efficiency Particulate Air filter unit in a set of filters arranged in a series for ventilation and effluent discharge in an air cleaning system. Fire - Unplanned destructive burning, including explosions (detonation or deflagration), as manifested by any or all of the following: light, flame, heat or smoke. Fire does not include the following unless they cause a fire or occur as a consequence of a fire: lightning or electrical discharge, rupture of a pressure vessel not caused by internal combustion, detonation of munitions, or overheat [without damage to initiating material.] Fire Area - A location bounded by construction having a minimum fire resistance rating of 2 hours with openings protected by appropriately fire-rated doors, windows, dampers, or penetration seals. The boundaries of exterior fire areas (yard areas) or other locations that represent unique conditions should be as determined by the cognizant fire protection engineer (contractor or DOE). (When relocatable structures are grouped and are not separated as directed in this standard, they should be considered as being part of the same fire area. (Extracted from DOE-STD-1088-95) Fire Barrier - A fire resistance-rated vertical or horizontal assembly of materials designed to restrict the spread of fire in which openings and penetrations are protected. [NFPA 801, Section 3.3.7 and International Building Code Section 702.1] NOTE: Fire barriers may be structural bearing or non-bearing (walls, ceilings, floors) or non-structural (e.g. cable tray or duct wrap fire barriers). 5
Fire Loss - The dollar cost of restoring damaged property to its pre-fire condition. When determining loss, the estimated damage to the facility and contents should include replacement cost, less salvage value. Fire loss should exclude the costs for: property scheduled for demolition; and decommissioned property not carried on books as a value. Fire loss should include the cost of: Replacement cost of building and building systems or contents within the damaged area Replacement cost of contents Cost of lost time (considered mission interruption costs) including maintained payroll and purchase of alternative production Cost of decontamination and environmental clean-up Exposure damage to other buildings, structures and property Costs for re-establishing operations; e.g., redesign approval and start-up Indirect costs of fire extinguishment (such as fire department equipment) Fire Protection A broad term which encompasses the aspects of fire and life safety, concerned with minimizing the direct and indirect consequences of fire and other perils, such as explosions and natural phenomenon events as they relate to fire. Aspects of fire protection include, but are not limited to, fire suppression and detection systems, fire water systems and emergency process safety control systems, building construction and fixed building features such as fire doors, fire walls and barriers, and fire dampers. Also included are the fire department and emergency response forces. Fire Protection Assessment A formal documented review conducted by DOE or Contractors in accordance with DOE requirements that examine the essential fire protection elements as they relate to a specific facility or overall fire protection program. Fire Protection Engineer - A graduate of an accredited engineering curriculum and having completed not less than 4 years of engineering practice, 3 of which shall have been in responsible charge of diverse fire protection engineering work. If not such a graduate, a qualified engineer shall either: demonstrate a knowledge of the principles of engineering and have completed not less than 6 years engineering practice, 3 of which shall have been in responsible charge of diverse fire protection engineering projects; be a registered professional engineer in fire protection; or meet the requirements for a Grade 11 or higher Fire Protection Engineer as defined by the Office of Personnel Management. Fire Protection System - Any system designed to detect contain or extinguish a fire, limit the extent of fire damage and enhance life safety. (These include: Automatic suppression systems, such as fire sprinklers, foam, gaseous, explosion suppression, or other specialized extinguishing systems plus appropriate alarms. An adequate supply, storage, and distribution system is an essential element. Automatic fire detection, occupant warning, manual fire alarm, and fire alarm reporting systems. Fire barrier systems or combinations of physical separation and barriers for outdoor locations. (Extracted from DOE-STD-1088-95 NOTE: this is the same as Redundant Fire Protection System described below) 6
Fire Prevention The process of managing and regulating potential fire hazards (fuels and heat energy sources) and the mechanisms that bring them together to either eliminate the hazard(s) or reduce the risk associated with the hazard(s). Fire Resistance Rating - The time, in minutes or hours, that materials or assemblies have withstood a fire exposure as determined by a fire test or methods based on tests [NFPA 221, Section 3.3.6]. The fire test exposure is established in accordance with test procedures of NFPA 251, ASTM E 119 and ANSI/UL 263 are similar to NFPA 251. Recognized methods based on tests (using exposure and acceptance criteria of ASTM E 119) are prescriptive designs and/or calculation methods documented in the building code, Section 719, American Iron and Steel Institute Fire Resistance Design Guide and Fire Resistance Ratings of Load Bearing Steel Stud Walls with Gypsum Wallboard Protection, Gypsum Wallboard Association s Fire Resistance Design Manual, FM Global Property Loss Prevention Data Sheets, and American Society of Civil Engineers/Society of Fire Protection Engineers Standard Calculation Method for Structural Fire Protection. Fire