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U.S.  Department of Energy
Washington, D.C. 20585					NOT MEASUREMENT SENSITIVE			   
										  DOE G 420.1-3
											   9-27-07
													


			   IMPLEMENTATION GUIDE FOR DOE
	    FIRE PROTECTION AND EMERGENCY SERVICES PROGRAMS
		 for Use with DOE O 420.1B, Facility Safety
						  
[This Guide describes suggested nonmandatory approaches for
meeting requirements.  Guides are not requirements documents and
are not construed as requirements in any audit or appraisal for
compliance with the parent Policy, Order, Notice, or Manual.]



					   FOREWORD
						  
This document replaces Department of Energy (DOE) G 440.1-5,
Implementation Guide for use with DOE Orders 420.1 and 440.1 Fire
Safety Program.

Comments should be sent to the Office of Nuclear Safety and
Environment within the Office of Health, Safety and Security,
phone 202-586-5680, or email jim.bisker@hq.doe.gov.

DOE implementation guides are part of the DOE Directives Program
and are issued to provide supplemental information regarding the
Department's expectations for fulfilling its requirements
as contained in rules, Orders, Notices, and regulatory standards.



			  
		   1.0	INTRODUCTION
						  
The purpose of this Guide is to facilitate implementation of
requirements in Department of Energy (DOE) Order (O) 420.1B,
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 Programs1
		
	  •	DOE G 450.1-4, Implementation Guide, Wildland Fire
		Management Program for Use with DOE O 450.1,
		Environmental Protection Program
		
	  •	DOE O 151.1C, Comprehensive Emergency Management System
		
	  •	DOE-STD-1066-99, Fire Protection Design Criteria
		
	  •	DOE-STD-1088-95, Fire Protection for Relocatable
		Structures
		
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/).



		   2.0	APPLICABILITY
						  
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.

This Guide applies to all Departmental Elements and Contractors
as delineated in DOE O 420.1B.  It provides an acceptable means
to implement the fire protection requirements detailed in Chapter
II and associated Attachment 2, Contractor Requirements Document
(CRD) of DOE O 420.1B.

Implementation of alternate or innovative fire safety
configurations and practices that will meet the requirements of
DOE O 420.1B and achieve a level of fire protection and emergency
response determined to be equal to that attained by conformance
with this Guide is allowed according to Sections 4c and 5b(5) of
DOE O 420.1B.

	
	
		    3.0	DEFINITIONS
						  
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 of the
conditions, safe boundaries, and hazard controls that provide the
basis for ensuring safety (10 CFR 830.3).

Emergency Services – The performance of activities pertaining to
the inherent responsibilities of 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
	
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 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) to
acceptable levels.

Pre-Incident 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.



		4.0   IMPLEMENTATION INSTRUCTIONS


DOE O 420.1B establishes facility and programmatic safety
requirements for a comprehensive fire protection program for DOE
sites, facilities, and emergency service organizations to
minimize:  (1) the potential for occurrence of a fire or related
event; (2) 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; (3) unacceptable interruption of vital DOE programs
as a result of fire and related hazards; (4) property loss from
fire exceeding limits established by DOE; and (5) fire damage to
critical process controls and safety systems structures and
components (as documented by appropriate safety analysis).

Comprehensive fire safety and emergency response programs at DOE
sites and facilities include, but are not limited to, appropriate
policies, requirements, technical criteria, analyses,
administrative procedures, and related documentation.  In
addition they feature adequately designed, installed and
maintained fire safety systems, hardware, structural features,
and related devices.  These programs include access to fully
capable emergency response forces featuring trained personnel and
an adequate inventory of apparatus and equipment that enable
these forces to respond in a timely and effective manner.  Where
the local emergency response capability is deemed insufficient,
appropriate compensatory measures are implemented to address
baseline needs.  The professional staff, general worker
population, and visiting public at these sites and facilities are
appropriately trained on the fire hazards and related conditions
that they are likely to encounter.

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 and should be implemented by qualified and
experienced fire safety professionals.  Where confusion exists as
to their intent or application, it is expected that the Authority
Having Jurisdiction2 (AHJ) be consulted.  This additional
guidance is referenced to the specific sections of the DOE O
420.1B where additional guidance was deemed warranted by DOE and
DOE contractor fire safety professionals.

4.1  Program Objectives
	
	Information in this section pertains to Section 1 of Chapter
	II in DOE O 420.1B (and the corresponding CRD Section in
	Attachment 2 of DOE O 420.1B).
	
	The following paragraphs describe in broad terms the
	approach to achieve the objectives of a DOE fire protection
	and emergency response program:
	
	1.	Contractors can achieve a comprehensive, multi-faceted
		emergency response capability in a number of ways.
		They can rely on an on-site emergency services
		organization, such as what currently exists at many DOE
		sites; or they can rely completely on off-site fire
		departments to meet DOE determined response objectives.

    		Contractors can also combine the capabilities of both
		on-site and off-site emergencies services organizations
		so as to assure the timely and effective response to
		the spectrum of emergency conditions (fires, medical
		emergencies, technical rescue, hazardous material
		response, etc.) that they may encounter (e.g. mutual
		aid agreements).
		
		a.	If an on-site fire department will be relied upon
			to provide complete emergency services, the full
			scope of its capabilities including: mission
			responsibilities, personnel, apparatus, equipment,
			facilities, programs, incident reporting, etc.
			should be delineated in a Baseline Needs
			Assessment (BNA) as further explained below.  The
			BNA should address compliance with the National
			Fire Protection Association (NFPA) codes and
			standards and other requirements that define the
			character of its mission and responsibilities.
			(This does not mean that the BNA has to be written
			to confirm code conformance on the basis of line-
			by-line comparisons.  A reasonable degree of
			documentation is expected.)  It should also
			address applicable contract provisions and aid
			agreements with other contractors on site as well
			as off-site organizations.  The goal is to capture
			in one document information that will confirm that
			the fire department is fully capable of meeting
			emergency response requirements and needs.  Note
			that there is a “model” BNA that can be downloaded
			and edited, available on the DOE fire protection
			website at
			http://www.hss.energy.doe.gov/nuclearsafety/nsea/f
			ire/models/models.html.

		b.	If a contractor will rely completely on (non-DOE)
			off-site emergency services organizations to
			satisfy the emergency response requirement, then
			the contractor should first define completely its
			emergency services needs against the services
			available by the off-site organization.  This can
			be done via a BNA or comparable document,
			commensurate with the off-site organization’s
			responsibilities.  This document should delineate
			what is required (capability), why is it required
			(hazards, accident potential, code requirements,
			etc), and how this capability is assured by the
			off-site emergency services organization.

		c.	If a contractor will rely on a combination of on-
			site and off-site emergency services
			organizations, the contractor should
			comprehensively demonstrate that an adequate
			emergency response capability exists on the basis
			of some combination of the efforts described in
			“a” and “b,” above.

	2.	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 fire
		protection systems, 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 required routine self-
		assessments with a corrective action program that
		facilitates the timely remediation of significant fire
		protection and emergency response deficiencies.  Such
		programs include appropriate notification, reporting,
		and tracking and trending of findings.
		
	3.	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.
		
4.2  Highly Protected Risk Status
	
	Information in this section pertains to Section 3a(1) of
	Chapter II in DOE O 420.1B (and the corresponding CRD
	section in Attachment 2 of DOE O 420.1B).
	
	Highly  Protected Risk (HPR) is a rating given  to  property
	that  qualifies for insurance coverage by the Factory Mutual
	System,  the Industrial Risk Insurers, and other  industrial
	insurance  companies that limit their insurance underwriting
	to the best-protected class of industrial risk.
	
	The requirement of the applicable building code and NFPA
	codes and standards are considered minimum levels of
	protection and do not necessarily meet the HPR status.  DOE
	facilities are expected to meet or exceed the applicable
	building code and NFPA codes and standards.  DOE facilities
	may also need to meet criteria in DOE-STD-1066-99 to
	minimize:  1) unacceptable onsite or offsite release of
	radiological or hazardous materials, 2) interruptions of
	vital programs and 3) property damage.  A means to achieve
	HPR status or the best-protected class of industrial risks
	includes compliance with insurance industry standards such
	as those published by the Factory Mutual Global (Loss
	Prevention Data Sheets and technical advisory bulletins).  A
	graded approach and experience in the application of
	insurance industry standards is necessary to determine the
	appropriate HPR provisions for a given facility or process.
	
4.3  Maintaining Safety Systems
	
	Information in this section pertains to Section 3a(2) of
	Chapter II in DOE O 420.1B (and the corresponding CRD
	section in Attachment 2 of DOE O 420.1B).
	
	Refer  to Section 4.21 of this Guide for information related
	to this topic.
	
4.4	Program Policy Statements
	
	Information in this section pertains to Section 3b(1) in
	Chapter II in DOE O 420.1B (and the corresponding CRD
	section in Attachment 2 of DOE O 420.1B).
	
	1.	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.”)
		
	2.	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 defined in DOE-STD-1066-
		99) as the subject matter expert (SME).  The AHJ may
		designate a contractor as the site’s Fire Marshall to
		act as his representative for day-to-day activities
		such as:  issuing of permits; reviewing and approving
		construction documents and shop drawings (new
		construction, modification, or renovation); approving
		routine fire protection equipment, materials,
		installation, and operational procedures (fire system
		inspection and testing), interpretation of building
		codes or standards; and other activities that would
		require formal approval.  Fire Marshall activities,
		inclusive of this authority, should be well documented
		and available for AHJ review.
		
4.5	Program Documentation
	
	Information in this section pertains to Section 3b(2) of
	Chapter II in DOE O 420.1B (and the corresponding CRD
	section in Attachment 2 of DOE O 420.1B).
	
	1.	The program should be completely documented.  This
		includes a description of applicable fire safety
		requirements in contracts and leases, where
		appropriate.
		
	2.	Documentation should also include a description of the
		fire protection organization and its roles and
		responsibilities in relation to other organizational
		entities.  It is preferable, although not always
		essential, to have all fire protection-related line
		activities under a single line manager to avoid
		unnecessary duplication and costs.
		
	3.	Training and qualification records of individuals
		having fire protection program responsibilities should
		be readily available and in an auditable form.
		
	4.	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.  The FHAs and
		facility assessment reports may be combined, provided
		that they address all essential elements as defined
		below.  The DOE Fire Protection Web Site contains
		copies of "models" of separate and combined FHAs and
		assessment reports.  Facility documentation should also
		include copies of any exemptions, equivalencies or
		deviations that have been approved by DOE.
		
	5.	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.	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 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.
		
