NFPA 801 ROC Meeting

9. A task group was formed to examine the applicable radiation thresholds that are listed in 1.3 of the 2008 edition of NFPA 801 and develop a recommendation. The task group consists of Bernie Till, Craig Christenson, Chuck March, and Ron Woodfin. 10. The Committee recessed at 6:00 PM ET. Wednesday, June 21, 2011: 1. Meeting re‐convened at 8:30AM ET by Chair, Bernie Till. 2. The Committee reviewed and took action on Public Proposals to NFPA 801. 3. The Committee generated and approved 4 committee proposals. 4. Discussion took place that it might be appropriate to create a new standard that addresses fire protection for Small Module Reactors (SMRs). 5. The next meeting is scheduled to take place in either Savannah, GA or Charleston, SC between March 2, 2012 and May 4, 2012 for the ROC. 6. The meeting was adjourned at 3:17PM ET.

Report on Comments – November 2012 NFPA 801 801- Log #32 Andrew Minister, Battelle Pacific Northwest National Laboratory 801-7 Revise text to read as follows: These requirements shall be applicable to all locations where radioactive materials that meet the thresholds established in 10 CFR 30 are stored, handled, or used in quantities and under conditions requiring where specified by governmental regulations (e.g., those of the U.S. Nuclear Regulatory Commission, or U.S. Department of Energy, or other governmental nuclear regulatory body) applicable to non-power nuclear reactors or to the possession or use these materials, and to all other locations with equal quantities or conditions. The possession and use of radioactive materials is subject to government regulation at the federal or state level depending on the material and use. The regulations of the governing authority specify the applicability of the fire protection requirements in this standard for those who possess, use, handle, or store radioactive materials or operate non-power reactors. The possession and use of radioactive material and the operation of processing, production, or utilization facilities, including non-power reactors is governed by governmental regulations, whether federal, state or governmental body in countries outside of the United States. The specific thresholds for regulation of materials can be substantially different across the various agencies with authority over these materials. The requirements governing safety or radioactive materials, including fire protection, are imbedded in the individual regulations of the governing authority for a particular use or facility. This standard is subordinate to those regulations. Rather than attempt to define a common material threshold that is acceptable to each regulatory entity, the applicability should be deferred to the individual agencies regulations and implementing requirements. 801- Log #29 Neal T. Hara, Idaho National Laboratory 801-7 Accept Proposal 801-10 (Log#48) with the following revision to the original proposal: Revise the fourth sentence within the substantiation to delete the word occupational: “The schedule B quantity was, roughly speaking, those levels for which continuous long term occupational exposure of the public to radioactive materials would not exceed a predetermined dose levels.” Federal Register, Volume 33, No.156 – Saturday, August 10, 1968 (pages 11413 through 11417) provided additional clarification of the basis for the 10 CFR 30, Schedule B threshold. The discussion within the federal register describes the schedule B quantity basis (continuous exposure over one year for inhalation hazards and 1 milliroentgen per hour for direct gamma radiation hazards). Since items with quantities of radioactive material less than those listed in schedule B are essentially uncontrolled after being supplied to the general public, the quantities are limited and are not appropriate for determining exposure of the public or emergency response personnel during or after a fire. Printed on 3/9/2012 1

Report on Comments – November 2012 NFPA 801 801- Log #26 Marcelo M. Hirschler, GBH International 801-1 Revise text to read as follows: ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959. ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials 2012 2010 ASTM E814, 1994. Standards update - 801- Log #1 John F. Bender, Underwriters Laboratories Inc. 801-1 Revise text to read as follows: Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062. UL 723, , 2008, Revised 2010. ANSI/UL 1479, 2003, revised 2006 2010. Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062. UL 723, , 2008, Revised 2010. Add ANSI approval designation to ANSI/UL 1479 and update referenced standards to most recent edition. 801- Log #28 Marcelo M. Hirschler, GBH International 801-1 Revise text to read as follows: A relative measurement of the surface burning characteristics of building materials. Flame spread ratings are determined by ASTM E 84 or UL 723. A comparative measure, expressed as a dimensionless number, derived from visual measurements of the spread of flame versus time for a material tested in accordance with ASTM E 84, ; or UL 723, . [NFPA 5000; 3.3.346.1] The term “flame spread rating” is no longer in use. The appropriate term is “flame spread index”. The preferred NFPA definition of “flame spread index” is the one from NFPA 5000, and it is recommended that NFPA 801 simply extracts it. With this definition the annex note is no longer needed. Printed on 3/9/2012 2

Report on Comments – November 2012 NFPA 801 801- Log #33 Andrew Minister, Battelle Pacific Northwest National Laboratory 801-18 Revise text to read as follows: The Fire Hazards Analysis shall be prepared by or under the supervision of a qualified fire protection engineer acceptable to the authority having jurisdiction. A qualified fire protection engineer acceptable to the AHJ responsible for the preparation of a fire hazards analysis for facilities handling radioactive materials should have generally has knowledge based on a combination of education and experience in the field of fire protection specific to these types of facilities. Examples of a qualified fire protection engineer can include a licensed professional engineer specializing in the field of fire protection or qualified to be a professional member of the Society of Fire Protection Engineers (SFPE). The proposed word implies that the AHJ must approve the technical capabilities of regulated user of radioactive materials. The authority having jurisdiction (i.e., regulatory agencies with authority for radioactive materials) should not determine the acceptability of the qualifications of engineering or other staff of the licensees, contractors, or other users governed by the AHJs. It is the role of the regulator to provide oversight with regard to meeting these requirements. Printed on 3/9/2012 3