Screen - An item of equipment installed ahead of all HEPA filter banks intended to reduce glowing/burning ember products from reaching final (HEPA) filters. Flammable Liquid - Any liquid that has a closed cup flash point below 100 F (37.8 C), as determined by the test procedures and apparatus set forth in Section 4.4 of NFPA 30, Flammable and Combustible Liquids Code, and a Reid vapor pressure that does not exceed an absolute pressure of 40 psi (76 kpa) at 100 F (37.8 C), as determined by ASTM D 323, Standard Test Method for Vapor Pressure of Petroleum Products (Reid Method). Flammable liquids are classified according to Section 4.3 of NFPA 30. Flame Spread Rating - Flame spread rating is a numerical classification determined by the test method in ASTM E-84, which indexes the relative burning behavior of a material by quantifying the spread of flame of a test specimen. The surface burning characteristic of a material is not a measure of fire resistance or combustibility. Glovebox - A sealed enclosure with viewing windows designed to separate the space in the enclosure from its surroundings and in which all items in the enclosure are handled using gloves that are sealed to the enclosure walls. High Efficiency Metal Fiber (HEMF) Filter - A reusable metal filter composed of fine sintered stainless steel fibers together with a stainless steel wire and metal support housing and pleated to enhance strength, surface area, and particle holding capacity. High Protected Risk (HPR) - HPR is a fire insurance term that if achieved gives the best insurance rate for that class of business. As DOE is self insured, maintaining the HPR level of best of insurance provides for the best fire protection features and implies that the facility will have the lowest possible fire looses. One method to achieve and maintain the HPR status is to use the FM Global Loss Prevention Data Sheets in the design, construction, and operations of a facility. The use of FM Global Data Sheets to achieve HPR in design, construction, and operations goes beyond the use of the Data Sheets that relate to fire protection systems. 7
Limited Supply Suppression System - A system installed in accordance with the applicable NFPA Standards and having a limited quantity of suppression agent. These systems typically include carbon dioxide, dry chemical, other gaseous agents, or water. Listed/Approved - Equipment or materials that have been tested, passed, and are included in a current list published by a nationally recognized testing laboratory which is concerned with product evaluation and is acceptable to the AHJ. The laboratory maintains periodic inspection of production of listed equipment or materials. Such lists state either that the equipment or material meets appropriate standards or has been tested and found suitable for use in a specified manner. This definition applies to products which are Underwriter's Laboratories (UL) listed or Factory Mutual (FM) approved. Maximum Possible Fire Loss (MPFL) - The value of property, excluding land value, within a fire area, unless a fire hazards analysis demonstrates a lesser (or greater) loss potential. This assumes the failure of both automatic fire suppression systems and manual fire fighting efforts. Noncombustible - A material that in the form in which it is used and under the conditions anticipated will not ignite, burn, support combustion, or release flammable vapors when subjected to fire or heat, as determined by ASTM Standard E-136. Occupancy - The purpose for which a building, or portion thereof, is used or intended to be used. For DOE facilities, the occupancy classification for purposes of determining construction, protection and area limitations should be as determined under the provisions of the [International Building Code unless otherwise specified by the AHJ. Prefilter - A filter that is located upstream from another filter. Prefilters, or roughing filters, remove and/or reduce the amount of large particles that could reduce the life of the next-in-line or final filters. Pre- Fire Plan A document owned and developed by a fire department which provides information to responding personnel that will help them safely and effectively manage emergencies with available resources at a specific facility or area. Pyrophoric Material - A material capable of igniting spontaneously in air at normal temperatures. Qualified Fire Protection Engineer A fire protection engineer who has completed the criteria in DOE-STD-1137. Redundant Fire Protection System - A fire protection system that is designed and installed to function in the event of the failure of a primary fire protection system. Relocatable Structure - Manufactured structures, mobile homes, trailers, semi-trailers, modular type structures, factory assembled structures, cargo containers, hazardous materials or flammable liquid storage containers, air supported/inflated structures, tent/membrane and cloth/rib structures. This term does not apply to trailers and cargo containers that are being 8
