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DEFENSE NUCLEAR FACILITIES SAFETY BOARD
Defense Nuclear Facilities Safety Board
DOCUMENT ID: [Recommendation 2008-1]
NOTICE: NOTICES
DOCUMENT ACTION: Notice, recommendation.
SUBJECT CATEGORY: Safety Classification of Fire Protection Systems
DATES: Comments, data, views, or arguments concerning the recommendation are due on or before March 7, 2008.
DOCUMENT SUMMARY: The Defense Nuclear Facilities Safety Board has made a recommendation to the Secretary of Energy pursuant to 42 U.S.C. 2286a(a)(5) which addresses the safety classification of fire protection systems at defense nuclear facilities in the Department of Energy complex.
SUMMARY: Safety Classification of Fire Protection Systems,
FOR FURTHER INFORMATION CONTACT Brian Grosner or Andrew L. Thibadeau at the address above or telephone (202) 6947000.
Dated: January 31, 2008.
A.J. Eggenberger,
Chairman.
Recommendation 20081 to the Secretary of Energy Safety Classification
of Fire Protection Systems Pursuant to 42 U.S.C. 2286a(a)(5) Atomic Energy Act of 1954, As Amended
Date: January 29, 2008.
Fire protection systems in defense nuclear facilities have generally not been designated as ``safetyclass'' as that term pertains to protection of the public from accidents. Such designation would bring into play a variety of Department of Energy (DOE) rules and directives, among them DOE Order 420.1B, Facility Safety, and DOE Guide 420.11, Nonreactor Nuclear Safety Design Criteria and Explosives Safety Criteria. While these documents describe general requirements for safetyclass systems, e.g., redundancy and quality assurance, they do not provide specific guidance on how a fire protection system such as an automatic sprinkler system should be designed, operated, and maintained.
Accordingly, when DOE's Savannah River Site contractor proposed in the late 1990s that certain fire protection systems employed in the site's tritium facilities be designated as safetyclass (and thus credited with protecting the public from accidents involving an offsite release of tritium), both DOE and the Defense Nuclear Facilities Safety Board (Board) were forced to conduct reviews of the proposal on an ad hoc basis without reference to specific guidance. The Board's review led to a March 18, 1999, letter to the Secretary of Energy agreeing with the reclassification of certain fire protection systems at the site's tritium facilities. The technical basis for the Board's agreement is found in the report appended to the letter:
Controlling incipient fires through operability of a more
reliable fire suppression system would make large fires less likely
to occur. To substantially reduce the predicted likelihood of such fires to the ``extremely unlikely'' frequency range, WSRC
reclassified the fire suppression (and some detection) systems as
safety class. TSRs will be applied to fire protection systems
falling in this category * * * WSRC acknowledges that installed fire
suppression systems will not meet criteria such as redundancy or
nucleargrade quality assurance, nor are these systems seismically
qualified. Imposition of safetyclass requirements means that, in
addition to meeting National Fire Protection Association (NFPA) code
requirements, higher levels of maintenance and surveillance and of
operability for these systems will be addressed in the TSRs. The
intent is to increase the reliability of the suppression systems to
maintain the SAR assumption that fullfacility fires will be
extremely unlikely. The TSRs will require that immediate actions be
taken, such as cessation of operations and posting of a fire watch,
should a safetyclass fire suppression system be taken out of service or found to be inoperative.
In June of 2000, the Board addressed more broadly the safety classification of fire protection systems. In Section 3.3 of Technical Report DNFSB/TECH27, Fire Protection at Defense Nuclear Facilities, the Board stated:
Designation of safetyclass or safetysignificant structures,
systems, and components (SSCs), administrative controls, and
engineered design features is determined through a prescribed
methodology (DOESTD300994, [U.S. Department of Energy, 1994] and
DOE G 420.12, [U.S. Department of Energy, 2000]) that relies to a
large extent on the engineering judgment of the safety analysts and
designers. Overall, the objective is to prevent a fire, or to control and confine a fire should one occur. Methods of
accomplishing this objective are set forth in NFPA codes that have
been a requirement of the DOE program for decades. It is essential
that decisions concerning the application of these codes and the
selection of features and controls be made by qualified and experienced fire protection engineers.