	7.	Site fire departments and other related emergency
		response organizations (such as brigades or emergency
		squads) should maintain a current file with all
		standard operating procedures and fire pre-incident
		plans, firefighter training and certification programs,
		and appropriate documentation governing related
		activities.  The level of documentation should be
		reasonable and commensurate with the contractor’s
		responsibilities.  A program should be in place to
		ensure that this documentation is updated at
		appropriate intervals.  Pre-incident plans should be
		developed on the basis of NFPA 1620, Recommended
		Practice for Pre-Incident Planning, with input from the
		site fire protection engineering staff as well as
		emergency responders.
		
	8.	Emergency response records must conform to DOE
		reporting requirements in DOE O 231.1A, Environment,
		Safety,  and Health Reporting, and should be based on
		standard fire incident reporting practices, such as the
		National Fire Incident Reporting System (NFIRS) or NFPA
		901, Standard Classifications for Incident Reporting
		and Fire Protection Data, in lieu of state or site-
		specific reporting formats.
		
	9.	Computerized information management techniques for the
		creation, maintenance and dissemination of relevant
		documentation pertaining to the fire protection program
		are acceptable.
		
	10.	Access to classified matter during an emergency must be
		documented after the emergency and individuals who were
		provided access must complete nondisclosure forms as
		required by DOE Manual (M) 470.4-4, Information
		Security.
		
4.6	Fire Hazards Analyses
	
	Information in this section pertains to Section 3b(5) of
	Chapter II in DOE O 420.1B (and the corresponding CRD
	section in Attachment 2 of DOE O 420.1B).
	
	1.	A 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 facilities that store or
		process significant quantities of hazardous materials
		in excess of the allowances described in NFPA 1,
		Uniform Fire Code.  These examples include planned
		facilities as well as significant 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
		office buildings.
		
	2.	The purpose of an FHA is to conduct a comprehensive,
		qualitative assessment of the risk from fire within
		individual fire areas 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.  The scope and
		content of an FHA should be limited to only those
		issues that are significant and relevant to the
		facility.  To facilitate the development of graded fire
		hazards analyses, "model" FHAs have been developed.
		These models are located at the following URL:
		http://www.hss.energy.gov/nuclearsafety/nsea/fire//mode
		ls/models.html
		
	3.	Analysis of significant planned facilities included in
		the FHA process should begin early in the design phase
		to ensure that an acceptable level of protection is
		being incorporated in the evolving design.  This
		project or preliminary FHA should be updated whenever
		significant changes occur within an individual fire
		area and should form the basis for post-construction
		FHA included in the review and revision schedule per
		Chapter II, Section 3b(5)(b) and 3b(5)(c) of
		DOE O 420.1B.  The analysis shall also support the
		conclusions of a preliminary Documented Safety Analysis
		(DSA) where required.  In situations where the AHJ
		has determined that an FHA is necessary for
		a significant new facility that is not considered
		hazardous; then post-construction FHA reviews and
		revisions are not required.
		
	4.	In accordance with DOE O 420.1B, the FHA must be
		performed under the direction of a qualified fire
		protection engineer (Reference DOE-STD-1066-99 and DOE-
		STD-1137-2000, 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.
		
	5.	An FHA should contain, but not be limited to, a
		conservative assessment of the following fire safety
		issues:
		
	    •	Description of construction
	    •	Description of critical process equipment
	    •	Description of high-value property
	    •	Description of fire hazards
	    •	Description of operations
	    •	Potential for a toxic, biological and/or
		  radiological incident due to a fire
	    •	Natural hazards (earthquake, flood, wind, lightning,
		  and wildland fire) impact on fire safety
	    •	Damage potential:  Include both the Maximum Possible
		  Fire Loss (MPFL) as defined in DOE-STD-1066-99 and
		  the DSA of the design basis fire scenario
	    •	Fire protection features
	    •	Protection of essential safety class systems
	    •	Life safety considerations
	    •	Emergency planning
	    •	Fire Department/Brigade response
	    •	Recovery potential
	    •	Security and Safeguards considerations related to
		  fire protection
	    •	Exposure fire potential and the potential for fire
		  spread between two fire areas
	    •	Effect of significant fire safety deficiencies on
		  fire risk
	    •	Environmental impacts from a fire including
		  suppression system run-off considerations
	6.	The FHA should evaluate the consequences of a single,
		worst-case automatic fire protection system
		malfunction; i.e., a detection system that also
		activates a pre-action type sprinkler system, but fails
		to transmit an alarm to the site emergency response
		force.  This FHA evaluation may also include 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.
		
	7.	In determining the value of the MPFL, which is used in
		part to assess the need for fire protection systems,
		the basic assumption should be that there is no
		automatic or manual fire suppression.  This loss
		determination should include all direct and indirect
		costs associated with the fire and clean-up operations.
		In addition, there may be intangible costs such as
		mission interruption, erosion of public support, and
		local economic impact.  All of these may need to be
		considered to ensure that appropriate levels of fire
		protection are included in a facility.  Direct and
		indirect costs that should be included are:
		
		a.	Replacement cost of building and building  systems
			or contents within the fire area
		b.	Replacement cost of contents
		c.	Cost of lost time (considered mission interruption
			costs)
		d.	Cost of environmental clean-up
		e.	Exposure damage to other buildings, structures and
			property
		f.	Costs   for   re-establishing  operations;   e.g.,
			redesign approval and start-up
	8.	If redundant automatic fire protection systems are
		provided in the area, only the system that causes the
		most vulnerable condition is assumed to fail.  Passive
		fire protection features, such as blank fire-rated
		walls or continuous fire-rated cable wraps, are assumed
		to remain viable for their rated fire endurance period
		to the extent that they are properly constructed and
		maintained.
		
	9.	The focus of the FHA 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.  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 fire-rated
		construction, the fire area should be defined by the
		exterior walls and roof of the facility.
		
	10.  An important element of an acceptable FHA for nuclear
		facilities is an inventory of all safety class and
		safety significant systems within the fire area that
		are susceptible to fire damage.  This includes those
		primary and supporting mechanical and electrical
		systems that must function effectively during and after
		a fire event to ensure safety.  For example, loss of
		the building ventilation system in a fire (due to
		damage of power cables) may result in an ambient air
		temperature rise, which may cause the failure of
		sensitive electrical components, such as relays.  Such
		safety systems may include, but are not limited to,
		process monitoring instrumentation, instrument air,
		hydraulic systems, and emergency lighting systems.
		
	11.  All credible fire-related failure modes of safety
		systems should be considered.  For example, it is
		insufficient to assume that fire will merely cause the
		loss of function of safety equipment when power cables
		to that equipment are within the fire area.  It is also
		necessary to consider the potential for spurious
		signals that may cause the inadvertent operation of
		such equipment.  Similarly, fire-induced electrical
		faults may trip upstream electrical disconnect devices
		in such a way as to render inoperable other safety
		systems that may not even be located within the fire
		area.  In addition, the effects of combustion products,
		manual fire-fighting efforts, and the activation of
		automatic fire suppression systems should be assessed.
		
	12.  Fire propagation and the potential for fire-induced
		radiological dispersal through the facility should be
		considered.  These effects should be considered for the
		normal operating mode of the air distribution system as
		well as alternate modes, such as shutdown, that may
		result from the fire.
		
	13.  A tool that may be used in the development of an FHA is
		a fire model, such as those developed by the National
		Institute of Standards and Technology, as applied by
		qualified fire protection engineers, and approved for
		DOE use as a Toolbox code.  This includes the CFAST
		Fire Model and other models in the following web site:
		http://www.hss.energy.gov/csa/csp/sqa/.  All
		assumptions used in a model should be listed in the FHA
		and limiting conditions of operation or specific
		administrative controls established to assure that
		these assumptions produce reasonably conservative
		results compared to applicable codes and standards.
		Also note that small variations in an assumption can
		have a major impact on the outcome.  For example,
		assuming a door is closed can reduce fire intensity by
		half, but there is no assurance that the door will
		remain closed throughout the life of the facility.
		Because of their potential errors, model results should
		be approved by a qualified fire protection engineer who
		is knowledgeable on the use of the model.
		
	14.  Additionally, FHA analysis may include reliance on
		actual fire testing or historical data on fire events
		both inside and outside the DOE Complex, provided that
		adequate documentation of such information is available
		for the AHJ’s review.  Alternately, an assumption can
		be made that all potentially vulnerable systems will be
		damaged within the fire area.  Acceptable exceptions to
		this assumption are water-filled steel pipes, tanks,
		and similar components of adequate structural integrity
		with welded fittings and adequate pressure relief.
		
	15.  The quantity and associated hazards of flammable and
		combustible materials that are often found within the
		fire area should be factored into the analyses.
		Consideration should also be given to the presence of
		transient combustibles associated with storage and
		maintenance activities.  Where a facility is fully
		protected as required by directives and prescriptive
		codes and standards, combustibles can usually be
		characterized in general terms and limited through
		normal housekeeping programs.  However, when conditions
		prevent employment of normal fire protection features
		such as automatic sprinklers, noncombustible
		construction, and fire resistant boundaries, the FHA
		should quantify fixed combustibles and their locations
		and determine limits and locations of transient
		combustibles.  These limits are usually enforced
		through formal combustible loading programs with
		permits for each combustible material brought into the
		area.  Averaging combustible loading as a means to
		characterize the fire severity is not considered an
		acceptable technique over localized combustible
		loading.
		
	16.  FHAs for high-bay locations should consider the effects
		of smoke/hot gas stratification that may occur at some
		intermediate point below the roof or ceiling as well as
		the potential for delayed sprinkler response.
		Similarly, the effect of smoke movement through doors
		and dampers held open by fusible links should be
		addressed.
		
4.7	FHA Incorporation
	
	Information in this section pertains to Section 3b(6) of
	Chapter II in DOE O 420.1B (and the corresponding CRD
	section in Attachment 2 of DOE O 420.1B).
	
	1.	The FHA, including all assumptions, should be
		documented.  When both an FHA and a DSA are developed
		for a facility, the developmental effort should be
		coordinated to the maximum extent possible to avoid
		duplication of effort.  It is recognized, however, that
		because an FHA is based on the premise that a fire will
		occur and considers fire safety issues (property loss
		and program discontinuity potential) that are not
		normally considered in the DSA, the conclusions of the
		FHA may be more conservative than would normally be
		developed by a DSA alone.  Nevertheless, the FHA and
		its conclusions should be addressed in the facility DSA
		in such a manner as to reflect all relevant fire safety
		objectives as defined in Chapter II, Section 1 of DOE O
		420.1B.
		
	2.	Information related to emergency response (number of
		emergency responders, number and types of apparatus,
		response time, etc.) should be incorporated into the
		DSA as a means of clearly establishing a “floor” below
		which this level of capability should not be reduced.
		
4.8	Personnel
	
	Information in this section pertains to Section 3b(7) of
	Chapter II in DOE O 420.1B (and the corresponding CRD
	section in Attachment 2 of DOE O 420.1B).
	
