FIRE PROTECTION QUESTIONS
 
 

FQ1 Is the staffing of the Fire Protection Organization sufficient to keep up with work requirements?
 
 

If human and material resources are inadequate at a nuclear facility, serious hidden weaknesses leading to an eventual fire protection disaster may be present. Because a fire protection program is a significant aspect of a facility's risk management, the program must be integral and accessible to all elements of line management. Inadequate technical resources for the Fire Protection Organization within a nuclear facility will, by definition, compromise safety. Even where other support organizations (e.g., maintenance, fire department, facilities engineering) help maintain the facility fire protection program, adequate training and guidance must be provided by qualified fire protection engineers if total fire risk management is to be achieved. The DOE fire protection program for nuclear facilities is defined by DOE 5480.7A to include staffing requirements and a support structure consisting not only of the facility operator but of the PSO and Field Office as well. Significant elements and symptoms may surface at all three responsible organizations and each should be examined accordingly.

A fire protection program is an ongoing process consisting of prevention and protection approaches to control and mitigate losses. These approaches are a combination of human element programs and physically engineered features and systems. Risk management requires that sufficient technical resources are in place to identify hazards and take corrective action. The Fire Protection Organization must have a sufficient mix of qualified personnel to conduct training; perform procedure development, construction, and facility design reviews; conduct hazards analysis and assessment; maintain and test fire protection systems; and manage communications during preparation of prioritization and funding proposals to maintain and upgrade facilities. Resources are not limited to trained personnel but include equipment, tools, and funding adequate to upgrade and maintain facilities in accordance with DOE 5480.7A.

According to DOE 5480.7A, each DOE fire protection program consists at a minimum of qualified fire fighters, technicians for maintenance and testing, and fire protection engineers. These positions are defined in DOE 5480.7A and 6430.1A, as are the objectives and responsibilities of line organizations to achieve compliance with the DOE fire protection program.

Assessors of DOE fire protection programs at nuclear facilities must be fully versed in DOE requirements and familiar with the use and application of required codes and standards. Therefore, facility assessments should be performed by those who qualify as fire protection engineers as defined in DOE 5480.7A.
 
 

Symptoms

This key question is supported by all of the fire protection assessment activities.
 
 

Management Cause Analysis

2B.1: Staffing problems often are masked by temporary assignments and the execution of responsibilities by other organizations. It is important to identify how staffing requirements are set for various positions in the Fire Protection Organization. Are the work load and expectations for a selected position realistic? What priority is placed on filling open positions? If delays in filling vacancies are significant, how can they be avoided?

2B.2: Where no cognizant fire protection engineer is available to carry out fire protection program objectives set out in DOE 5480.7A, significant program deficiencies are inevitable. Often the unavailability of a qualified fire protection engineer is the result of a DOE Field Office or contractor failure to define the role and responsibilities of the position adequately. In some cases, fire protection staff are selected on the basis of availability, rather than on having the qualifications needed to fulfill requirements.

2B.3: Personnel may be identified in numbers sufficient to perform the work, but not with sufficient training and guidance to maintain and test fire protection systems. Similar problems can arise in an emergency organization or fire department, if either basic duty training or site-specific hazard training is incomplete.

2C: A fire protection program cannot deal effectively with facility hazards without clear direction. Deficiencies may include the following:

2E: To be effective, the facility fire protection program must be integrated into the existing PSO and DOE Field Office programs and processes. The facility fire protection program needs recognition and support from the PSO and DOE Field Office to ensure provision of necessary resources and to oversee action planning and funding resolution activities.

2F: Management attitude toward fire safety is evident in how management selects, qualifies, and trains fire protection staff. Failure to implement a selection, qualification, and training program may indicate management failure to understand the significance of fire hazards.
 
 

References

If structural, organizational, or assessment functions are inadequate at a nuclear facility, serious hidden weaknesses leading to an eventual fire protection disaster may be present. Because a fire protection program is a significant aspect of a facility's risk management, the DOE fire protection program requires that fire prevention and protection be integrated into the entire management process. Even where other support organizations (e.g., maintenance, fire department, facilities engineering) help maintain the facility fire protection program, adequate training and guidance must be provided by qualified fire protection engineers to achieve total fire risk management. The DOE fire protection program defined by DOE 5480.7A includes staffing requirements and a support structure consisting not only of the facility operator but the PSO and Field Office as well. Significant elements may surface at all three responsible organizations and each should be examined accordingly. Ill-defined responsibilities or a failure to frequently and thoroughly review activities can render even the most well-designed fire protection systems and features unreliable or ineffective.