used in the transportation mode for conveying materials while onsite, or to prefabricated buildings that are permanently located, such as "Butler" or "Strand Steel" buildings. Structures not specifically identified herein should be referred to the AHJ for categorization. Smoke Developed Rating - Smoke developed rating is a numerical classification determined by ASTM E-84, which indexes the smoke generation rate of a given material to those of two standard materials (inorganic reinforced cement board and select grade red oak). 6 FIRE PROTECTION PROGRAM 6.1 General DOE and contractor fire safety programs include all activities pertaining to fire hazards and related perils including: emergency services, operations and maintenance activities such as hot work or combustible material handling or storage; construction activities related to fire safety; installation and testing of fire protection systems; water supply and distribution systems; fire safety training; assessments; facility and site walk downs; and other fire protection activities that are not explicitly identified here. Contractors can achieve and maintain a comprehensive site and facility fire protection program through implementation of applicable industry codes and standards (principally from the NFPA), as modified by DOE fire safety criteria. Site and facility fire protection programs are characterized by defense-in-depth. This means that adequate safety is assured by reliance on multiple levels of fire protection (fire safety policies, administrative procedures, active and, passive fire safety features, trained people, and an adequate emergency response capability, among other possible facets). Additionally, the long-term adequacy of site and facility fire safety programs require routine self-assessments of all aspects of the contractor s fire protection program. A corrective action program that facilitates the prioritization and timely remediation of all fire protection and emergency response deficiencies is required for a fire protection program to be successful in the long term. Deficiency discovery and resolution must include appropriate notification, reporting, tracking to closure, and trending of findings. Subcontractors can achieve compliance with DOE fire safety objectives through an established and appropriately documented relationship with a prime contractor s fire protection and emergency response program. In any case, the prime contractor s fire protection program requirements must flow down to all sub-contractors. 6.2 National Standards DOE O 420.1X reflects Public Law 100-678, as codified in 40 USC 3312, which requires acquisition, construction, and alteration of federal facilities to meet the latest edition of the national model building code as well as national standards for electrical, fire and life safety. National codes and standards provide minimum criteria which may not be sufficient for hazardous or high value facilities or for users that place a premium on safety or loss control. Beginning with the Manhattan Project, Departmental facilities were also required to meet Highly Protected Risk criteria. Highly Protected Risk (HPR) is an insurance industry term applied to property that qualifies for coverage by insurers such as FM Global (formerly called Factory Mutual) that limit their underwriting to the best-protected class of risk where they provide 9
superior fire protection engineering oversight while charging substantially lower premiums. (Insurance companies provided the leadership to develop the fire and building codes and are a major enforcer of fire protection in the private sector, so insurance terminology is often used in the field of fire protection.) HPR criteria can be found on the FM Global web site. Examples fire protection features or activities that may be found at qualifying as HPR includes, but is not limited to redundant water supplies, enhanced fire protection system inspection, testing & maintenance programs, applying recommendations from Factory Mutual Data Sheets to the protection of building and process hazards and associated equipment, etc. The National Fire Codes are comprised of over 200 codes and standards. In addition, ASTM and other organizations promulgate national standards for fire protection. DOE regulations and directives require use of applicable fire standards. The applicable standards are generally a small subset of the total which may vary significantly from facility to facility, depending on the use and hazards. Applicability can usually be determined by an applicability statement at the beginning of each standard. Needless to say, a subject matter expert familiar with the complete set of codes and standards should be consulted in selecting what is applicable for a specific facility as well as any time the use, contents, occupancy, or processes are changed. National codes and standards focus primarily on safety rather than functionality and must be supplemented by complete specifications to assure fully functional facilities and systems. The development of this Standard reflects the fact that national consensus standards and other design criteria do not comprehensively or, in some cases, adequately address special or unique fire protection issues at DOE facilities. 6.3 Fire Protection Policy Statement The intent of documenting policy statements is to have the uppermost levels of DOE and Contractor management state in writing their fire protection program expectations. Such policy statements should not conflict with regulatory, DOE, or contractual obligations. For site emergency services organizations, this policy statement should include fundamental statements regarding the level of service that DOE expects and the level of capability that the contractors intend to provide. (For example: DOE expects that the site fire department will maintain a capability to provide Advanced Life Support, as defined in the State of or will provide an emergency services capability that fully conforms with the requirements of the State of, DOE directives, and NFPA codes and standards, unless explicit relief has been granted by DOE. ) 6.4 Authority Having Jurisdiction Section 5d(10) of DOE O 420.1B assigns the responsibilities for the AHJ, in most cases, to the DOE heads of field elements under advisement of a qualified fire protection engineer as the subject matter expert (SME). The AHJ may designate a contractor as the site s Fire Marshall to act as his representative for routine activities such as: issuing of permits; reviewing and approving construction documents and shop drawings (new construction, modification, or renovation); accepting fire protection equipment, materials, installation, and operational procedures (fire system inspection and testing), interpretation of building codes or standards; and other activities that require AHJ approval. Fire Marshall activities, inclusive of this authority, should be well documented and available for AHJ review, including documents submitted to DOE/NNSA for Government review and approval. The DOE/NNSA retains the right to override 10