	1.	A sufficient number of qualified fire safety
		professionals (fire protection engineers, fire
		department management personnel and technicians) should
		be on staff to develop, implement and maintain the fire
		protection and emergency response program.  Staffing
		levels should be based on a BNA, "work load analysis"
		or similar analysis that provides a technical basis for
		the fire safety staff.  In those instances where a site
		is of insufficient size to warrant a fire protection
		staff or emergency response force, such capability
		should be achieved by other means, such as reliance on
		off-site fire departments or fire brigades and fire
		protection engineering support contractors.
		
	2.	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.)
		
	3.	Sites should provide appropriate support personnel for
		escort or oversight responsibilities when using off-
		site fire departments, brigades and fire protection
		engineering support contractors who need to gain access
		to areas with classified material.
		
	4.	An appropriate level of individualized safety and
		health training is expected to be provided to all
		workers 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.
		
	5.	All DOE Federal and contractor employees should be
		provided with a basic level of fire safety 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.)
		
	6.	Members of the public, including visiting students and
		scientists, should be provided with suitable
		orientation on the fire hazards (if any) that they may
		encounter while on site and the appropriate personal
		response if they should find themselves in an emergency
		situation.
		
4.9	Baseline Needs Assessment
	
	Information in this section pertains to Section 3b(8) of
	Chapter II in DOE O 420.1B (and the corresponding CRD
	section in Attachment 2 of DOE O 420.1B).
	
	1.	DOE site emergency services organizations are
		considered to be career fire departments in the
		application of NFPA Standards including the Standard
		for the Organization and Deployment of Fire Suppression
		Operations, Emergency Medical Operations, and Special
		Operations to the Public by Career Fire Departments
		(NFPA 1710).  Additionally, such organizations are
		expected to meet the DOE O 420.1B requirement for the
		completion of a BNA.  In developing the BNA, the intent
		is that this be a coordinated effort involving the AHJ
		and the representatives of the site emergency services
		organization.  Additional expertise in unique emergency
		response or fire prevention issues, legal matters,
		labor-related issues, emergency medical protocols,
		etc., may be required to assist in the development of
		the BNA.
		
	2.	A BNA is required for each site that maintains a
		staffed fire department or fire brigade.  A BNA or an
		evaluation in documented form of comparable scope is to
		be developed by contractors at sites where emergency
		response is achieved by a capability other than a site
		fire department or brigade.  The intent is to define,
		for all sites, the minimum capability to achieve a
		timely and effective response to fires and related
		events.
		
	3.	The BNA should be based on conformance with applicable
		NFPA standards, promulgated by the NFPA, as well as
		supplementary requirements and guidance developed by
		DOE.  It should include organizational
		responsibilities, collateral duties, facility hazards,
		response time requirements, personnel levels, required
		apparatus and equipment.  In addition, the document
		should describe the organization's various programs
		that support its personnel.  This should include
		training, physical fitness, and medical programs
		relating to emergency responders.
		
	4.	In developing a comprehensive needs assessment, the
		basic assumption should be that there is only one
		emergency incident (such as a fire) occurring on site,
		with a casualty requiring emergency medical assistance.
		However, the document should also describe how the fire
		department would respond if a second incident occurred
		while the first was underway.  The second response
		capability could be based on documented mutual aid
		agreements and utilization of some percentage of off-
		duty personnel overtime.  To the extent that an
		insufficient response capability is determined to exist
		for this second emergency, the BNA should address the
		required supplemental emergency response resources that
		would be needed to respond to this event.
		
	5.	A critical factor in any such analysis is the minimum
		response time necessary to begin active intervention
		(fire suppression, emergency medical, technical rescue,
		etc.) activities.  The determination of a minimally
		acceptable response time should be based on risk and
		should reflect categories, such as alarm, call
		processing, dispatch, response, and turnout times that
		have been established in NFPA 1710.  DOE expects that
		the response time requirements of NFPA 1710 be the
		starting point in the determination.  Site specific
		conditions, such as the widespread installation of
		automatic fire suppression systems, could be used to
		extend response time to structural fires through the
		NFPA 1710 accepted equivalency process.  Similarly, the
		provision of localized Automated External
		Defibrillators (AEDs) and first-aid supplies, along
		with appropriate employee training, could be used, in
		part, as a basis for extending Emergency Medical
		Service response times.
		
	6.	The minimum number of trained firefighters necessary to
		begin interior structural fire-fighting should be five,
		in line with the longstanding DOE guidelines on NFPA
		1500 implementation.  (It is recognized that, where
		lives may be at risk, the Incident Commander has the
		authority and responsibility to initiate rescue with
		less than this minimum if, in his judgment, it is safe
		to do so, for instance, in properties fully protected
		by automatic sprinkler systems.)  Additional emergency
		response personnel will be necessary where multiple
		hose lines are required to suppress a fire and to
		support other fire ground activities such as search and
		rescue.
		
		a.	The minimum number of personnel required for
			exterior fire fighting, hazardous material
			incidents, specialized rescue or other related
			events should be based on DOE fire protection
			guidelines, pre-incident fire planning where
			possible, and the judgment of trained and
			experienced  Incident Commanders.
			
		b.	When no site fire department or brigade exists and
			when reliance will be placed on off-site fire
			departments, a plan should be developed that
			details how such forces will be expected to
			respond in conjunction with the site emergency
			plan and how appropriate training and site
			familiarization will be provided to ensure that
			the off-site fire departments will be prepared for
			fires that occur on site.  Appropriate drills
			should be performed periodically to verify the
			effectiveness of the plan.
			
		c.	Training of emergency responders may be based on
			existing requirements such as those used by the
			state in which the site is located, those
			delineated in 29 CFR Parts 1910 and 19263, as well
			as criteria developed by the NFPA.  In addition,
			emergency responders should be provided with
			sufficient site-specific training and
			familiarization necessary to effectively respond
			to the unique conditions that characterize DOE
			facilities.  As part of this effort, regular
			facility tours should be conducted utilizing
			current pre-incident fire plans as well as to
			verify that plans are accurate.
			
		d.	Drills and exercises should be structured to
			emphasize realistic scenarios and feature standard
			fire department tactical evolutions.  Such drills
			should also be scheduled, as appropriate, during
			weekends and evening shifts when normal activities
			are reduced.
			
	7.	Emergency radio communication should be compatible with
		other organizations involved with emergency response
		and should be designed to be effective in areas subject
		to structural interference.
		
	8.	Fire department apparatus should reflect all site-
		specific response requirements, including those
		described in the first paragraph above.  Other examples
		include hazardous material response, heavy rescue,
		rough terrain rescue, chemical or large flammable
		liquid spills, and wildland fire response.  Reserve
		apparatus, if utilized, should be properly maintained
		and equipped to provide its intended response
		capabilities whenever first-line apparatus is out-of-
		service.  Periodic replacement programs for apparatus
		should be structured to avoid excessive "down time" and
		repair costs and should reflect the industry norm of
		useful life cycles (e.g., 20 years).
		
	9.	DOE Site fire stations, where provided, should be
		designed to provide sufficient capacity for mobile
		apparatus, including maintenance functions.  Living
		quarters should provide a comfortable, private and safe
		environment for personnel, consistent with state or
		NFPA requirements.  This includes adequate sleeping
		quarters where necessary (when personnel are working
		more than a 12-hour shift), kitchen facilities,
		training rooms, physical fitness areas, and other
		ancillary needs.  To the extent that related
		occupancies such as alarm rooms, maintenance rooms, and
		personnel areas are co-located within the same
		facility, appropriate fire-rated physical separation,
		ventilation and exhaust, and other fire protection
		features should be provided to prevent interference and
		to ensure the viability of individual areas in the
		event of a fire.  All sleeping quarters should also be
		protected with automatic sprinklers (quick response),
		smoke detection and carbon monoxide (CO) detection that
		are connected to transmit alarms locally and to the
		site central reporting location.
		
	10.  Fire stations should be "centrally" located to the
		facilities protected so as to minimize response time.
		Station location should also reflect prevailing traffic
		patterns, climatic conditions, railroad tracks and
		other sources of delay.
		
	11.  Consistent with the training needs identified above,
		adequate facilities should be provided for training.
		This includes "live fire" training, confined space
		entry, vehicle extrication, hazardous material
		response, and other site-specific conditions.  Where on-
		site training facilities are unavailable, arrangements
		should be made for appropriate training for fire
		department personnel off-site.
		
4.10	BNA Incorporation
	
	Information in this section pertains to Section 3b(9) of
	Chapter II in DOE O 420.1B (and the corresponding CRD
	section in Attachment 2 of DOE O 420.1B).
	
	Information related to the site emergency services
	organization, such as the number of emergency responders,
	number and types of apparatus, response time, etc. should be
	incorporated into the site emergency plans, FHAs, and DSAs,
	as appropriate, to clearly establish a “floor” below, which
	this level of capability should not be reduced without
	appropriate compensating safeguards and/or the restriction
	of hazardous operations.  This information can be inserted
	in summary fashion or the BNA can be incorporated directly
	into the above-referenced documents.
	
4.11	Pre-Incident Fire Activities
	
	Information in this section pertains to Section 3b(10) of
	Chapter II in DOE O 420.1B (and the corresponding CRD
	section in Attachment 2 of DOE O 420.1B).
	
	It is expected that pre-incident fire plan documents (or
	comparable software) be developed in accordance with
	standard practices within the emergency services community,
	applicable NFPA standards, and DOE expectations, as
	reflected in published guidelines.  For additional
	information and to access “model” documents that can be
	downloaded and edited, refer to the DOE fire protection web
	site at
	http://www.hss.energy.gov/nuclearsafety/nsea/fire//models/mo
	dels.html
	
4.12	Unique Fire-fighting Activities
	
	Information in this section pertains to Section 3b(11) of
	Chapter II in DOE O 420.1B (and the corresponding CRD
	section in Attachment 2 of DOE O 420.1B).
	
	Procedures on unique fire-fighting activities can be
	developed and maintained in conjunction with efforts
	governing fire department procedures in general.  DOE and
	contractor management should be kept routinely informed if
	fire department emergency operations for these special
	circumstances represent deviations from the norm.  FHAs
	and DSAs should reflect unique fire fighting strategies
	where rapid intervention may not be possible (moderation
	controlled areas) and where fixed fire protection systems
	may no longer be applicable, e.g., certain transitional
	facilities (See Section 4.16 for further information).
	
4.13	Assessments
	
	Information in this section pertains to Section 3b(13) of
	Chapter II in DOE O 420.1B (and the corresponding CRD
	section as well as Section 3b(14) in Attachment 2 of DOE O
	420.1B).
	
	1.	The principal objective of a fire safety assessment is
		to identify deficiencies that would prevent the
		achievement of DOE's fire safety policy objectives.
		