A fire protection program is an ongoing process consisting of prevention and protection approaches to control and mitigate losses. These approaches are a combination of human element programs and physically engineered features and systems. Risk management requires that sufficient technical resources are in place to address both the identification of hazards and corrective action. The Fire Protection Organization itself must be well defined and readily report its concerns to the highest level of facility management. The Fire Protection Organization must have a sufficient mix of qualified personnel to conduct training; conduct procedure development, construction, and facility design reviews; perform hazards analysis and assessment; maintain and test fire protection systems; and manage communications during preparation of prioritization and funding proposals to maintain and upgrade facilities. Resources are not limited to trained personnel but include equipment, tools, and funding adequate to upgrade and maintain facilities in accordance with DOE 5480.7A. Because many of these functions are carried out by other organizations within the facility, it is vital that responsibilities and reporting requirements be well defined and understood. Further, regular oversight and self-assessment of fire protection program functions must be conducted to confirm the adequacy of performance and identify further initiatives.

According to DOE 5480.7A, the DOE fire protection program consists at a minimum of at least qualified fire fighters, technicians for maintenance and testing, and fire protection engineers. These positions are defined within DOE 5480.7A and 6430.1A, as are the objectives and responsibilities of line organizations to achieve compliance with the DOE fire protection program. Implementation of the program at the facility level occurs through development of formal procedures, whose bases derive from DOE Orders and from reference codes and standards, using sound engineering principles.

Because assessors must be fully versed in DOE requirements and familiar with the use and application of required codes and standards, they should qualify as fire protection engineers under DOE 5480.7A in order to assess fire protection at nuclear facilities.
 
 

Symptoms

This key question is supported by all of the fire protection assessment activities.
 
 

Management Cause Analysis

2A.3: Issues raised by the Fire Protection Organization should be reviewed at the appropriate levels of management (both by facility management and by appropriate DOE management). Action plans by management organizations should be examined for appropriateness and effective implementation. Finally, how fire protection issues are placed within the funding process should be determined. When funding to provide technical resources or physical upgrades is delayed or rejected, the appropriateness and the effectiveness of interim compensatory actions should be assessed.

2B.2: The unavailability of a cognizant fire protection engineer to carry out fire protection program objectives in accordance with DOE 5480.7 is a significant deficiency in a fire protection program. Often this unavailability results from the failure by a DOE Field Office or contractor to define the role and responsibilities of the position adequately. In some cases, the management selection of fire protection staff is based on availability, rather than on the qualifications needed to fulfill requirements.

2C: A fire protection program cannot deal effectively with facility hazards unless there is clear direction. Deficiencies may include the following:

2D.2.3: The DOE Field Office must review the contractor's fire protection activities on a regular basis to determine if existing fire protection requirements are satisfied and changing requirements are properly addressed. The failure to do so may severely reduce the direction of and support for the program. Similarly, appropriate DOE Field Office and contractor management levels must oversee daily fire protection activities of facility operations to ensure that work is performed in accordance with established plans, schedules, and procedures. The failure to do so may allow vital trends and opportunities to be overlooked or delayed.

2D.3.3: Frequently, what is identified as a funding or staffing problem is in reality a communication problem among the Fire Protection Organization, senior management, or management of supporting organizations. This inability to communicate affects the Fire Protection Organization's ability to identify concerns, set priorities for corrective action, and to gain access to decision makers, who establish plans of action based on risk and need. Therefore, the first area of examination should be the facility organization itself. According to DOE 5480.7A and principles of "improved risk" for fire protection, the Fire Protection Organization should interface with facility management "at the highest levels."

Assessors should first determine whether issues can be adequately identified and assessed by the Fire Protection Organization in a timely manner. Are objectives and requirements of the fire protection program clearly defined and endorsed by all responsible levels of management for the facility? Has a prioritization system been developed to weigh and communicate concerns, and has the system been reviewed and accepted by management?

2E: The PSO and DOE Field Office must confirm that contractor managers provide corporate and facility fire protection personnel with sufficient resources to design, operate, test, and maintain fire protection systems and implement activities in accordance with approved plans and governing standards.

2F: Organizational structures that emphasize production, schedule, or other objectives over that of safety, or which fail to be risk-management-based, often lead to an ineffective fire protection program. Failure to recognize the importance of sound fire protection initiatives often results in facility operational objectives that are contrary to safety.
 
 

References

A fire hazards analysis (FHA), or the designed section of an SAR developed as directed by DOE 5480.7A, is a comprehensive examination of building features and vulnerabilities. Unlike the SAR, the FHA can identify deficiencies for which corrective action has not been taken. While interim compensatory measures or administrative controls can mitigate these deficiencies, fire protection engineering emphasizes physical systems over programs for the "high degree of reliability" required to control fire hazards within the DOE Fire Protection Program. The FHA is therefore a process that can identify and quantify weaknesses in the fire protection program, demonstrate the effectiveness of interim measures, establish the design basis of existing systems, and validate the need for and type of new fire protection features or devices. The FHA further provides the basis for justification of exemptions or equivalencies by delivering a balanced view of risks and benefits. Relative time frames and priorities are also examined within an FHA.