decisions of the Contractor s Fire Marshal, including the interpretation and application of DOE Orders, Guides, Standards, and mandatory codes and standards. In addition, this approval authority does not extend to the DOE/NNSA s approval of exemptions and equivalencies to DOE Orders, DOE Standards, and mandatory codes and standards such as those promulgated by the National Fire Protection Association. For the purposes of enforcing the adopted building code at sites, the Head of the DOE Field element is designated as the Building Official. The DOE Head of the Field element may delegate to the contactor in writing responsibility for decisions on diminutive issues, but not the responsibility for approving exemptions and variances to Building Code requirements. 6.5 Fire Protection Staff A sufficient number of qualified fire safety professionals (fire protection engineers, fire department management personnel, firefighters and technicians) should be on staff to develop, implement and maintain the fire protection and emergency response program. Staffing levels for the Contractor s fire protection program should be based on a "work load analysis" or similar analysis that provides a technical basis for the fire safety staff. Staffing for the fire department should be based upon conclusions reached in the Baseline Needs Assessment (BNA) required by DOE-O-420,1B. Established industry criteria, such as those promulgated by the NFPA, as supplemented by DOE fire safety criteria, should be the basis for site and facility fire safety and emergency response training and qualifications. Emergency services organization officers and personnel may additionally meet the minimum requirements for training and certifications as established by the state or local jurisdiction, as an alternative to DOE directives or applicable NFPA standards, provided those state and local requirements are substantially equivalent and approved by the AHJ. (Although State and local requirements do not apply on Federal reservations, it may be selectively desirable to apply them to facilitate mutual assistance agreements with nearby jurisdictions.) Sites should provide appropriate support or oversight personnel when using off-site fire departments, brigades and fire protection engineering support contractors as well as escorts for access to areas with classified material. Where reliance is placed on off-site fire brigades or fire departments for fire suppression, efforts should be made to obtain suitable clearances for fire response personnel in order to avoid delays in fire department response, and associated consequences (e.g., loss of life, injury, increased fire damage) that may result as a result of delayed response. An appropriate level of individualized safety and health training is expected to be provided to all workers including sub-contractors, visiting scientist and summer interns, and emergency responders in accordance with the provisions of 10 CFR Part 851 and the incorporated training requirements of 29 CFR 1910 and 1926. Particular attention is directed at the HAZWOPER training requirements. Such training and familiarization also applies, as appropriate, to managers and decision makers to the extent that they are involved in directing the actions of their subordinates in the face of known fire hazards and in conjunction with hazardous materials incidents and fires. Certain DOE personnel, including NNSA fire protection engineers are 11
required to complete and maintain the Technical Qualifications Program (TQP) for Fire Protection Engineer. All DOE Federal and contractor employees should be provided with a basic level of fire safety training and response to emergency training initially, with refresher training provided in conjunction with other general federal and contractor training programs. (This can include the distribution of printed matter and public address announcements.) It is important that the level of training provided match the level of the individual s responsibility. Members of the public should be provided with suitable orientation on the fire hazards (if any) that they may encounter while on site and the appropriate personal response, including escape and notification, if they should find themselves in an emergency situation. Where escorting is required, the responsibility (briefing escortees, dos and don ts, pointing out evacuation routes and muster areas, etc.) of the escort should be clearly defined. 6.6 Fire Protection Program Documentation The program should be completely documented. This includes a description of applicable fire safety requirements in contracts and leases, where appropriate. Documentation should also include a description of the fire protection organization and its roles and responsibilities in relation to other organizational entities. Training and qualification records of individuals having fire protection program responsibilities shall be readily available and in an auditable form. Appropriate fire protection documentation includes copies of all fire hazard analyses (FHAs) and at least the two most recent facility assessment reports in a continually updated filing system. FHAs and facility assessment reports may be combined, provided that they address all essential elements as defined below. Facility documentation should also include copies of any exemptions, equivalencies or deviations that have been