	2.	Facility and programmatic assessments should be
		performed under the supervision of a qualified fire
		protection engineer as defined by DOE.  Personnel
		conducting such assessments should have an appropriate
		level of knowledge and experience in the application of
		fire safety codes and standards to diverse facilities.
		Assessments should, as a minimum, encompass the
		following elements of the fire protection program:
		
		a.	Program Related (performed by both DOE and
			contractors):
			
			•	Comprehensiveness of the fire protection
			  program
			  
			•	Procedures for engineering design and review
			  
			•	Procedures for maintenance, testing, and
			  inspection of installed fire protection systems
			  and features
			  
			•	Fire protection engineering staff (number,
			  qualifications, training)
			  
			•	Emergency Services Organizations including the
			  BNAs
			  
			•	Management support
			  
			•	Exemptions and documented equivalencies or
			  deviations
			  
		b.	Facility Related (principally, but not exclusively
			contractor self-assessments and DOE operational
			readiness reviews):
			
			•	Fire protection of safety class and safety
			  significant equipment
			  
			•	Life safety considerations
			  
			•	Fire protection of vital programs
			  
			•	Fire protection of high-value property
			  
			•	Fire suppression equipment
			  
			•	Water runoff
			  
			•	Facility fire prevention planning documents
			  (evacuation plan/fire wardens extinguisher
			  training)
			  
			•	Fire apparatus accessibility
			  
			•	Completeness of fire hazards analyses
			  
			•	Fire barrier integrity
			  
			•	Completeness of fire loss potential (MPFL)
			  determinations
			  
			•	Fire safety training
			  
			•	Potential for toxic, biological and /or
			  radiological incident due to fire
			  
		c.	Combined Aspects (Program and Facility):
			
			•	Conformance with applicable Orders, codes and
			  standards
			  
			•	Inspection, testing, and maintenance reports
			  
			•	Adequacy of facility appraisal reports
			  
			•	Tests, inspections, procedures, and records for
			  maintaining fire protection systems and
			  features
			  
			•	Administrative controls
			  
			•	Temporary protection and compensatory measures
			  
	3.	The frequency of assessments should be as follows:
		
		a.	Annual fire protection assessments should be made
			of facilities valued in excess of $100 million,
			facilities considered a high hazard, or those in
			which vital programs are involved as defined by
			DOE.
			
		b.	Remaining facilities should be assessed at least
			every three years or at frequencies determined by
			the AHJ.  (Note:  Low and ordinary hazard facility
			assessments in adjacent areas may be combined.)
			
		c.	Comprehensive assessments of fire protection
			program elements by DOE and by contractors should
			be made every three years.  (These should be
			staggered in anticipation of contractor-initiated
			enhancements.)
			
	4.	Assessment reports should include a description of what
		was accomplished during the effort (areas toured,
		documents reviewed, and people interviewed).  It should
		feature a "baseline" description of the facility,
		hazards and other occupancy considerations, and fire
		protection features.  In addition, the report should
		document changes of significance that have occurred
		within the facility since the last assessment that
		affect fire safety, and it should list all noted
		deficiencies, along with a recommendation for
		remediation and interim compensatory measures, if
		necessary, pending resolution.  A "model" assessment
		report is available at the following web site:
		http://www.hss.energy.gov/nuclearsafety/nsea/fire//mode
		ls/models.html.
		
	5.	DOE self-assessments and assessments of contractors are
		intended to confirm that comprehensive fire protection
		programs are in place site-wide.  They should include a
		select review of facility and site fire protection
		features, fire safety policies and procedures, the
		qualifications of contractor fire safety professionals,
		the adequacy of self-assessments, fire hazards
		analyses, and program performance as detailed in this
		guidance and other DOE Orders/ Manuals such as
		DOE O 226.1, Implementation of DOE Oversight Policy,
		and Table F-2 (Program Performance Measures) of DOE M
		231.1-1A, Environment, Safety and Health Reporting
		Manual.
		
	6.	Additionally, it is expected that DOE assessments
		include the capabilities to respond in a timely and
		effective manner to site fire emergencies and related
		events.  This assessment responsibility extends to
		contractors where there is no site fire department or
		brigade and where effective emergency response is
		predicated on other resources, such as occupant
		emergency organizations and offsite fire departments.
		In other words, the heads of field elements should
		determine the adequacy of the emergency response
		capability at all of the sites for which they have
		responsibility.
		
4.14	Corrective Action Processes
	
	Information in this section pertains to Section 3b(14) of
	Chapter II in DOE O 420.1B (and CRD Section 3b(15) in
	Attachment 2 of DOE O 420.1B).
	
	1.	It is expected that the corrective action process will
		encompass all fire protection "findings"; i.e., all
		issues requiring action, e.g., facility, program, and
		emergency response.  When modifications that are
		necessary to correct significant fire safety
		deficiencies will be delayed beyond one week, it is
		expected that interim compensatory measures (such as
		fire watchers) be adopted until the modifications are
		complete.  Compensatory measures should be initiated
		without delay commensurate with the finding and at the
		discretion of the AHJ.
		
	2.	Significant findings (life threatening or with a
		serious injury potential) from these assessments will
		be the basis, in part, for contractor entries into the
		Noncompliance Tracking System that is a component of
		the enforcement process required through 10 CFR Part
		851.
		
4.15	Exemptions Variances & Equivalencies (Approved Requirement
	Relief)
	
	Information in this section pertains to Section 3b(15) of
	Chapter II in DOE O 420.1B (and CRD Section 3b(16) in
	Attachment 2 of DOE O 420.1B).
	
	The DOE directives system and the requirements of 10 CFR
	Part 851 impose a range of explicit direction in the
	development, review, and approval of exemptions, variances
	and equivalencies as delineated below.  Contractors are
	advised to consult with the AHJ before proceeding with a
	request for relief.  One goal is to avoid unnecessary
	duplication of effort and the generation of unnecessary
	paperwork.
	
	1.	DOE  M 251.1-1B, Departmental Directives Program
		Manual, states:
		
			If the Order, Notice, or Manual includes specific
			provisions for exemptions, equivalencies, or other
			forms of relief from the requirements in the
			document, then those provisions must be applied.
			If the document does not include specific
			provisions for relief, the process in this chapter
			[of DOE M 251.1-1B] applies to granting permanent
			or temporary relief from the applicable
			requirements in those documents.
			
		With respect to exemptions to the provisions of DOE O
		420.1B, paragraph 6a of that Order states:
		
			Exemptions to this Order (DOE O 420.1B) must
			follow the process defined for exemptions in DOE M
			251.1-1B, Departmental Directives Program Manual,
			except for the approval authority defined in the
			responsibilities paragraphs of this Order.
			
		DOE O 420.1B assigns the authority to grant exemptions
		to the provisions of DOE O 420.1B to the Secretarial
		Officer, unless delegated.  Furthermore, a granted
		exemption to DOE O 420.1B is not considered an
		exemption from all other DOE directives or statutory
		requirements, such as 10CFR 851, that may be affected
		by such relief.  Please refer to the DOE directive or
		statutory requirements for information on exemption
		processing of the affected document.
		
		With respect to requests for relief from NFPA Code
		provisions, paragraph 6b of DOE O 420.1B states:
		
			Exemptions, exclusions, and equivalencies to
			standards or other documents referenced in this
			Order should follow the provisions explicitly set
			forth in those documents; for example: the
			equivalency, alternative, and modification
			provisions in the NFPA Code.
			
		Paragraph 5d(10) of DOE O 420.1B assigns the AHJ
		responsibility, and therefore the authority to approve
		equivalency decisions in accordance with those
		provisions, to the head of field elements with a
		notation to ensure that fire protection SME comments
		are addressed.
		
	2.	The process for requesting and approving variances from
		the provisions of 10 CFR Part 851 are delineated in the
		Rule and in supplemental guidance promulgated by DOE.
		Consult the following web site for this information:
		http://www.hss.energy.gov/HealthSafety/wshp/rule851/851
		final.html
		
	3.	Most codes and standards of the NFPA are silent on
		exemptions to their requirements but allow for an
		equivalent or alternate means of achieving compliance
		with the code or standard.  Where no equivalent or
		alternate means for achieving compliance is provided,
		noncompliance to an applicable NFPA code or standard
		should be processed as an exemption to DOE O 420.1B
		according to the provisions in DOE O 420.1B for
		exemptions to that Order, including the referenced
		provisions in DOE M 251.1-1B.
		
	4.	Documented requests for relief should be developed by a
		qualified fire protection engineer or certified fire
		department officer and submitted through the AHJ to the
		appropriate reviewing authority.  Documented approvals
		should be kept on file in an auditable form.  Multiple
		conditions that can be resolved on the basis of such
		relief can be grouped by individual code or standard,
		provided that the specific conditions are explicitly
		identified.
		
	5.	The level of documentation necessary to support a
		request for relief will vary depending on the issue.
		As a minimum, each request should identify the specific
		site location or condition at issue and the
		paragraph/section of the code or standard which
		addresses the issue; discuss why the requirements of
		the code or standard that cannot or should not be met;
		and justify the conclusion that the alternate
		configuration is acceptable from a safety,
		environmental, property damage, or program continuity
		perspective to what is stipulated in the code or
		standard.  All functions should also be addressed.  For
		example, an automatic sprinkler system provides
		detection, local alarms, fire department notification,
		and fire suppression.  The description of alternatives
		in an equivalency should address each of these
		functions.  Additionally, relief under one source
		document is not considered relief from another.  All
		codes and standards with similar requirements should be
		identified and any differences addressed accordingly.
		For example, sprinklers may be required for life safety
		by NFPA 101 and for nuclear safety by NFPA 801.
		
	6.	When a positive determination is made in support of
		relief, then documentation should include signatures of
		all those involved in the decision, including that of
		the cognizant DOE fire protection engineer.
		
	7.	A change in use or occupancy will require the re-
		evaluation and approval of all documented requests for
		relief within the structure to assure that these are
		valid under the building’s new use or occupancy.
		
	8.	Regarding FHAs, all approved variances and exemptions
		to DOE directives and/or equivalencies should be
		provided or referenced within the FHA document itself
		along with all supporting information.  Documentation
		related to approved relief should be reviewed during
		the FHA update to verify that conditions have not
		changed and the justifications are still valid.
		Additionally, such considerations may have other
		conditions for review according to a specified
		schedule, which should also be documented in the FHA.
		If there is no FHA for the facility, appropriate
		reviews and documentation should be consolidated and
		maintained with the fire protection staff for review by
		the AHJ or representative.
		
	9.	Regarding BNAs, those responsible for managing site
		fire protection emergency service programs may decide
		to request relief from the provisions of NFPA and
		similar industry standards, provided that the NFPA or
		industry standards allows the use of an alternative
		approach and the proposed alternative achieves an
		equivalent level of safety.  Appropriate documentation
		that justifies the alternative should be submitted to
		the AHJ for review and approval prior to the
		implementation of the alternate.  If such relief
		relates to the site’s emergency services program, then
		such documentation should be included within the BNA
		discussed in Section 4.9 of this Guide.
		