Because the FHA is a total risk management tool for planning and maintaining the fire protection program at a facility, failure to develop this document can lead to significant gaps and vulnerabilities within the plant fire protection activities. The primary concerns of an FHA from a nuclear safety perspective involve three functional areas. The first is the safety class systems needed for safe shutdown and control of the process. An examination of this area deals not only with the identification of safety class systems, but with routing and locating key components and systems, and assessing the potential exposures of these component systems, their vulnerability to common mode failures, and the means employed to protect them.

The second concern is failure modes with respect to fire. In this area, the FHA must examine both safety class and nonsafety class systems for their potential for mis- or mal-operation during a fire and the potential effects on safe shutdown. The FHA is a "living" document, which can be updated annually or when significant changes occur. Therefore, not all potential exposures or vulnerabilities are examined at one time. Instead, the FHA process should be used to ensure that procedures are in place for both updating the document and for identifying other areas that need to be examined in the process.

The third area of concern is radioactive contamination of the surrounding public environment as a result of fire. Both active and passive confinement measures need to be established within the FHA to examine airborne and liquid releases. Process tanks as well as potential fire-suppression water discharge need to be quantified and bounding conditions established.

The failure to examine comprehensively all possible hazards and protection scenarios in one subject area of the FHA does not necessarily mean that the FHA is deficient. Instead, it is important to examine the process to ensure that qualified technical resources are being employed to perform the work, that the FHA is a continuing process and has formal procedures for updating and examination, that it is a model for planning and an integral part of the fire protection program, and that its conclusions are reasonable. In all cases a graded approach to the FHA should be employed, based on the complexity of the process and risks involved.

To properly evaluate an FHA, the assessor must be fully versed in DOE requirements and familiar with the use and application of required codes and standards. Therefore, a qualified fire protection engineer, as defined in DOE 5480.7A, should address the key fire protection questions.
 
 

Symptoms

This key question is supported by all of the fire protection assessment activities.
 
 

Management Cause Analysis

2A: The FHA is critical to the oversight activities of the PSO and DOE Field Office. The absence of direction by these offices on the conduct, update, and concurrence review process of FHAs may indicate a lack of direct interest or understanding of the facility, its hazards, and features.

2A.1: The FHA is a summary of all pertinent fire protection design, operation, hazards, and protection information for a facility. If an FHA is not completed or its equivalent examination not placed within the SAR, vital facility information is incomplete. Current fire protection and hazards information itself may not be available in drawing and specification files. If this is the case, then a significant area of facility configuration and control is missing from the total management system. Incomplete or missing fire protection drawings can adversely affect the reliability of maintenance efforts, engineering modifications, and assessment of hazard controls for the overall safety envelope.

2A.2: As a living document, the FHA needs to be part of the planning and facility operations process. If the key responsible managers of the facility, maintenance, operations, and emergency preparedness organizations do not use the current edition of the FHA, emergency response, resource planning, funding, staffing, and even engineering modifications may be affected adversely. Facility managers should understand clearly the FHA objectives and concur with the conclusions. The FHA should be a reference for any proposed changes to the facility.

Because the conclusions of the FHA directly affect the adequacy of the overall fire safety program, it is vital that the bases for the conclusions be clear, along with any other assumptions, and/or equivalent approaches taken. The FHA document should clearly communicate bounding conditions and verify that a nuclear safety envelope can be achieved with the features in place. The importance of these conclusions is such that the PSO and DOE Field Office need to formally review and concur with the results and offer additional direction for future updates.

2A.3: Part of the orientation for any line manager entering a facility should be the FHA. This includes the overall basis for its development, key areas of importance, significant controls or systems necessary to protect the facility, exemptions and equivalencies taken, and potential fire hazards and vulnerabilities to the process. In addition, the line manager should be familiar with the means and importance of updating the FHA, as well as its use in any consideration of facility reconfiguration or modification.

2E: DOE and contractor resources needed for fire protection relative to nuclear safety are validated and examined within an FHA. If significant issues are not clearly addressed within the FHA, or if the FHA itself is not used as part of the planning and funding process, then objectives and requirements may not be met. Therefore, the FHA should clearly identify risks versus benefits from protection features and likely outcomes of significant scenarios, as defined by DOE 5480.7A.

2F: The manner in which information from the FHA is used for both strategic planning and development of the overall safety program is a leading indicator of management interest in safety. The FHA, and in particular deficiencies and recommended corrective actions, should receive attention and review by senior management. Results of the FHA should be placed within the facility corrective action tracking plan. The prioritization methodology should be reviewed along with the FHA to ensure that significant issues are adequately addressed.
 
 

References

The DOE fire protection program recognizes that unique conditions can exist in its facilities, which pose conflicts with nationally recognized codes and standards. However, the intents of DOE 5480.7A must always be fulfilled (i.e., to prevent fire, keep fire loss to acceptable limits, protect personnel life, public safety, and the environment). Facility management must reconcile any conflicts among the objectives of security, environmental protection, and other safety aspects to ensure that as much safety is achieved as is reasonable and possible. Fire protection, like other aspects of safety, must not be compromised in favor of production or schedule objectives. DOE 5480.7A provides guidance and requirements for the analysis and preparation of equivalency approaches. Key to this submittal is preparation of the request by a qualified fire protection engineer with technical support and input from other affected safety, security, or environmental disciplines. Managerial and technical peer reviews at the facility, DOE Field Office, and PSO levels are required to ensure that a balanced and reasonable approach is taken to counter the hazards involved.