Report on Comments – November 2012 NFPA 801 801- Log #34 Andrew Minister, Battelle Pacific Northwest National Laboratory 801-19 Revise text to read as follows: A written fire protection plan program shall be established and implemented for all operational modes of the facility and shall include the following: (1) Management and policy direction as indicated in Section 4.1 (2) Standards, procedures, processes and supporting documentation for fire protection design and operation of the facility (3) Preparation and maintenance of a fire hazard analysis as indicated in Section 4.2 (4) Management of changes to the facility that affect fire protection (5) Fire safety information for all employees and contractors, including familiarization with procedures for fire prevention, emergency alarm response, and reporting of fires (6)* Documented facility inspections conducted at least monthly, including provisions for remedial action to correct conditions that increase fire hazards (7)* A description of the general housekeeping practices and the control of transient combustibles (8)* Fire prevention surveillance (9) Control of flammable and combustible liquids and gases and oxidizers in accordance with the applicable documents referenced in Section 7.1 (10)* Control of ignition sources including, but not limited to, grinding, welding, and cutting (11) Restriction of smoking to designated and supervised areas of the facility (12) Inspection, testing and maintenance of fire protection design features and equipment as indicated in Section 4.4 (13) Procedures for planned and unplanned impairments to fire protection design features and equipment as indicated in Section 4.5 (14)* Fire reports, including an investigation and a statement on the corrective action to be taken (15)* Construction, demolition, and renovating activities that conform to the requirements of NFPA 241, (16) Emergency response requirements as indicated in Section 4.6 (17) Provision of the facility fire emergency organization as indicated in Section 4.7 (18) Preparation of pre-fire plans as indicated in Section 4.8 (19) Quality assurance and self auditing of the above activities (20) Provision for staff and training to carry out the above activities Preparation of the fire protection program should follow the requirements of Section 4.3 while taking into consideration the hazards and complexity of the facility and potential consequences of a fire to building occupants, the public or the environment. The level of detail to the fire protection program elements will depend on the risk of the facility in relation to the fire protection objectives. Pressure-impregnated fire-retardant lumber should be used in accordance with its listing and the manufacturer’s instructions. Where exposed to the weather or moisture (e.g., concrete forms), the fire retardant used should be suitable for this exposure. Fire-retardant coatings are not acceptable on walking surfaces or surfaces subject to mechanical damage. Use of fire-retardant paint requires special care. Inconsistent application and exposure to weather can reduce the effectiveness of fire-retardant coatings. Large timbers are occasionally used to support large pieces of equipment during storage or maintenance. The size of these timbers makes them difficult to ignite, and they do not represent an immediate fire threat. The reason for addition of the term “Plan” after program in the subsection title is unclear from the ROP. The elements described are the content of a comprehensive program and the term “Program” is familiar to many who apply this standard (e.g., DOE regulations (10 CFR 851) and directives refer to a fire protection program). The combination of program and plan is confusing and implies two different elements without definition. The deleted text regarding operational modes eliminates ambiguity. Operational modes are not defined for many facilities handling radioactive materials nor is the term defined in this standard. There is nothing in the standard to imply that fire protection would not apply at all times and to all conditions of facility operations. Printed on 3/9/2012 4

Report on Comments – November 2012 NFPA 801 801- Log #4 Wayne Holmes, Burlington, NC 801-27 Retain the original text of the first part of 5.2.1 to read, "Facilities having quantities of radioactive materials that can become airborne In the event of a fire or explosion.". Not all facilities that contain radioactive materials need to be segregated from other buildings or operations. Facilities with minor quantities do not need to be segregated. Nuclear materials such as a solid ingot of uranium that has no potential to become airborne need not be segregated. It is important to retain the concept that the segregation requirement applies only to quantities of materials that might become airborne due to fire exposure as determined by the FHA. 801- Log #5 Wayne Holmes, Burlington, NC 801-27 Retain the word, "important", such that 5.2.1 reads, "Facilities having quantities of radioactive materials that can become airborne in the event of fire or explosion shall be segregated from other important buildings.". Segregation does need to be provided for all buildings. Small or unimportant buildings do not need to be segregated. The analysis in the FHA will determine which buildings are important and need to be segregated. 801- Log #7 Wayne Holmes, Burlington, NC 801-38 Revise proposed 5.9.5.3.5 to read: Filters in smoke exhaust systems shall be proved with fixed fire suppression systems if required by the Fire Hazard Analysis. This absolute requirement to provide fixed protection for all filters that might collect combustible materials unless justified by the FHA is unnecessary. The topic of this section is filters in smoke exhaust systems. All filters in such systems smoke exhaust systems will collect combustible materials. Enforcement of proposed 5.9.5.3.5 would required that all filters, regardless of size or importance, be provided with fixed protection unless justified by the FHA. Typical nuclear ventilation systems, including those that might be used for smoke exhaust, often include multiple levels of filters, including many that are quite small. Fire protection for all filters is unwarranted and, in some cases, might be detrimental to sound fire protection and radiological safety. The FHA should not need to provide an analysis of all filters in smoke exhaust systems to justify the omission of fixed fire protection. Rather, the FHA should evaluate the ventilation system and determine if and where, fixed fire protection is necessary for fire and radiological safety Printed on 3/9/2012 5