4.16	Transitional Facilities
	
	Information in this section pertains to Section 3b(16) of
	Chapter II in DOE O 420.1B (and CRD Section 3b(17) in
	Attachment 2 of DOE O 420.1B).
	
	1.	Transitional facilities are those that have been placed
		in a safe-shutdown condition and abandoned, or are
		undergoing decontamination and decommissioning (D&D)
		work and ultimately demolition or abandonment.
		The need for fire protection features in these
		structures is governed by the consequences of a fire to
		the public, workers, and fire fighters as well as the
		potential release of hazardous and radiological
		materials while the facility is in the transition
		process.  Since property protection and program
		continuity are not always factors to consider in a
		transitional facility, all fire protection requirements
		may not be appropriate.  Factors, which should be
		considered, center on the transition itself, such as
		fire protection equipment removal, and the impact that
		this transition has upon fire protection features and
		activities.  Such factors are additionally important if
		the facility possesses a definable value and/or mission
		as determined by the DOE program office; or, if a fire
		would significantly increase the cost of the D&D
		process, such as destroy vital equipment required for
		D&D activities, delay transition commitments, or
		undermine public confidence.
		
	2.	Fire safety and emergency response for transitional
		facilities are governed by the requirements contained
		in 10 CFR Part 851 (including 29 CFR Part 1926) and the
		provisions of NFPA Standard 241, Safeguarding
		Construction, Alteration and Demolition Operations.
		(See also Factory Mutual Data Sheet 1-0 Safeguards
		During Construction, and Chapter 8 of  NFPA 801, Fire
		Protection for Facilities Handling Radioactive.)
		
	3.	Decisions relating to fire safety of such facilities
		should be made on the basis of the following
		principles:
		
		a.	The evaluation of fire risks imposed by the work
			in relation to the need for traditional fire
			safety features.  This can be accomplished through
			a graded transitional facility fire hazard
			analysis or assessment (TFHA) that has been
			reviewed and concurred with by the AHJ.  Approved
			relief from normal DOE requirements should be
			listed on the signature page.  All requests for
			relief should be processed in accordance with DOE
			procedures.  The facility’s fire protection
			assessment or FHA may be utilized where applicable
			to complete this evaluation.
			
		b.	Fire hazards within these facilities may change
			over time, such as an increase in combustible
			loading during abatement activities.  Fire
			protection should be adequate to deal with these
			changes.  The TFHA together with updated pre-
			incident plans should account for this either
			through a phasing schedule, or be revised as
			appropriate when significant changes in occupancy
			or hazard occur that affect fire safety.
			
		c.	Fire safety features that have originally been
			required by DOE may be rendered inoperable or
			considered no longer needed if justified by the
			TFHA on the basis that the safety of D&D workers
			and emergency responders will not be compromised.
			Such features may be abandoned in place (and
			properly identified as being out of service) until
			they are dismantled as part of planned demolition
			activities.
			
		d.	The decision to deactivate automatic fire
			suppression systems in large facilities should
			reflect the possibility that the fire department
			may not be able to safely enter the facility to
			effect manual fire suppression.  A defensive
			tactical approach, which features exterior fire
			attack and protection of exposures, should be a
			part of the BNA described in Section 4.9 of this
			Guide and written into the fire department’s
			updated pre-incident plan.  Such approach
			necessitates additional emphasis on maintaining
			communication and cooperation between facility
			personnel and the fire department so that
			emergency responders are aware of changes in
			occupancy and fire protection system status.
			
		e.	Retained fire protection features in these
			facilities are not required to comply with all of
			the design and installation criteria of the
			governing NFPA standard if the AHJ concurs that
			the system will function adequately during a fire
			in its current design mode.  The AHJ concurrence
			should be documented in accordance with site
			procedures.
			
		f.	Retained fire protection features should be
			inspected, tested and maintained to ensure that
			the features will function adequately during fire
			incidents, based on the mission of the facility.
			
		g.	Transitional facilities should be routinely
			inspected and reviewed by representatives of the
			fire department and fire protection engineering
			staffs consistent with established standard
			operating procedures and fire protection program
			criteria.  Tours of facilities should also be
			conducted by the fire department to familiarize
			them with existing conditions and to revalidate
			pre-incident plans.  Drills and training exercises
			should also be conducted at these locations at an
			appropriate frequency commensurate with the fire
			risks and complexity of the facility.
			
		h.	Prior to commencement of work activities in a
			facility, appropriate procedures should be
			approved and implemented (including worker
			training) governing the control of potentially
			hazardous operations including, but not limited
			to, cutting and welding, storage and handling of
			flammable or combustible liquids, transient
			combustibles, and sources of ignition such as
			temporary wiring and heating equipment.  Smoking
			areas, when allowed on the premises, should also
			be established.
			
		i.	The fire risks associated with materials and
			processes used as part of the transition process
			should be evaluated by a fire protection engineer.
			Fire protection features should be adequate to
			limit these risks to an acceptable level.
			
		j.	The deactivation of process lines containing
			hazardous materials as well as flammable or
			combustible liquids should be preceded by an
			analysis or performed under a work plan that
			addresses the methods used to control related
			hazards during the deactivation process.
			Appropriate safeguards need to be in place to
			control and minimize the release of residual
			materials that may remain in piping and tanks.
			
		k.	Safeguards to assure D&D worker and emergency
			responder safety and health are expected to
			conform to the requirements in 10 CFR Part 851,
			and the requirements for buildings under
			construction or demolition, as provided in NFPA
			241, Standard for Safeguarding Construction,
			Alteration, and Demolition Operations,  unless
			relief has been granted by the AHJ.  In buildings
			where regular tours and inspections are conducted,
			adequate exits and lighting must be provided as a
			minimum as required by NFPA 101.  Compensatory
			measures should be established whenever routine
			surveillance is being performed in these
			facilities.  These measures should be approved by
			the site fire authority.  Locked and abandoned
			facilities where there is no human occupancy do
			not need to maintain emergency egress features.
			
		l.	Where no automatic system exists, an effective
			means for manually summoning the fire department
			and for communicating with personnel inside of a
			building is required.  This can take the form of
			an exterior fire alarm pull station or call box,
			telephone (fixed or mobile), radio or some
			combination of the above based on the
			accessibility of the devices to all personnel and
			their reliability.  However, in accordance with
			NFPA 101, all egress features must be reviewed
			once the facility is reopened for actual
			demolition activities.  Stairwells should be
			inspected on a routine basis and maintained
			accessible, clear and dry in the event
			firefighting activities are required.
			
		m.	All retained interior fire protection systems
			should be maintained operational to the extent
			possible while interior work activities are taking
			place.  The sequence of removal of these systems
			should be clearly spelled out in contractor
			requirement documents and the TFHA.  Verification
			of operable status should include appropriate
			inspection and testing in accordance with
			established procedures.  Sprinkler systems should
			be retained until all fixed and transient
			combustible materials have been removed.  Wet
			sprinkler systems may be converted to dry systems
			to minimize heating needs.  Any temporary
			deactivation of fire protection features during
			transition operations should be treated as an
			impairment, with appropriate interim compensatory
			measures implemented until the feature is returned
			to full operational mode pending final demolition.
			
		n.	The site and facility fire water distribution
			system, including hydrants, fire department
			connections, and interior standpipe systems,
			should be maintained in an operable mode.  Access
			for mobile apparatus for emergency response should
			be maintained and verified on a frequent basis.
			(Refer to fire department pre-incident fire
			plans.)
			
		o.	To the extent that the TFHA validates the need to
			maintain fire protection features during
			transition activities, such features should be
			inspected, tested and maintained, consistent with
			established procedures, sufficient to ensure that
			they will function effectively during a fire,
			based on their intent during transition.  This
			implies that defects or design deficiencies that
			are not essential to ensure liability and
			effective performance, as determined by the AHJ,
			may remain as is.
			
	4.	Firefighting procedures may be developed and maintained
		in conjunction with efforts governing fire department
		procedures in general.  DOE and contractor management
		should be kept routinely informed if fire department
		emergency operations for these special circumstances
		represent deviations from the norm. TFHAs and/or DSAs
		should reflect unique fire-fighting strategies where
		rapid intervention may not be possible (moderation
		controlled areas) and where fixed fire protection
		systems may no longer be applicable.
		
4.17	Fire Protection Design
	
	Information in this section pertains to Section 3c of
	Chapter II in DOE O 420.1B (and the corresponding CRD
	section in Attachment 2 of DOE O 420.1B).
	
	1.	Design aspects of new DOE facilities as well as
		modifications to existing facilities must be based on
		the provisions of the applicable requirements of the
		Code of Federal Regulations (CFR), DOE directives, the
		model building codes, and the applicable NFPA codes and
		standards.  Refer also to DOE-STD-1066-99 for
		supplemental design guidance of DOE facilities.  The
		design process should include appropriate oversight by
		a qualified fire protection engineer of plans,
		specifications, and testing of fire protection
		features.
		
	2.	In accordance with DOE O 420.1B, DOE facilities, sites,
		and activities (including design and construction) must
		have a level of fire protection that is sufficient to
		fulfill the requirements of the best protected class of
		industrial risks (commonly referred to as "Highly
		Protected Risk " or "Improved Risk") and should be
		provided protection to achieve "defense-in-depth."
		This includes meeting the applicable building code and
		NFPA Codes and Standards, and exceeding them when
		necessary to meet safety objectives.  The applicable
		codes and standards are those in effect when facility
		design commences ("code of record").  In accordance
		with DOE O 420.1B, when significant modifications to a
		facility occur, as determined by the AHJ, the current
		edition of the code or standard must apply to the
		modification.
		
	3.	Life safety provisions fall within the jurisdiction of
		10 CFR Part 851 and DOE O 440.1B.  Refer to DOE G 440.1-
		8 for additional guidance.  Additional or modified
		exiting requirements for toxic and explosive
		environments should be as determined by the appropriate
		authorities defined within the above stated documents.
		In addition, for explosive environments, exits should
		reflect the criteria contained in the DOE Explosives
		Safety Manual (DOE M 440.1-1A).
		
	4.	It may be necessary to exceed or supplement the
		requirements of the applicable NFPA code or standard
		when designing fire protection systems designated as
		safety class in the DSA.  Such additional design
		requirements would be required when justified on the
		basis of the conclusions of the DSA or FHA.
		
	5.	Except for systems designated as safety class or safety
		significant, existing sprinkler systems installed under
		the 'pipe schedule' rules of NFPA 13, Standard for the
		Installation of Sprinkler Systems, do not require
		hydraulic verification, provided that:  the sprinkler
		system is adequately maintained; there has been no
		increase in occupancy hazard classification; there has
		been no significant degradation in available water
		supply as determined by the AHJ; it is reliably
		maintained; and meets the water supply requirements of
		NFPA 13 for pipe schedule systems.  Refer to
		Section 4.21 for guidance when considering a change in
		the safety classification of any existing sprinkler
		system.
		