approved by DOE. The Contractor s fire protection program must include oversight of fire protection aspects of new construction, facility modifications, the installation of potentially hazardous operations and experiments. In order to avoid project delays and last minute change requests this involvement must be early and beginning at project conception. For large projects it may be beneficial to establish a fire protection working group composed of DOE and Contractor fire protection engineers, safety basis representatives, responsible design engineers, operations personnel and others as may be appropriate. Such working groups can be successful in resolving fire protection challenges, ensuring that issues do not become side-tracked, identifying early the possible need for exemptions or equivalencies, and most important avoiding costly delays in design or construction. Construction projects should feature a file in which all significant decisions and reports concerning fire protection can be found. Supporting documents in this file should be maintained for future reference. 6.7 Inspection, Testing and Maintenance The inspection, testing and maintenance (ITM) program for fire protection features, apparatus and equipment should be based on industry standards, such as those established by the NFPA unless an alternative has been approved by the AHJ. The IT&M program must include a fire protection system impairments program, which at a minimum should consist of the process for approving and initiating impairments, the tracking of impairments, reporting to DOE when 12
impairments exceed DOE Site Office established criteria, as well as appropriate record (date, location, nature of impairment, corrective action taken, closure date, etc.). The organizations responsible for ITM of fire protection features should maintain system inspection and test records according to Section 11.4 of DOE Administrative Records Schedule 18, Security, Emergency Planning and Safety Records or, if not specifically addressed in the Schedule 18 document, for a minimum of three review cycles. In addition, responsible authorities should retain records of all ITM procedures for as long as such equipment remains in service. 6.8 Fire Hazards Analysis The purpose of an FHA is to conduct a comprehensive, qualitative assessment of the risk from fire in a DOE facility to ascertain whether the DOE fire safety objectives of DOE O 420.1B are met. This should include an assessment of the risk from fire and related hazards (wildland fire exposure, direct flame impingement, hot gases, smoke migration, fire-fighting water damage, etc.) in relation to existing or proposed fire safety features to ensure that the facility can be safely controlled and stabilized during and after a fire. In accordance with the "graded approach" concept, the level of detail necessary for an acceptable FHA is directly related to the complexity of the facility and the potential risk to the public and facility operators. A FHA for a fully compliant facility can be relatively brief but deviations from codes, standards or directives require documentation that may substantially increase the level of detail. The FHAs and facility assessment reports may be combined, provided that they address all essential elements. To facilitate the development of graded fire hazards analyses, the DOE Fire Protection Web Site contains copies of "models" of separate and combined FHAs and assessment reports. These models are located at the following URL: http://www.hss.energy.gov/nuclearsafety/nsea/fire//models/models.html An FHA is required for all Hazard Category 1, 2 and 3 nuclear facilities (as defined in DOE Standard 1027), high-hazard facilities as determined by the AHJ, significant new facilities, and when required by the DOE Field Element. This requirement includes planned facilities as well as renovations to existing facilities as determined necessary by the AHJ. NFPA 801 also requires a graded FHA for radiological facilities that exceed the thresholds in 10 CFR Part 30. Examples of facilities not generally requiring an FHA include small utility buildings, trailers, and small office buildings. For new construction and major facility modifications where an FHA does not already exist, development of a design analysis is acceptable. An analysis of planned facilities requiring an FHA should begin early in the development phase to ensure that an acceptable level of protection is being incorporated in the evolving design, including building placement, height, area per floor, emergency access, construction materials, fire areas, and other fire related details. This project or preliminary FHA (typically called a PFHA) should be updated whenever significant changes occur and should form the basis for post-construction FHA. The analysis shall also support the conclusions of a preliminary Documented Safety Analysis (DSA) where required. For significant new facilities that are not considered hazardous, the PFHA serves to guide the construction process and provide historic documentation but post construction FHA reviews and revisions are not required. [A Fire Protection Design Analysis should be developed for all major new projects, Hazard Category 1, 2 & 3 nuclear facilities, radiological facilities, high hazard and explosive facilities, or 13