Exemptions are defined by DOE 5480.7A for instances where an equivalent level of protection cannot be achieved and future corrective action is not feasible, either due to the nature of the process involved, or physical plant structure requirements. The exemption request process reflects the fact that there exist occasions where neither intent nor letter of the code can be met. Yet compensatory measures still must be instituted to limit, control, or mitigate the hazard potential. These measures may take the form of administrative procedures, increased surveillance, early warning features, quantity limits on hazardous or combustible materials, or the like. The exemption request procedure requires that an exhaustive examination be conducted of alternative approaches, and reasonable assurances must be made that the purpose for which the exemption is sought can be effectively maintained. The request must clearly describe the process by which alternatives were considered and hazards assessed and demonstrate that the final approach is the best, most reasonable choice. The development and approval process for an exemption request is essentially identical to that for submittal of an equivalency.

DOE 6430.1A requires that any equivalencies or exemptions be developed during the design phase for new construction, remodeling, and renovation. Ideally, equivalencies and exemptions should receive consideration as part of a fire hazards analysis (FHA). The format and justification and approval process for design exemptions and equivalencies in fire protection are controlled by DOE 5480.7A and individual implementing policies and procedures of the PSO and DOE Field Offices.

Compliance schedule approvals (CSAs) requests for fire protection are developed for conditions where final resolution may not be achieved for an extended period. They are developed for existing facilities only. Corrective action may call for an exemption request for some aspects of the problem, equivalency approaches for others, and long-term design and funding plans for the remainder. Any or all of these actions may be necessary to reach final closure on a conflict. The CSA is a stand-alone document, which is intended to contain all of the justifications and bases of development needed to resolve an issue. Because the deficient condition will persist for an extended period of time, it is important that interim compensatory measures be taken to control or eliminate as many of the related hazards as possible. The CSA must be reviewed for completeness, thorough examination and implementation of alternatives, and reasonableness of the time schedule and corrective action approach selected.

Determination of the method selected to resolve a requirement deficiency needs to be a collaborative effort by the facility and DOE Field Office. The facility must notify the Field Office of problems in a timely manner and make a preliminary effort to identify alternatives to resolve any deficiency. The Field Office needs to offer clear guidance on the approach to be selected and direction on the key alternatives selected. Concurrence should consist of an informed and proactive decision by both facility management and the field office.

Because assessors must be fully versed in DOE requirements and familiar with use and application of required codes and standards, qualified fire protection engineers, as defined in DOE 5480.7A, should address the key fire protection questions.
 
 

Symptoms

This key question is supported by all of the fire protection assessment activities.
 
 

Management Cause Analysis

2A.1: Often the reason that requests for exceptions to fire protection requirements are not submitted is because the facility has not examined buildings and operations adequately. In the fire protection program, this work is primarily accomplished through the fire hazards analysis process. Other means used to identify hazards and noncompliance are less comprehensive, but may provide early indicators of a deficient or dangerous condition, if implemented effectively. These means may include other fire protection engineering surveys, management self-inspections, various DOE Office oversight appraisals and audits, or even other facility safety discipline inspection activities. The key to examination of the fire protection requirement deficiencies, is to have a process in place to identify problems from the outset.

2A.2: If the hazards can be identified comprehensively in a facility, the next challenge of the fire protection program is to deliver the material to the cognizant and responsible management. Often FHAs may be developed within the Fire Protection Organization and never be distributed outside that group. It is essential that exception requests, regardless of their nature be developed with the knowledge of the facility manager and that progress reports be submitted for concurrence. If this is not done, serious assumption errors can occur in the requests, which do not accurately reflect facility conditions or which pose unworkable solutions. Similarly, DOE Field Office technical and managerial counterparts must receive early and frequent communications about potential exception requests, if they are to be proactive in the process.

2A.3: The information provided in FHAs and exception requests can be useful only if managers understand the reasons for their development and their intent. Management, both at the facility level and at the DOE Field Office, must understand the objectives and required content of these reports. It is of particular concern that a manager understand the impact an approved exception will have on a facility. Only when the ramifications of the request process are understood can a manager take part in the decision process.

2B.3: It is important that new managers receive periodic training updates in the use, objectives, and impacts of fire protection exception request processes. They must understand their roles in the development and support of these tools as "permits to operate." This refresher training should include not only facility management but management at the DOE Field Office as well.

2C: While basic procedures for the variety of exception requests is contained in DOE 5480.7A, implementation of the review process needs to be integrated into the practices of the facility, the DOE Field Offices, and PSO offices. These procedures should provide clear direction regarding methodology, content, and format needed to establish the validity of the approach and basic request to the reviewer. It should also formalize the review process and critical areas being reviewed. The entire process should ensure that appropriate technical staff participation is included in both the development and review process and require senior management concurrence at each step toward approval. Accountability for development should be clearly identified in the exception process. Various stages of review for requests should verify that this accountability is maintained.