4.18 Water Supply
	
	Information in this section pertains Section 3c(1) of
	Chapter II in DOE O 420.1B (and the corresponding CRD
	section in Attachment 2 of DOE O 420.1B).
	
	It is expected that the emergency services organization for
	DOE sites will be either directly involved with or sent the
	results of routine water supply tests that are required by
	NFPA 25, Standard for the Inspection, Testing, and
	Maintenance of Water-Based Fire Protection Systems.
	Similarly, the emergency services organization for DOE sites
	should be immediately informed of any water line breaks or
	other water supply outages that would adversely affect its
	ability to respond to fires and related events.
	
4.19 Automatic Fire Suppression
	
	Information in this section pertains to Section 3c(4) of
	Chapter II in DOE O 420.1B (and the corresponding CRD
	section in Attachment 2 of DOE O 420.1B).
	
	1.	A fundamental precept of the DOE Fire Protection
		Program is that all facilities of significance (new and
		existing), including facilities where a fire could
		cause unacceptable off-site and/or on-site consequences
		to health, safety, or the environment should be
		protected by automatic fire suppression systems
		(usually sprinkler systems).
		
	2.	The need for an automatic fire suppression system may
		be based on conclusions resulting from an FHA, a DSA,
		or state or local building codes.  The FHA should be
		predicated on the assumption that a fire will occur.
		The nature of that fire depends on the hazards present
		at any given time within the facility.  The resulting
		protection should be designed to ensure that a fire
		would be successfully controlled until such time that
		emergency response forces arrive to complete
		extinguishment.
		
	3.	DOE has an obligation to provide protection for its
		facilities such that a fire will not result in an
		unacceptable program delay or property loss.
		Consequently, the Department considers any facility in
		excess of 5,000 square feet total floor area, or in any
		facility with a MPFL of $3 million as warranting
		protection by a supervised automatic fire suppression
		system.  Private sector practice in recent years has
		expanded sprinkler system use in smaller and less
		hazardous facilities as well.  Additionally, when the
		MPFL exceeds $50 million, a redundant fire protection
		system should be provided that, despite the failure of
		the primary fire protection system, would limit the
		loss to below $50 million.  Redundant protection may be
		a fire-rated barrier system or a smoke detection system
		in conjunction with a fully capable fire department,
		among other options.
		
4.20 Fire Suppression System Confinement or Containment
	
	Information in this section pertains to Section 3c(10) of
	Chapter II in DOE O 420.1B (and the corresponding CRD
	section in Attachment 2 of DOE O 420.1B).
	
	The intent of this requirement is to contain any potentially
	contaminated fire suppression system water in an area until
	such time as it can be tested and determined safe to release
	to the environment.  Such containment could include
	specifically constructed tanks, ponds, or dikes to hold the
	effluent; or it could consist as emergency response
	procedures to “build” such a containment system as necessary
	to prevent an offsite release.  The capacity of such a
	system should be based upon a calculated and reasonable
	approach to determining water volume, such as the
	anticipated flow rate from sprinkler systems and hose
	streams along with the expected duration necessary to
	respond, control and extinguish the fire.  Additionally,
	such systems should be configured with overflow capability
	and established procedures developed to prevent any offsite
	overflow release
	
4.21 Fire Protection Systems Classification
	
	Information  in this section pertains to Section  3c(5)  and
	3c(6)  of  Chapter II in DOE O 420.1B (and the corresponding
	CRD section in Attachment 2 of DOE O 420.1B).
	
	1.	Determination of the need for redundant [exceeding what
		is necessary or normal in the interest of preventing
		failure of the structure, system, or component (SSC)]
		fire protection SSCs, rests with the FHA and DSA
		process described in this Guide.  This section
		addresses cases (for both new and existing fire
		protection systems) wherein DOE takes credit for fire
		protection SSCs in meeting mandatory worker and public
		protection guidelines applicable to a nuclear facility
		(i.e., 10 CFR 830, Nuclear Safety Management; and DOE O
		420.1B).  In these situations, the DSA may identify the
		fire protection system either safety significant
		(needed for defense in depth and worker protection) or
		safety class (needed for protection of the public).
		The objective of this identification might be to reduce
		the frequency and/or consequences of an analyzed fire.
		Methods to achieve these calculated objectives might
		include enhanced reliability of detection and
		suppression systems, minimization of ignition sources
		and transient combustible loading, and increased
		reliance on the integrity of fire barriers,
		penetrations, and filter plenums.
		
	2.	Safety classification is handled according to the
		methodology prescribed in DOE-STD-3009-94, Preparation
		Guide for U.S. Department of Energy Nonreactor Nuclear
		Facility Documented Safety Analyses, and DOE Guide
		420.1-1, Nonreactor Nuclear Safety Design Criteria and
		Explosives Safety Criteria Guide for use with DOE O
		420.1, Facility Safety.  For new and major modification
		to existing systems, safety class, or safety
		significant systems are to meet requirements of DOE O
		420.1B Chapter 1, Nuclear and Explosives Safety Design
		Criteria, as well as any further applicable guidance
		provided in both DOE G 420.1-1 and this Guide.
		
	3.	For existing fire protection SSCs, a certain inherent
		level of reliability is established in the application
		of the appropriate codes and standards when such
		systems were originally built.  It is, however, the
		responsibility of the fire protection engineer, system
		engineer, and the safety analyst to ensure that
		functional requirements of the DSA are adequately
		achieved when reclassifying an existing system.
		Optimally, an existing safety system to be designated
		as safety class or safety significant should satisfy
		the criteria for a newly designed system.  However, if
		differences between current standards and an existing
		system are significant, designation of the system as
		safety class or safety significant is still possible if
		adequate enhancements are implemented.
		
	4.	The criteria used to evaluate the ability of existing
		systems to meet the appropriate conditions to be
		classified as safety class or safety significant is
		provided in Chapter 1 of DOE O 420.1B and its
		accompanying guidance document G 420.1-1.  This can
		also be accomplished by performing a design adequacy
		review using guidance provided by the Energy Facility
		Contractors Group (EFCOG) Engineering Practices Working
		group available at
		http://efcog.org/wg/ep/docs/archive/Safety%20System%20D
		esign%20Adequacy.pdf.
		
	5.	In reviewing the vulnerabilities of the existing
		system, the responsible fire protection engineer
		(working with the system engineering manager for the
		system and the safety analyst) should consider the
		topics below:
		
		a.	What is actual performance requirement to be
			imposed on the fire protection system?
			
			The fire protection engineer should understand
			exactly how the system must perform to meet the
			requirements of the DSA.  This understanding is
			acquired by focusing on the performance
			requirement for the system as described in
			specific accident scenarios.  If the system to be
			reclassified is a sprinkler system, the fire
			protection engineer should ask questions such as:
			
			•	What accident scenarios is the sprinkler system
			  to be relied on for mitigation?
			  
			•	What range of fires does the system have to
			  control?
			  
			•	Is the system expected to control the fire to a
			  theoretical maximum size for a specified
			  period?
			  
			•	Does the system have to function for fire
			  control?
			  
			•	Is there radiological or other concerns related
			  to inadvertent system actuation?
			  
			If the system at issue is a passive one such as
			barriers, a sample question might be:  If a fire
			barrier is relied upon to limit the material at
			risk, is the main concern the fire rating of the
			barrier, the integrity of penetration seals, or
			something else?  (These questions are intended as
			examples.)
			
			The first step in this analysis is complete when
			the fire protection engineer thoroughly
			understands (in a qualitative way) the specific
			performance requirements for the system that would
			serve as a basis for reclassification to safety
			class or safety significant.
			
		b.	What is the required reliability for the system?
			
			Required safety functions for the system will
			normally be established in the approved safety
			basis.  This stage of the inquiry is needed to
			determine whether this level can be substantiated
			from the performance standpoint.  Particularly
			where safety class designation is sought, adoption
			of industry benchmarks may not be sufficiently
			probative of reliability.
			
			Taking as an example the reliability on demand of
			a sprinkler system, one can find NFPA sprinkler
			system data from the late 1960s (the last time
			NFPA published reliability date) suggesting an on-
			demand reliability of 96 percent.4  DOE has
			published study asserting sprinkler system
			reliabilities as high as 99 percent,5 while other
			studies offer figures as low as 85 percent.6  But
			a DSA will require that the assumptions used in
			developing any benchmark be available.  It is
			possible that in some cases the assumptions
			underlying a study would conflict with the
			assumptions of the safety analysis.
			
			There is no answer applicable to all cases.  Each
			reliability study should be evaluated on the basis
			of the assumptions made, the type of data
			collected, maintenance of the systems studied,
			etc.  The reliability of the system needed to
			mitigate accident scenarios may not be adequately
			demonstrated based on available data.  In such
			cases, reclassification of the system cannot
			proceed without appropriate alternative measures
			such as system enhancements, reduction of
			combustibles, or reduction of material at risk.
			
			The second step in this analysis is complete when
			the fire protection engineer understands the
			reliability goal established by the DSA and has
			identified data that does or does not support
			reliability at that level. Reliability can be
			increased, but some baseline should first be
			established in order to quantify the effects of
			design changes or changes in inspections, tests,
			and maintenance.
			
		c.	What are the limits of the designated fire
			protection system?  What support systems are
			needed to guarantee its functionality?
			
			This next step is to define the limits of the fire
			protection system being considered and to identify
			all support systems needed for the system to
			function on demand.  The system boundary limits
			should include all SSCs and support systems
			necessary to guarantee its functionality.  With
			respect to a sprinkler system, for example, how
			far does that system extend?  To the base of the
			riser, the post indicator valve outside the
			building, the connection to the water supply loop,
			or the water source and pumps?
			
			Assuming for a moment that the system is being
			traced all the way back to the fire pumps and if
			these pumps are electrically powered, is the power
			supply a required support system?  The issue of
			system boundary can also arise for passive
			systems.  For example, if safety credit is to be
			taken for a fire-rated wall assembly, does the
			assembly extend only from the floor to the ceiling
			of a given area or does it extend through multiple
			floors?  If the barrier is supported by structural
			steel, could a failure of the structural steel
			lead to a failure of the fire barrier?
			
			This third step in the analysis is complete when
			the fire protection engineer is in a position to
			write out a definition of the system for which
			safety credit is to be taken, and can identify all
			support systems that are relied upon for the
			system to function upon demand.
			
		d.	In the accident scenarios of interest, what events
			or conditions could threaten the ability of the
			fire protection system to perform its intended
			function?
			
