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7 February 2008
[Federal Register: February 6, 2008 (Volume 73, Number 25)]
[Notices]
[Page 6938-6939]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr06fe08-33]
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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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