2D: An exception request may be incomplete because appropriate managerial or technical staff were not involved in the preparation or review stages. Clearly defined responsibilities need to be established to implement procedures, and the necessary staff resources identified.

2D.1.3/2D.2.3: Both PSO and DOE Field Office oversight roles should include assessment and evaluation of not only exception requests, but all cases where fire protection requirements may not be met at a facility. Field assessments and oversight activities should specifically address exception processes used by the facility.

2D.2.3.9: Due to the nature and importance of exceptions to fire protection requirements, proactive communication and involvement in the decision-making process are needed by the facility and DOE Field Office. Formal methods for conflict resolution and direction are needed at the PSO and Field Office levels. A clear process for the facility to obtain determinations and final positions should be defined and well understood.

2E.1: The exception process may be misused to obtain relief from fire protection requirements due to a lack of funds. It is important that Field and PSO office funding request practices be examined.

2F.1: Line management interest in fostering a safety culture can be directly measured in the degree of involvement in the development of fire protection requirement exception requests. This is true not only of the request development phase, but the degree to which management maintains compensatory features in effect subsequent to an approval.
 
 

References

Training within the Fire Protection Organization is not limited to fire department personnel alone. This training includes facility and field office fire protection engineers, fire protection design technicians, maintenance personnel involved in fire protection equipment inspection and maintenance, emergency brigade members, supervisors and personnel involved with hotwork and cutting/welding activities, and supervisory personnel responsible for control of fire protection impairments or facility fire prevention inspections.

DOE 5480.7A defines the qualifications for fire protection engineers within DOE. It is equally important that continuing education and training be provided in the art and science of fire protection. Basic to this training are facility-specific fundamentals of nuclear processes, operations, and systems. This background is essential for the cognizant fire protection engineer to assess hazards and make decisions on protection measures. In addition, formal training plans should be established by management to ensure that fire protection training keeps current with technological developments in fire protection. Plans should allocate time and resources for outside seminars and continuing education at an institution of higher learning. The training provided to the fire protection engineer should be based on mutually agreed to objectives for professional development relevant to fire protection responsibilities. Additional training should be provided in project plan and design review according to DOE 6430.1A and site-specific project management procedures. One strong indicator of adequate professional training in fire protection is the extent of the resource library available to the engineer. This library should include at least the applicable DOE Orders and both the mandatory and reference codes and standards of DOE 5480.4.

Fire protection designers often are retained within the facility engineering function for preliminary development of specifications for new construction or remodeling. The effectiveness and reliability of the fire protection systems can become questionable if nonqualified personnel are used to complete the work. The National Institute of Civil Engineering Technologies (NICET) has established core-level certifications for engineering technicians. The Society of Fire Protection Engineers has endorsed the certification programs for alarm and detection, special hazards protection, and sprinkler designer technicians. Training comparable to that sponsored by NICET may be gained through a combination of college-level courses and specific vendor training offered by applicable manufacturers. It is important that this training be closely reviewed by a qualified fire protection engineer to ensure that it is comprehensive enough for the duties of the technician involved. In other instances, engineers from other disciplines may be used for fire protection design activities. Again, it is important that they receive formal training relevant to fire protection through similar resources available to the fire protection engineer or engineering technician. Regardless of the resources used, a formal fire protection training plan should be established and maintained, based on specific fire protection job qualifications and descriptions. Other indicators of adequate training are the technical tools and resources available. These should include at least the current edition of minimum design and building codes as well as current manufacturer and vendor manuals on the equipment being used. Where automatic sprinkler systems are specified or designed, a nationally recognized automatic sprinkler hydraulics software program should be available and personnel given training on its application.

Personnel responsible for fire protection maintenance may work either within a maintenance organization or fire department services. These individuals should be qualified in their basic skills or trades and, in addition to normal facility training, they should undergo training with regard to the specific fire protection equipment they maintain. Basic inspection and testing requirements are defined for water-based fire protection equipment in NFPA 25. Courses in these activities should be offered by qualified fire protection engineers or technicians, and training can be accomplished on the job, through classroom instruction, or a combination of both. Outside fire protection contractors may be used to provide this training and instruction, but the specific objectives should be established and verified by cognizant facility training and fire protection staff. Facility-specific training should be provided on equipment used in the plant, based on the manufacturer and vendor maintenance and operations manuals. Training resources should include current drawing and operations/maintenance manuals for each system, current manufacturer or vendor notices, and the manufacturer-required testing or maintenance apparatus. Fire alarm and detection systems tend to be more complex and manufacture training courses or schools should be used for training purposes. It is also useful to take advantage of national industry association or NFPA courses to supplement this training. In either case, the minimum qualifications and training requirements for a position should be clearly established in formal position descriptions, which include specific duties in fire protection.