			An example of this factor is the attempt to rely
			on a fire protection system to mitigate a design
			basis fire initiated by an earthquake.  In this
			case, it is possible that a suppression system is
			expected to survive and remain functional after
			such a seismic event.  Whether credit can be taken
			for the system in the safety analysis of post-
			earthquake fire scenarios will be dependent not
			only on the continued integrity of the in-building
			system, but on all other supporting components
			leading back to the water supply.
			
			In general, the fire protection engineer (having
			already identified the system to be analyzed and
			having a full understanding of the scenarios in
			which it might be called upon to function) should
			proceed in this step to look for the system’s
			vulnerabilities as a result of the initiating
			event.  This investigation should be done in
			coordination with the assigned system engineer and
			the safety analyst to ensure that all potential
			vulnerabilities are identified and their impact on
			functionality assessed.  The outcome might be that
			safety class or safety significant credit can be
			taken with the system in as-found condition, or
			that design changes will be needed to prevent
			system failure in the scenarios for which safety
			credit is to be taken.
			
		e.	Is the system as designed (or installed in the
			case of an existing system) adequate to meet the
			required safety function?  Are modifications or
			upgrades required?
			
			DOE does not specify the design expectations of
			fire protection systems relied upon in safety
			analysis documentation, except for the following:
			(1) seismic requirements on sprinkler systems set
			forth in Section 7.3 of DOE-STD-1066-99, (2)
			general infrastructural (Mechanical/Electrical)
			requirements in Chapter 5 of DOE G 420.1-1; and
			(3) Chapter II, Section 3c(12) of DOE O 420.1B
			which states: “Fire protection systems designed
			such that their inadvertent operation,
			inactivation, or failure of structural stability
			will not result in the loss of vital safety
			functions or inoperability of safety class systems
			as determined by the DSA.”  The fire protection
			engineer will need to assess the overall adequacy
			of the system to mitigate the fire scenarios of
			concern.  For a new system, this effort may be
			minimal, such as verifying that the design basis
			performance characteristics match those described
			in the safety basis documents.  For an existing
			system, this effort may be more extensive.  DOE O
			420.1B, Chapter I, Section 3b(7) requires SSCs to
			be “designed, commensurate with the importance of
			the safety functions performed, to perform their
			safety functions when called upon and to meet the
			quality assurance program requirements of either
			10 CFR 830, Subpart A, or DOE O 414.1C, Quality
			Assurance, as applicable.”
			
			Useful guidance to perform this design adequacy
			review has been provided by the EFCOG.  For
			example, hydraulic calculations, in lieu of
			scheduled design, may be needed to demonstrate
			that an installed sprinkler system can deliver the
			water discharge density required by NFPA 13 and
			otherwise meets the code’s criteria for spacing
			and obstructions to water discharge.  Where the
			existing system cannot be shown adequate to meet
			the requirements of the safety analysis, design
			upgrades may be needed or the system’s reliability
			adjusted downward to reflect the less-than-optimum
			design.
			
		f.	What level of inspection, testing, maintenance and
			surveillance is appropriate to ensure the required
			performance of the system?
			
			Meeting the inspection, testing, maintenance and
			surveillance requirements of NFPA codes applicable
			to the system in question should be considered a
			minimum to guarantee the functionality and
			performance of the system on demand.  In most
			cases, this level of attention should be adequate
			to justify classifying the fire protection system
			as safety significant.  Where the higher
			designation of safety class is desired, however,
			the fire protection engineer may need to consider
			substantial increases over basic NFPA criteria.
			
			Among the additional steps that might be taken are
			increased quality assurance (e.g., procurement
			procedures, 100% pre-installation inspection and
			documentation of equipment, additional training
			for installation, maintenance, and testing
			personnel) and more frequent intervals for
			inspections, tests, and maintenance.7
			
		g.	Is the fire protection system’s operability
			protected by a technical safety requirement (TSR)?
			
			The final step in the analysis, assuming the steps
			above have shown that a fire protection system may
			be reclassified as safety class or safety
			significant, is for the fire protection engineer
			to develop, in coordination with the system
			engineer and the safety analyst, a TSR.  Such
			requirement will specify, among other things,
			required intervals for inspections, tests, and
			maintenance, a definition of operability for the
			system, action statements for instances where the
			system becomes unavailable, and compensatory
			actions to be taken.  In addition, any
			surveillance testing imposed by TSR should have
			acceptance criteria for tested parameters
			supported by calculations or other engineering
			documents to ensure that design bases assumptions
			are met.
			
			In addition, the development of the TSR will
			require the evaluation of systems interactions,
			i.e., how the failure of other systems could
			induce a failure in the fire protection system
			covered by a TSR.  For example, the water supply
			for a safety class sprinkler system may be
			provided by a site-wide water system.  This system
			may need TSRs to ensure maintenance performed on
			the underground piping will not inadvertently
			impact the safety class function.  The TSR is a
			critical factor in ensuring that a fire protection
			system for which safety analysis credit is taken
			will perform on demand and as designed.
			


				NFPA CODES AND STANDARDS
						  
1.	As a minimum, all of the following NFPA codes and standards
	(or their current equivalents) are likely to be applicable
	to all DOE elements and contractors that have responsibility
	for fire safety programs per the requirements of CFR 851 and
	DOE O 420.1B:
	
	NFPA 1	Uniform Fire Code
	NFPA 10    Standard for Portable Fire Extinguishers
	NFPA 13    Standard for the Installation of Sprinkler
			 Systems
	NFPA 30    Flammable and Combustible Liquids Code
	NFPA 51B   Standard for Fire Prevention During Welding,
			 Cutting, and Other Hot Work
	NFPA 55    Standard for the Storage, Use, and Handling of
			 Compressed Gases and Cryogenic Fluids in
			 Portable and Stationary Containers, Cylinders,
			 and Tanks
	NFPA 70    National Electrical Code
	NFPA 70E   Standard for Electrical Safety in the Workplace
	NFPA 72    National Fire Alarm Code
	NFPA 80    Standard for Fire Doors and Other Operating
			 Protectives
	NFPA 90A   Standard for the Installation of
			 Air-Conditioning and Ventilating Systems
	NFPA 101   Life Safety Code
	NFPA 101B  Code for Means of Egress for Buildings and
			 Structures
	NFPA 241   Standard for Safeguarding Construction,
			 Alteration, and Demolition Operations
	NFPA 780   Standard for the Installation of Lightning
			 Protection Systems
	NFPA 801   Standard for Fire Protection for Facilities
			 Handling Radioactive Materials
	NFPA 1144  Standard for Reducing Structure Ignition
			 Hazards from Wildfire
	
2.	As a minimum, the following NFPA codes and standards (or their
	current equivalents) are likely to be applicable to contractors
	that have responsibility for site emergency response programs
	(fire department, fire brigade, etc.):
	
	NFPA 1000  Standard for Fire Service Professional
			 Qualifications Accreditation and Certification
			 Systems
	NFPA 1001  Standard for Fire Fighter Professional
			 Qualifications
	NFPA 1002  Standard on Fire Apparatus Driver/Operator
			 Professional Qualifications
	NFPA 1005  Standard on Professional Qualifications for
			 Marine Fire Fighting for Land-Based Fire
			 Fighters
	NFPA 1006  Standard for Rescue Technician Professional
			 Qualifications
	NFPA 1021  Standard for Fire Officer Professional
			 Qualifications
	NFPA 1037  Standard for Professional Qualifications for
			 Fire Marshals
	NFPA 1041  Standard for Fire Service Instructor
			 Professional Qualifications
	NFPA 1051  Standard for Wildland Fire Fighter Professional
			 Qualifications
	NFPA 1061  Standard for Professional Qualifications for
			 Public Safety Telecommunicator
	NFPA 1071  Standard for Emergency Vehicle Technician
			 Professional Qualifications
	NFPA 1081  Standard for Industrial Fire Brigade Member
			 Professional Qualifications
			 
	NFPA 1141  Standard for Fire Protection Infrastructure for
			 Land Development in Suburban and Rural Areas
	NFPA 1142  Standard on Water Supplies for Suburban and
			 Rural Fire Fighting
	NFPA 1143  Standard for Wildland Fire Management
	NFPA 1221  Standard for the Installation, Maintenance, and
			 Use of Emergency Services Communications
			 Systems
	NFPA 1403  Standard on Live Fire Training Evolutions
	NFPA 1404  Standard for Fire Service Respiratory
			 Protection Training
	NFPA 1410  Standard on Training for Initial Emergency
			 Scene Operations
	NFPA 1451  Standard for a Fire Service Vehicle Operations
			 Training Program
	NFPA 1500  Standard on Fire Department Occupational Safety
			 and Health Program
	NFPA 1521  Standard for Fire Department Safety Officer
	NFPA 1561  Standard on Emergency Services Incident
			 Management System
	NFPA 1581  Standard on Fire Department Infection Control
			 Program
	NFPA 1582  Standard on Comprehensive Occupational Medical
			 Program for Fire Departments
	NFPA 1583  Standard on Health-Related Fitness Programs for
			 Fire Department Members
	NFPA 1600  Standard on Disaster/Emergency Management and
			 Business Continuity Programs
	NFPA 1670  Standard on Operations and Training for
			 Technical Search and Rescue Incidents
	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 1851  Standard on Selection, Care, and Maintenance of
			 Protective Ensembles for Structural and
			 Proximity Fire Fighting
	NFPA 1852  Standard on Selection, Care, and Maintenance of
			 Open-Circuit Self-Contained Breathing Apparatus
			 (SCBA)
	NFPA 1901  Standard for Automotive Fire Apparatus
	NFPA 1906  Standard for Wildland Fire Apparatus
	NFPA 1911  Standard for the Inspection, Maintenance,
			 Testing, and Retirement of In-Service
			 Automotive Fire Apparatus
	NFPA 1912  Standard for Fire Apparatus Refurbishing
	NFPA 1931  Standard for Manufacturer’s Design of  Fire
			 Department Ground Ladders
	NFPA 1932  Standard on Use, Maintenance, and Service
			 Testing of  In-Service Fire Department Ground
			 Ladders
	NFPA 1936  Standard on Powered Rescue Tools
	NFPA 1951  Standard on Protective Ensembles Technical
			 Rescue Incidents
	NFPA 1961  Standard on Fire Hose
	NFPA 1962  Standard for the Inspection, Care, and Use of
			 Fire Hose, Couplings, and Nozzles and the
			 Service Testing of Fire Hose
	NFPA 1963  Standard for Fire Hose Connections
	NFPA 1964  Standard for Spray Nozzles
	NFPA 1965  Standard for Fire Hose Appliances
	NFPA 1971  Standard on Protective Ensembles for Structural
			 Fire Fighting and Proximity Fire Fighting
	NFPA 1975  Standard on Station/Work Uniforms for Fire and
			 Emergency Services
	NFPA 1976  Standard on Protective Ensemble for Proximity
			 Fire Fighting
	NFPA 1977  Standard on Protective Clothing and Equipment
			 for Wildland Fire Fighting
	NFPA 1981  Standard on Open-Circuit Self-Contained
			 Breathing Apparatus (SCBA) for Emergency
			 Services
	NFPA 1982  Standard on Personal Alert Safety Systems
			 (PASS)
	NFPA 1983  Standard on Life Safety Rope and Equipment for
			 Emergency Services
	NFPA 1989  Standard on Breathing Air Quality for Fire and
			 Emergency Services Respiratory Protection
	NFPA 1991  Standard on Vapor-Protective Ensembles for
			 Hazardous Materials Emergencies
	NFPA 1992  Standard on Liquid Splash-Protective Ensembles
			 and Clothing for Hazardous Materials
			 Emergencies
	NFPA 1994  Standard on Protective Ensembles for First
			 Responders to CBRN Terrorism Incidents
	NFPA 1999  Standard on Protective Clothing for Emergency
			 Medical Operations
	NFPA 2113  Standard on Selection, Care, Use, and
			 Maintenance of Flame-Resistant Garments for
			 Protection of Industrial Personnel against
			 Flash Fire
3.	Individual NFPA codes and standards from the list below may be
	applicable to DOE and its contractors based on their respective
	responsibilities and scope of work:
	