Report on Comments – November 2012 NFPA 801 801- Log #9 Wayne Holmes, Burlington, NC 801-39 Revise text to read as follows: Where required by the FHA, rooms for the storage of radioactive material, including radioactive gases and radioactive waste shall be separated from the remainder of the building by a 2-hour fire separation, except where it is demonstrated by the fire hazard analysis that the fire protection objectives can be met by other fire protection measures. The proposed 5.14.3 as presented in the ROP would require that all storage rooms that contain any amount of radioactive material, including minor amounts of material, be provided with 2-hour fire-rated separation unless justified by the FHA This level of enclosure for all radioactive storage is unjustified. The need for enclosure should be driven by analysis rather than prescription. 801- Log #10 Wayne Holmes, Burlington, NC 801-39 Delete proposed 5.14.3.1 in its entirety. The intent of this paragraph is unclear. It contains no requirements nor does it provide relief from any requirements. It states that needed materials are permitted to be available. It does not address whether the materials need to be enclosed or not enclosed. It does not address amounts or the significance of the material or hazard. Proposed 5.14.3.1 should not appear in NFPA 801. Printed on 3/9/2012 6

Report on Comments – November 2012 NFPA 801 801- Log #35 Andrew Minister, Battelle Pacific Northwest National Laboratory 801-40 Revise text to read as follows: A fire hazards analysis shall be performed to determine the fire protection requirements for the facility, using a graded approach based on the hazard presented by the facility. Automatic sprinkler protection shall be provided unless the fire hazards analysis in Section 4.2 dictates otherwise. As determined by the fire hazards analysis, special hazards shall be provided with additional fixed fire protection systems. For locations where fissile materials might be present and could create a potential criticality hazard, combustible materials shall be excluded. In handling fissile materials, precautions should be taken not only to protect against the normal radiation hazard but also against the criticality hazard caused by the assembly of a minimum critical mass. To avoid criticality during fire emergencies, fissile materials that have been arranged so as to minimize the possibility of a criticality hazard should be moved only if absolutely necessary. If it becomes necessary to move such fissile materials, it should be done under the direction of a responsible person on the staff of the facility and in batches that are below the critical mass, or the materials should be moved in layers that minimize the possibility of a criticality occurring. If combustible materials are unavoidably present in a quantity sufficient to constitute a fire hazard, water or another suitable extinguishing agent shall be provided for fire-fighting purposes. Fissile materials shall be arranged such that neutron moderation and reflection by water shall not present a criticality hazard. The requirement for a fire hazards analysis is specified in Section 4.2 and does not need to be repeated. 801- Log #11 Wayne Holmes, Burlington, NC 801-40 Delete "using a graded approach" so that the final phrase in 6.1.1. reads "based on the hazard presented by the facility." The term "graded approach" is not defined in NFPA 801. The meaning of the term is subject to great variation depending on application The application of a "graded approach" as applied to a Department of Energy facility might not be available to, applicable to, or useful to other types of facilities handling nuclear materials such as a hospital. The phrase which is recommended to be deleted adds nothing to the existing requirement in 6.1.1. The intent of this phrase might be better expressed in annex material. Printed on 3/9/2012 7

Report on Comments – November 2012 NFPA 801 801- Log #12 Wayne Holmes, Burlington, NC 801-44 Insert "by the FHA" so that 6.8.2 reads: "Where automatic fire detectors are required by the FHA.". The proposed committee action on 6.8.2 would delete "as required by the FHA." As a result, NFPA 801 would have no guidance or requirements for where fire detection is needed except where required by another referenced standard such as the Life Safety Code NFPA 72 is an installation standard does not specify where detection must be installed It is important that NFPA 801 specifies that detection must be provided in accordance with the FHA. Printed on 3/9/2012 8

Report on Comments – November 2012 NFPA 801 801- Log #36 Andrew Minister, Battelle Pacific Northwest National Laboratory 801-47 Revise text to read as follows: Flammable and combustible liquids shall be stored and handled in accordance with NFPA

Fire Protection for Nuclear Facilities FIF-AAA Paul May 03/09/2012 FIF-AAA Neal W. Krantz, Sr. Principal Krantz Systems & Associates, LLC 30126 Bretton Livonia, MI 48152 Automatic Fire Alarm Association, Inc. Alternate: Fred M. Leber M 1/1/1992 FIF-AAA Christopher A. Ksobiech Principal We Energies 231 West Michigan, P378 Milwaukee, WI 53203