Emergency brigade members should receive training in accordance with NFPA 600, 29 CFR 1910, and within the scope and charter of the emergency organization selected. The emergency brigade charter itself should describe the type of fire suppression and recovery operations for which the brigade is authorized to respond and conditions under which it must stand down. Assistance and support of professional emergency response organizations should be defined within formal interface agreements. Training should be defined for each position description within the organization and be documented in accordance with NFPA 600. This training includes basic fire suppression training, fire ground safety, facility-specific hazards training, incident commander and specialist training, operation and integration with automatic suppression systems, and team response. Further field training includes live fire exercises and joint fire department and emergency responder exercises. Emergency pre-plans should also be reviewed and practiced with emergency brigade members. Additional training is required in the use and maintenance of personal protective equipment, based on the level of response selected by the brigade organization.

Fire departments are subject to the provisions of NFPA 1500 for training and physical fitness. In addition, there are specific NFPA qualifications examinations and training required for fire officers. Practical training should involve iterations with emergency brigades consisting of implementation and review of emergency pre-plans and facility familiarization tours. Training programs for these personnel should include not only the requirements for emergency brigade members but formal and nationally recognized courses. It is desirable that key training be state-certified and presented by certified fire service instructors.

Supervisors and personnel involved with hotwork or cutting/welding activities should receive specific fire hazard training and regular updates in accordance with NFPA 52B and the NFPA Fire Protection Handbook, as well as fire extinguisher and fire watch training. The plant fire watch and hotwork permit procedures should be a part of this specific training. Similarly, those personnel and supervisors involved in fire protection impairment handling should be trained in the principles of automatic fire suppression system operation, hazards recognition, precautionary procedures, and the site-specific impairment monitoring procedure. In addition to basic fire prevention training provided to all employees, managers should receive training in the requirements and features of the DOE fire protection program, FHAs, and fire protection requirement exception processes. Personnel involved in fire prevention inspections should be given training in the recognition of hazards, deficiency reporting procedures, and facility-specific procedures. This training should include familiarization with facility buildings and operations.

Because assessors must be fully versed in DOE requirements and familiar with use and application of required codes and standards, qualified fire protection engineers, as defined in DOE 5480.7A, should address key fire protection questions.
 
 

Symptoms

This key question is supported by all of the fire protection assessment activities.

TA1: The assessor reviewing the Training Organization interfaces with other departments can assist in determining the quality of facility-specific training being provided to the Fire Protection Organization. If fire protection personnel are adequately trained, the Training Organization planned the training in close coordination with the Fire Protection Organization and probably receives routine feedback to improve the training. On the other hand, if fire protection training is inadequate, it is possible that one of the reasons for the deficiency is that the Training Organization has neglected this area in its programs.
 
 

Management Cause Analysis

2A.1: Ineffective training, particularly of maintenance personnel involved in fire protection, may be a function of incomplete information. When evaluating training, it is important to examine the status and availability of current design, operations, and procedural and manufacturer maintenance manuals and guides. A portion of each training session should include a discussion of the locations and contents of key reference information.

2A.2: It is important that not only line management but fire protection support group supervisors have convenient access to specific information about the equipment they examine or service. On-the-job training of crafts persons or operators in fire protection or prevention greatly influences the effectiveness of support efforts later.

2A.3: Training and specific plant knowledge of the fire protection features and hazards of the facility for which the manager is to be responsible should be integral to the training and orientation process. Position qualifications and certifications at the facility should require confirmation of a clear understanding of responsibilities relative to the fire protection program. The line manager should be trained in the fire protection procedures and permitting systems specific to the facility, as well as the use of risk management tools such as FHAs, and fire protection appraisals for planning and maintaining the overall plant.

2B.2: Training requirements and job position descriptions should be related to one another. A lack of formality in either may lead to inadequate job performance. Generalized position descriptions, which do not specifically address fire protection responsibilities often subordinate those duties and may send a message that fire protection or prevention tasks are trivial. Strong position descriptions, which identify qualifications needed for specialized tasks, such as those performed by an emergency brigade member or fire equipment tester, reinforce training objectives and ensure that adequate training is provided. When outside consultants or contractors are used to support fire protection efforts, the facility should require equivalent qualification and training relevant to the task performed.

2B.3: Trainers and training resources selected to support education in fire protection need to have the necessary qualifications or certifications expected of other trainers of a nuclear program. NFPA and the International Fire Service Trainers Association (FIST) establish minimum trainer qualifications and basic standards for training in the fire service and for maintenance personnel. State guidelines may also be applicable from the State Fire Marshall's Office relative to assessor qualifications. Model building codes and rulemaking organizations offer additional guides for qualifications and certification. Regardless of the code, standard, or organization selected, the facility, with guidance from the DOE Field Office, should make a conscious effort to establish trainer qualifications and certifiable training in fire protection using nationally recognized models.