	NFPA 11    Standard for Low-, Medium-, and High-Expansion
			 Foam
	NFPA 12    Standard on Carbon Dioxide Extinguishing
			 Systems
	NFPA 12A   Standard on Halon 1301 Fire Extinguishing
			 Systems
	NFPA 14    Standard for the Installation of Standpipe and
			 Hose Systems
	NFPA 15    Standard for Water Spray Fixed Systems for Fire
			 Protection
	NFPA 16    Standard for the Installation of Foam-Water
			 Sprinkler and Foam-Water Spray Systems
	NFPA 17    Standard for Dry Chemical Extinguishing Systems
	NFPA 17A   Standard for Wet Chemical Extinguishing Systems
	NFPA 20    Standard for the Installation of Stationary
			 Pumps for Fire Protection
	NFPA 22    Standard for Water Tanks for Private Fire
			 Protection
	NFPA 24    Standard for the Installation of Private Fire
			 Service Mains and Their Appurtenances
	NFPA 25    Standard for the Inspection, Testing, and
			 Maintenance of Water-Based Fire Protection
			 Systems
	NFPA 30A   Code for Motor Fuel Dispensing Facilities and
			 Repair Garages
	NFPA 31    Standard for the Installation of Oil-Burning
			 Equipment
	NFPA 33    Standard for Spray Application Using Flammable
			 or Combustible Materials
	NFPA 37    Standard for the Installation and Use of
			 Stationary Combustion Engines and Gas Turbines
	NFPA 45    Standard on Fire Protection for Laboratories
			 Using Chemicals
	NFPA 51    Standard for the Design and Installation of
			 Oxygen-Fuel Gas Systems for Welding, Cutting,
			 and Allied Processes
	NFPA 52    Vehicular Fuel Systems Code
	NFPA 54    National Fuel Gas Code
	NFPA 58    Liquefied Petroleum Gas Code
	NFPA 59    Utility LP-Gas Plant Code
	NFPA 59A   Standard for the Production, Storage, and
			 Handling of Liquefied Natural Gas (LNG)
	NFPA 68    Standard on Explosion Protection by
			 Deflagration Venting
	NFPA 69    Standard on Explosion Prevention Systems
	NFPA 75    Standard for the Protection of Information
			 Technology Equipment
	NFPA 82    Standard on Incinerators and Waste and Linen
			 Handling Systems and Equipment
	NFPA 85    Boiler and Combustion Systems Hazards Code
	NFPA 86    Standard for Ovens and Furnaces
	NFPA 88A   Standard for Parking Structures
	NFPA 90B   Standard for the Installation of Warm Air
			 Heating and Air-Conditioning Systems
	NFPA 91    Standard for Exhaust Systems for Air Conveying
			 of Vapors, Gases, Mists, and Noncombustible
			 Particulate Solids
	NFPA 96    Standard for Ventilation Control and Fire
			 Protection of Commercial Cooking Operations
	NFPA 99    Standard for Health Care Facilities
	NFPA 99C   Standard on Gas and Vacuum Systems
	NFPA 102   Standard for Grandstands, Folding and
			 Telescopic Seating, Tents, and Membrane
			 Structures
	NFPA 105   Standard for the Installation of Smoke Door
			 Assemblies and Other Opening Protectives
	NFPA 110   Standard for Emergency and Standby Power
			 Systems
	NFPA 111   Standard on Stored Electrical Energy Emergency
			 and Standby Power Systems
	NFPA 115   Standard for Laser Fire Protection
	NFPA 204   Standard for Smoke and Heat Venting
	NFPA 211   Standard for Chimneys, Fireplaces, Vents, and
			 Solid Fuel-Burning Appliances
	NFPA 214   Standard on Water-Cooling Towers
	NFPA 220   Standard on Types of Building Construction
	NFPA 221   Standard for High Challenge Fire Walls, Fire
			 Walls and Fire Barrier Walls
	NFPA 232   Standard for the Protection of Records
	NFPA 318   Standard for the Protection of Semiconductor
			 Fabrication Facilities
	NFPA 326   Standard for the Safeguarding of Tanks and
			 Containers for Entry, Cleaning, or Repair
	NFPA 385   Standard for Tank Vehicles for Flammable and
			 Combustible Liquids
	NFPA 407   Standard for Aircraft Fuel Servicing
	NFPA 408   Standard for Aircraft Hand Portable Fire
			 Extinguishers
	NFPA 409   Standard on Aircraft Hangars
	NFPA 415   Standard on Airport Terminal Buildings, Fueling
			 Ramp Drainage, and Loading Walkways
	NFPA 418   Standard for Heliports
	NFPA 430   Code for the Storage of Liquid and Solid
			 Oxidizers
	NFPA 432   Code for the Storage of Organic Peroxide
			 Formulations
	NFPA 434   Code for the Storage of Pesticides
	NFPA 472   Standard for Competence of Responders to
			 Hazardous Materials/Weapons of Mass Destruction
			 Incidents
	NFPA 473   Standard for Competencies for EMS Personnel
			 Responding to Hazardous Materials/WMD Incidents
	NFPA 484   Standard for Combustible Metals
	NFPA 490   Code for the Storage of Ammonium Nitrate
	NFPA 495   Explosive Materials Code
	NFPA 496   Standard for Purged and Pressurized Enclosures
			 for Electrical Equipment
	NFPA 497   Recommended Practice for the Classification of
			 Flammable Liquids, Gases, or Vapors and of
			 Hazardous (Classified) Locations for Electrical
			 Installations in Chemical Process Areas
	NFPA 498   Standard for Safe Havens and Interchange Lots
			 for Vehicles Transporting Explosives
	NFPA 502   Standard for Road Tunnels, Bridges, and Other
			 Limited Access Highways
	NFPA 505   Fire Safety Standard for Powered Industrial
			 Trucks Including Type Designations, Areas of
			 Use, Conversions, Maintenance, and Operations
	NFPA 520   Standard on Subterranean Spaces
	NFPA 560   Standard for the Storage, Handling, and Use of
			 Ethylene Oxide for Sterilization and Fumigation
	NFPA 600   Standard on Industrial Fire Brigades
	NFPA 601   Standard for Security Services in Fire Loss
			 Prevention
	NFPA 654   Standard for the Prevention of Fire and Dust
			 Explosions from the Manufacturing, Processing,
			 and Handling of Combustible Particulate Solids
	NFPA 655   Standard for Prevention of Sulfur Fires and
			 Explosions
	NFPA 664   Standard for the Prevention of Fires and
			 Explosions in Wood Processing and Woodworking
			 Facilities
	NFPA 701   Standard Methods of Fire Tests for Flame
			 Propagation of Textiles and Films
	NFPA 703   Standard for Fire-Retardant Treated Wood and
			 Fire Retardant Coatings for Building Materials
	NFPA 704   Standard System for the Identification of the
			 Hazards of Materials for Emergency Response
	NFPA 750   Standard on Water Mist Fire Protection Systems
	NFPA 820   Standard for Fire Protection in Wastewater
			 Treatment and Collection Facilities
	NFPA 853   Standard for the Installation of Stationary
			 Fuel Cell Power Systems
	NFPA 909   Code for the Protection of Cultural Resources
			 Properties – Museums, Libraries, and Places of
			 Worship
	NFPA 914   Code for Fire Protection of Historic Structures
	NFPA 2001  Standard on Clean Agent Fire Extinguishing
			 Systems
	NFPA 5000  Building Construction and Safety Code




_______________________________
1 DOE G 440.1-8 states that “Complete guidance on the
development, adoption and maintenance of a fire safety and
emergency response program that satisfies the provisions of the
Rule can be found in DOE G 440.1-5, Fire Safety Program for use
with DOE O 420.1 and DOE O 440.1.”  This Guide (DOE G 420.1-3) is
based upon and replaces DOE G 440.1-5 and includes some
additional guidance on the development, adoption and maintenance
of a fire safety and emergency response program to support
implementation of the 10 CFR 851 rule.  However, as experienced
is gained in implementing 10 CFR 851, further guidance may be
determined to be needed to support its implementation; and either
DOE G 440.1-8 or DOE G 420.1-3 will be updated as appropriate.

2 The Authority Having Jurisdiction (AHJ) is defined by Section
5.d.10 of DOE O 420.1B and Section 4 of DOE-STD-1066 as the
decision making authority in matters concerning fire protection
as defined by the National Fire Protection Association Codes and
Standards.  The DOE head of field organization or designee is the
AHJ unless otherwise directed by the Secretarial Officer.

3 Contractors subject to 10 CFR Part 851 must adhere to 29 CFR
Parts 1910 and 1926 if these regulations are applicable to the
hazards at their covered workplace.  See 10 CFR § 851.23 (a)(3)
and (7).

4  NFPA, “Automatic Sprinkler Performance Tables, 1970 Edition,”
Fire Journal, July 1970, pp. 35-39.
5  Maybee, W.W., “Summary of Fire Protection Programs in the U.S.
 Department of Energy—Calendar Year 1987,” U.S. Department of
 Energy, August 1988.
6  For a summary of sprinkler reliability studies, see Koffel,
 W., “Reliability of Automatic Sprinkler Systems,” available on
 the website of the Alliance for Fire Safety:
 http://www.afscc.org/ReliabilityofSprinklerSystemsRJan2006.html
 (Checked August 2007).
7  See safety documentation developed by Westinghouse Savannah
 River Company in connection with the Tritium Consolidation
 Project, described in letter and attached report, John Conway
 to Ernest Moniz, March 18, 1999.