This section of the report provided additional guidance on application of these principles to the control of ignition sources, use of passive fire barriers, suppression of incipient fires, minimization of transient combustibles, and enhancement and protection of confinement systems such as ventilation through HEPA (high efficiency particulate air) filters. The report acknowledged the Board's letter regarding Savannah River's tritium facilities and encouraged the safety designation of suppression systems when they are relied on for critical safety functions: ``Fire sprinkler systems relied upon for worker safety and public protection should be classified as safetyclass or safetysignificant SSCs because they provide the most effective, automated, and quick response to a fire.'' (Report, p. 33) The report noted that the Los Alamos National Laboratory (LANL) had identified the fire sprinkler system in the Chemistry and Metallurgy Research Facility as a vital system and had begun an effort to inspect and test the system for functional performance.
Subsequent to the Board's 1999 letter and 2000 technical report,
DOE expanded its reliance on fire protection systems as primary lines
of defense against accidents. For example, the following projects
initially planned or reclassified fire protection systems as safety class or safetysignificant:
Although it should be clear from the Board's earlier statements
that it can support reliance on fire protection systems as primary safety measures, the Board is no longer comfortable with
[[Page 6939]]
such widespread reliance in the continued absence of specific criteria
for the design and operation of such systems. At this time, DOE's fire
protection guidance documents do not provide design and operational
criteria for fire protection systems designated as safetyclass or
safetysignificant. This lack of guidance makes design of new
facilities more difficult and timeconsuming and renders problematic
the assessment of proposed enhancements to fire protection systems in
existing facilities. In the latter case, possible upgrades to existing
systems can be evaluated using a procedure developed by the Energy
Facility Contractors Group (EFCOG), Safety System Design Adequacy
(August 2004). Proper application of this procedure demands that an
existing system be compared with ``a set of appropriate design,
quality, or maintenance requirements, specifically including applicable
current codes and standards.'' At present, DOE does not have a set of requirements that would permit use of the EFCOG procedure.
Lack of suitable requirements and guidance does not pose an
immediate safety issue, because each separate project listed above can
be evaluated on an ad hoc basis both by DOE and by the Board. However,
this unstructured approach is wasteful of DOE and Board resources and
prevents the sharing of technical knowledge and engineering solutions
throughout the complex. More importantly, the Board's enabling legislation, 42 U.S.C. 2286a(a)(1) requires that it
* * * recommend to the Secretary of Energy those specific
measures that should be adopted to ensure that public health and
safety are adequately protected. The Board shall include in its
recommendations necessary changes in the content and implementation
of such standards, as well as matters on which additional data or additional research is needed.
Because the Department has chosen to increase its reliance on fire protection systems as primary safety systems, the Board concludes that the Department should without delay develop standards in this area. These standards should be sufficiently specific to guide both the design of new fire protection systems and the reclassification of existing systems. All of the necessary attributes of a safetyclass or safetysignificant fire protection system should be identified, leaving room for engineering judgment and innovative approaches in achieving high reliability and quality.
The Board observes that work on revising a key fire protection directive, DOESTD106699, Fire Protection Design Criteria, is expected to commence early in 2008 and be completed by the end of the year. Incorporation of suitable guidance for safety classification of fire protection systems in this standard would be a good starting point for carrying out the purposes of this Recommendation. Other guides that may need enhancement or revision include DOE Guide 420.11, Nonreactor Nuclear Safety Design Criteria and Explosives Safety Criteria, and DOE Guide 420.13, Implementation Guide for DOE Fire Protection and Emergency Services Programs. Safety classification of fire protection systems may necessitate changes to other DOE orders or directives.
Pursuant to its statutory mandate to recommend needed changes in DOE's standards for safety at defense nuclear facilities, the Board recommends that DOE:
1. Develop design and operational criteria for safetyclass and safetysignificant fire protection systems.
2. Use the revision of DOESTD106699, Fire Protection Design Criteria, as a starting point to provide suitable guidance for safety classification of fire protection systems. The revision to this standard must incorporate:
a. Design approaches for a variety of fire protection systems, e.g., automatic sprinklers, gaseous suppression, alarm, detection, and passive barriers, that can be used to achieve safetyclass or safety significant designation.
b. Guidance on technical safety requirements and administrative controls, in areas such as maintenance, tests, and configuration control, so as to ensure the operability of safetyclass and safety significant fire protection systems.
3. Identify design codes and standards for safetyclass and safety significant fire protection systems and their components, and incorporate them into DOE Guide 420.11, Nonreactor Nuclear Safety Design Criteria and Explosives Safety Criteria.
4. Modify other DOE directives and standards as necessary to ensure
consistency with the new guidance for fire protection systems. A.J. Eggenberger,
Chairman.
[FR Doc. E82185 Filed 2508; 8:45 am]
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