2B.4: Fire protection engineers with responsibilities for the DOE Field Office and the PSO should meet minimum qualifications and undergo continuing training to perform specific review, oversight, and support responsibilities. At the DOE Field Office level, the fire protection engineers should also receive site-specific training in fire protection and hazards at the facilities for which they are responsible.

2D.2.3: DOE Field Office policy and guidance should include direction on Fire Protection Organization qualifications and minimum acceptable training. Policy should extend to the selection of consultant and contractor support for fire protection.
 
 

References

The foundation of the DOE fire protection program is the ability to rely on properly designed automatic suppression systems and passive construction features. Design, review and verification of hazards, testing and maintenance, regular assessment by qualified fire protection professionals, and frequent inspection with prompt corrective action by facility staff are key to ensuring this objective.

In new facilities or during remodeling and renovation, a fire hazard analysis (FHA) and strict design review procedures must be implemented. Even changes in process equipment can influence the effectiveness of existing protection. Therefore, fire protection design review must encompass the examination of all facility drawings and specifications, not merely those involved in fire protection systems. The design review process should involve the fire protection engineer at the earliest stages of planning and continue through all revisions to the point of field testing and acceptance. The reviews themselves should be conducted by qualified fire protection engineers and be formally documented at each stage. Open items from one review phase should be addressed in the next review's comments until resolved. FHAs should be completed for all major construction and updated for any subsequent modifications. Authority Having Jurisdiction responsibilities should accord with DOE 5480.7A and be delegated to qualified fire protection engineers by formal procedure and policy, from the PSO to the DOE Field Office and thence to the facility. Conflict resolution with respect to code or protection issues should be formally addressed in the design process and in accordance with DOE 6430.1A.

In existing facilities, fire protection should be maintained in accordance with applicable NFPA codes and manufacture instructions. These should be incorporated into facility and equipment procedures, and carried out by trained and qualified crafts persons. The facility fire protection engineer should review and concur with fire protection equipment inspections, testing, and maintenance. All fire protection equipment should be identified and placed within appropriate preventive maintenance logs to ensure that proper testing and service steps and frequencies are conducted. Records of completed work for these systems should be communicated to the fire protection engineer for review and analysis. Facility operations inspections should be formal and recorded, covering specific aspects of fire prevention and safety. A formal corrective action system should include fire protection repairs and establish a priority system for timely response. Line management should review work backlogs and identify any need for additional resources to restore fire protection reliability promptly. Fire protection engineering oversight activities should include reviewing records, protection systems, and equipment, as well as verifying that the training of personnel, who conduct the work, is sound and so is the work quality.

Fire protection system control valves and supplies should be secured in the open position and verified visually at least monthly, and the actual valve position verified physically at least quarterly. Water flow loop tests and fire pump tests should be conducted at least annually, with results recorded for future design purposes, as well as for trending to establish need for flushing or other corrective action. A system for fire protection impairment handling should be in place to ensure both prompt restoration of protection and adequate precautions during operations. Personnel conducting pump tests should have specific training and knowledge of not only the mechanics of the pump and controller system but the objectives and requirements for satisfactory testing per NFPA 20. A procedure for expediting repairs should be in place.

All fire protection systems (including passive arrangements) should be documented and drawings made readily available to the fire protection engineer, maintenance, and testing personnel. Testing and maintenance should not be conducted without formal work packages that contain the pertinent drawings. The plant configuration control system should allow for updates to be efficiently made from the field and promptly recorded accurately within the drawing archive. Any planned renovations or new construction involving fire protection should be promptly documented through formal procedures, once final field verification and acceptance have taken place. Records of contractor materials and test certificates should be completed in accordance with applicable NFPA codes and standards. Drawings, specifications, operations, and maintenance manuals, design calculations, vendor material specifications, and acceptance test reports should be reviewed and concurred with by the facility fire protection engineer prior to final acceptance of systems. Similar procedures should be employed to ensure review and acceptance of fire protection drawing revisions.

Existing fire protection systems (both active and passive) for which formal fire protection reviews, documentation, and acceptance are not completed or are missing, should be formally evaluated by the facility fire protection engineer, based on the hazards currently present and on recognized current codes and standards. The results may be incorporated into the FHA as part of the comprehensive evaluation of the facility. Deficiencies in design should be clearly identified and corrective action recommended. Any unresolved issues should be formally submitted to management for consideration and action. Particular attention from a nuclear safety standpoint should be paid to fire protection equipment and features with a direct effect on safety class systems and components, as well as on equipment and features where a fire may cause misoperation of nonsafety systems, resulting in an unsafe condition. Potentially important safety equipment should be clearly identified and analyzed along with fire scenarios where radioactive release would occur. Fire protection features or systems, which are required to mitigate or prevent loss of important safety equipment, should be closely examined and a high degree of reliability ensured through formal procedures and surveillance. Automatic and redundant fire protection systems or features needed to protect critical equipment or buildings per DOE 5480.7A should be identified and well maintained. Areas for which fire protection requirements cannot be met and exceptions are taken, should be closely monitored to ensure that compensatory measures and controls remain effective.