when directed by DOE. The analysis should address the following topics 1) Introduction, 2) General Information (document and memo references, drawing references, definitions, and applicable DOE Orders & standards, and mandatory codes and standards, 3) Building details (property values, estimated fire loss potential, construction, detailed description of occupancy, process & other hazards, description of safety class or safety significant systems, utilities, exposure hazards, building specific fire protection features, proposed fire protection upgrades if applicable, post fire recovery plan, and life safety) 4) relevant site-wide fire protection systems (water supply & distribution system, fire alarm reporting system, fire protection system IT&M including record keeping, impairment control, fire department services, other emergency management operations, and security and safeguards considerations, 5) verification that the design complies with the objectives of DOE Order 420.1B, including sub-elements 6) fire protection system requirements, 7) compensatory and/or fire safety measures required during the construction phase, 8) fire control measures, 8) the need to a higher standard of fire protection in order to meet HPR, Safety Basis or other identified special needs, recommendations to address deficiencies in the design or construction process, and 9) a description of the use and associated hazard of each room or area when appropriate.] The FHA must be performed under the direction of a qualified fire protection engineer (Reference DOE-STD-1137-2007, Fire Protection Engineering Functional Area Qualification Standard.) This should include directing all of the technical aspects of an FHA s development including support from emergency services, systems, electrical, and mechanical engineers, as well as operations staff as needed. DOE-STD-1137 applies to Federal personnel and builds upon prerequisite OPM standards and professional engineering registration criteria. If adapted for use by contractor fire protection engineering staff, OPM and PE criteria should be included. An FHA should contain, but not be limited to, a conservative assessment of the following fire safety issues: a) Order, code & standard drivers b) Description of mission and associated hazards c) Description of construction d) Description of critical process equipment e) Description of high-value property f) Description of fire hazards g) Description of operations h) Potential for a toxic, biological and/or radiological incident due to a fire i) Natural hazards (earthquake, flood, wind, lightning, and wildland fire) impact on fire safety j) Damage potential: Include both the Maximum Possible Fire Loss (MPFL) and Maximum Probable Fire Loss, including the basis for the conclusions DSA design basis fire scenario a) Fire protection features, including special fire protection features, and fire protection features classified as Safety Class or Safety Significant. b) Protection of essential safety class systems 14
c) Life safety analysis d) Emergency planning e) Fire Department/Brigade response (may be discussed and evaluated in a stand-alone site wide document) f) Recovery potential g) Security and Safeguards considerations related to fire protection h) Exposure fire potential and the potential for fire spread between two fire areas i) Effect of significant fire safety deficiencies on fire risk j) Environmental impacts from a fire including suppression system run-off considerations A graded approach may omit some of these topics but it should be clear that omission was intentional. The FHA should evaluate the consequences of a single, worst-case automatic fire protection system malfunction; eg., failure of detection system used to activate a pre-action type sprinkler system, and transmit an alarm to the site emergency response force; or the failure of a valve in the underground main that could impair multiple systems, either in the same building or in adjacent buildings evaluated as an exposure. The FHA must address findings, and where appropriate provide a path forward for resolving the finding. It is recommended the FHA in addition to discussions of findings and recommendation found within the body of the report provide a listing of findings and associated recommendations in table format. This is to avoid the potential for findings and associated recommendations to become lost. A distinction should be made between mandatory recommendations including those listed as general industry practice and those proposed as a matter of preference. The focus of the Fire Hazards Analysis should be the individual fire areas that comprise the facility. A fire area is defined as a location bounded by fire-rated construction, having a minimum fire resistance rating of two hours, with openings protected by equivalently-rated fire doors, dampers or penetration seals. It cannot be assumed that a two hour rated boundary is sufficient to contain a worst case fire. Compliance with the building code may require 3- or 4- hour rated free-standing boundaries, without openings, designed to prevent failure in the event the structure on either side collapses. The boundaries of exterior fire areas (yard areas) should be as determined by the AHJ or delegated authority. Where a facility is not subdivided by firerated construction, the fire area should be defined by the exterior walls and roof of the facility. In production facilities, conveyor and trolley systems may pass through credited fire walls or barriers. In some instances the design and operation of the equipment may preclude the use of fire dampers and similar devices. Such installations in new construction may require fire testing and taking credit for all features (non-rated fire dampers, metal construction, the use of fire rated glass in addition to confinement control glass, etc.) of the conveyor/trolley design that will impede fire spread from one fire area to the adjacent fire area. In determining the adequacy of fire rated construction, especially where the facility structure or confinement system is being credited with preventing or limiting a radiological release, it is important to fully estimate fire load within the facility, including transient, process equipment and facility construction materials that are combustible. Example, a large process piping system 15