Fire Protection Program
An
acceptable fire protection program includes those fire protection policies,
requirements, technical criteria, analyses, administrative procedures, systems
and hardware, apparatus and equipment, plans, and personnel that
comprehensively ensure that DOE objectives relating to fire safety are
achieved. Such a program should be characterized by a level of fire protection
sufficient to fulfill the requirements for the best protected class of
industrial risks ("Highly Protected Risk" or "Improved
Risk") and should have protection to provide "defense-in-depth."
This means that fire safety should be an integral part of all activities and
that facilities should be designed with both active and passive fire protection
features such that reliance will not be placed on only one means to ensure an
acceptable level of fire safety. This is also characterized by the
demonstration of a continuing, sincere interest on the part of management and
employees in minimizing losses from fire and related hazards and the
implementation of preventive features necessary to ensure the satisfaction of
objectives related to fire safety.
To
achieve this level of fire protection, site operations and facilities should
meet a minimum level of fire protection as further defined below.
An
acceptable fire protection program should meet the minimum requirements
established by the National Fire Protection Association (NFPA) and other
referenced fire safety criteria (or exceed them when necessary to meet fire
safety objectives), unless explicit relief has been granted by DOE.
Basic elements of an acceptable program include:
- A policy statement that incorporates the requirements of this Order, related DOE directives, and other applicable Federal, state and local fire protection requirements. The statement should affirm management's commitment to support a level of fire protection and fire suppression capability sufficient to minimize losses from fire and related hazards consistent with the best class of protected property in private industry.
- Comprehensive, written fire protection criteria that reflect additional site-specific aspects of the fire protection program, including: the organization, training and responsibilities of the fire protection staff; administrative aspects of the fire protection program; and requirements for the design, installation, operability , inspection, maintenance and testing of fire protection systems.
- Written fire safety procedures governing the use and storage of combustible, flammable, radioactive, and hazardous materials so as to minimize the risk from fire. Such procedures should also exist for fire protection system impairments and for activities such as smoking, hot work, safe operation of process equipment, and other fire prevention measures which contribute to the decrease in fire risk.
- A system to ensure that the requirements of the DOE fire protection program are documented and incorporated in the plans and specifications for all new facilities and for significant modifications of existing facilities. This includes a documented review by a qualified fire protection engineer of plans, specifications, procedures, and acceptance tests.
- Fire hazards analyses (FHA) for all nuclear facilities, significant new facilities and facilities that represent unique or significant fire safety risks. The FHA should be developed using a graded approach. The conclusions of the FHA should be incorporated in the Safety Analysis Report (SAR) Accident Analysis and should be integrated into design basis and beyond design basis accident conditions.
- Access to a qualified and trained fire protection staff, including a fire protection engineer(s), technicians and fire-fighting personnel to implement the requirements of this Order.
- A "baseline" needs assessment that establishes the minimum required capabilities of site fire-fighting forces. This includes minimum staffing, apparatus, facilities, equipment, training, fire pre-plans, off-site assistance requirements, and procedures. Information from this assessment should be incorporated into the site Emergency Plan.
- Written pre-fire strategies, plans, and standard operating procedures to enhance the effectiveness of site fire-fighting forces, where provided. Such procedures include those governing the use of fire-fighting water or other neutron-moderating materials to suppress fire within or adjacent to moderation controlled areas. Restrictions on the use of water should be fully justified on the basis of criticality safety.
- A comprehensive, documented fire protection self-assessment program, which includes all aspects (program and facility) of the fire protection program. Assessments should be performed on a regular basis at a frequency established by DOE.
- A program to identify, prioritize and monitor the status of fire protection-related appraisal findings/recommendations until final resolution is achieved. When final resolution will be significantly delayed, appropriate interim compensatory measures should be implemented to minimize the fire risk.
- A process for reviewing and recommending approval of fire safety "equivalencies" and "exemptions" to the DOE AHJ for fire safety.
- Access to a fully equipped, staffed and trained emergency response force that is capable of effectively responding to a fire and other emergencies in a timely manner.
Sources: DOE
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