Safety Classification of Fire Protection Systems, 6938-6939 [E8-2185]

Agencies

• Defense Nuclear Facilities Safety Board

[Federal Register Volume 73, Number 25 (Wednesday, February 6, 2008)]
[Notices]
[Pages 6938-6939]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-2185]


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DEFENSE NUCLEAR FACILITIES SAFETY BOARD

[Recommendation 2008-1]


Safety Classification of Fire Protection Systems

AGENCY: Defense Nuclear Facilities Safety Board.

ACTION: Notice, recommendation.

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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.

DATES: Comments, data, views, or arguments concerning the 
recommendation are due on or before March 7, 2008.

ADDRESS: Send comments, data, views, or arguments concerning this 
recommendation to: Defense Nuclear Facilities Safety Board, 625 Indiana 
Avenue, NW., Suite 700, Washington, DC 20004-2001.

FOR FURTHER INFORMATION CONTACT: Brian Grosner or Andrew L. Thibadeau 
at the address above or telephone (202) 694-7000.

    Dated: January 31, 2008.
A.J. Eggenberger,
Chairman.

Recommendation 2008-1 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 ``safety-class'' 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 
420.1-1, Nonreactor Nuclear Safety Design Criteria and Explosives 
Safety Criteria. While these documents describe general requirements 
for safety-class 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 safety-class (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 
nuclear-grade quality assurance, nor are these systems seismically 
qualified. Imposition of safety-class 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 full-facility 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 safety-class 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/TECH-27, Fire Protection at Defense Nuclear Facilities, 
the Board stated:

    Designation of safety-class or safety-significant structures, 
systems, and components (SSCs), administrative controls, and 
engineered design features is determined through a prescribed 
methodology (DOE-STD-3009-94, [U.S. Department of Energy, 1994] and 
DOE G 420.1-2, [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 safety-class or 
safety-significant SSCs because they provide the most effective, 
automated, and quick response to a fire.'' (Report, p. 3-3) 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 safety-significant:
     Chemistry and Metallurgy Research Replacement Project, 
LANL.
     Device Assembly Facility, Nevada Test Site.
     Building 9212, Y-12 National Security Complex.
     Explosive Bays and Cells, Pantex Plant.
     Building 332, Lawrence Livermore National Laboratory.
     Highly Enriched Uranium Materials Facility, Y-12 National 
Security Complex.
     Uranium Processing Facility, Y-12 National Security 
Complex.
     K-Area Container Surveillance and Storage Capability, 
Savannah River Site.
    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 safety-class or 
safety-significant. This lack of guidance makes design of new 
facilities more difficult and time-consuming 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 safety-class or 
safety-significant 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, DOE-STD-1066-99, 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 420.1-1, Nonreactor 
Nuclear Safety Design Criteria and Explosives Safety Criteria, and DOE 
Guide 420.1-3, 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 safety-class and 
safety-significant fire protection systems.
    2. Use the revision of DOE-STD-1066-99, 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 safety-class 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 safety-class and safety-
significant fire protection systems.
    3. Identify design codes and standards for safety-class and safety-
significant fire protection systems and their components, and 
incorporate them into DOE Guide 420.1-1, 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. E8-2185 Filed 2-5-08; 8:45 am]
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