Automatic suppression systems provide highly reliable control in fire situations. However, fire extinguishment and final salvage are considered manual operations. It is crucial that alarm systems be audible to ensure reliable and prompt response. In addition, detection devices and systems may restrict fire damage to the points of origin, if they operate prior to the automatic suppression systems and personnel respond quickly. The key to the effectiveness of these systems is a combination of maintenance in accordance with manufacturer instructions and applicable NFPA codes, and of training operations personnel in the appropriate responses to an alarm. Special care is needed both at the design phase and in later maintenance to achieve a highly reliable arrangement with a minimum of false alarms.

Because assessors must be fully versed in DOE requirements and familiar with use and application of required codes and standards, qualified fire protection engineers as defined in DOE 5480.7A should address key fire protection questions.
 
 

Symptoms

This key question is supported by all of the fire protection functional area activities.

MA1: The assessor inspecting the physical plant from the Maintenance Organization perspective can assist in determining whether the plant fire protection systems and equipment are adequate to ensure an optimum level of nuclear safety. Fire hazards and inadequate fire reporting and alarm systems are sometimes identified during plant inspections. Hazards are often due to transient materials or accumulations of debris not considered in the plant safety analysis or fire hazards analysis. Deficiencies identified during the physical plant inspection would also indicate a lack of Fire Marshall inspections or inadequate followup on such inspections. Personnel safety issues also are often identified during plant inspections. For example, sometimes the assessor can not readily identify egress routes or clearance for emergency vehicles adjacent to facilities. Areas where workers could be injured due to falls or electrical hazards are also frequently identified during a physical plant inspection. If there is no routine industrial safety inspection program, significant personnel safety vulnerabilities can be expected, especially during emergency response operations such as during a fire. Sometimes the industrial safety hazards are well documented, but the plant management has given this area a low priority relative to correcting other plant deficiencies, or the industrial safety reviews have not considered emergence response conditions. To determine whether fire protection systems and equipment are adequate, additional scenarios may need to be considered, including loss of lighting, electrical hazards due to the presence of fire fighting water, and the current status of plant ventilation in terms of smoke removal.
 
 

Management Cause Analysis

2A.1: Even well-designed fire protection systems can become ineffective or obsolete if maintenance and revision are performed without referring to current documentation. A formal process needs to be in place which ensures that fire protection drawings for a new project are incorporated into the drawing and configuration control system as an integral part of the project management. Existing systems should receive similar drawing control, where changes in the field are made by maintenance or facility engineering personnel. All fire protection documentation and final acceptance of systems or features should be reviewed and concurred with at least by the facility fire protection engineer. For existing fire protection systems where a formal design review process was not employed or information is missing, the facilities fire protection engineer should provide hazards and protection analysis that establishes the adequacy of each arrangement. This should be formally documented in a recognizable assessment such as a fire hazard analysis.

2A.2: Line management should be readily aware of the location and content of fire protection configuration and design information. This information should be accessible and current for the facility fire protection engineer. Work packages involving repair, service, or testing of fire protection equipment or features should contain current working drawings and descriptions of the protection. Engineering should confirm that system component labels conform to the markings and nomenclature on reference drawings and to procedural steps for specific equipment.

2A.3: Line managers responsible for maintenance or facility engineering should be knowledgeable about the importance, operation, and requirements involved in specific fire protection equipment. Detailed knowledge of codes and manufacturer requirements is not expected. However, managers should at least recognize the importance of fire protection within a nuclear facility and the need to consult the facility fire protection engineer when changes are made or work packages prepared. Formal procedures relative to design review, facility configuration and control, and fire protection precautions should be familiar to the manager responsible.

2D1.3/2D2.3: Both the PSO and DOE Field Office should have in place implementing policies and procedures for fire protection design, fire protection engineering review, technical safety support, and oversight evaluation of physical fire protection. The Field Office and PSO should have specific assessment responsibilities in their oversight activities in order to evaluate facility fire protection, protection maintenance procedures, and the effectiveness of the facility fire protection design review process. Appraisal in these areas adds significance and importance at the facility level to the procedures and policy guidance presented by the PSO and Field Office with regard to fire protection, and reinforces the objectives of the DOE fire protection program, as set out in DOE 5480.7A.
 
 

References

FA1 Conduct a facility fire hazards and protection survey.
 
 

Physical survey of a facility is key to evaluating the effectiveness of a plant fire protection program. A survey establishes fundamental information regarding facility process, construction, hazards, and protection features and is a strong indicator of management interest in fire protection and prevention. The critical elements that a survey covers are those areas designated as essential nuclear safety subheadings in a fire hazard analysis (FHA), as outlined in DOE 5480.7A:

A survey should confirm the depth to which FHAs and similar analyses were performed. The reviewer should confirm the bases for key conclusions and verify both physical attributes and hazards. In addition, the survey should reveal the effectiveness and facility staff comprehension of fire protection procedures relative to daily surveillance, periodic inspections, and preventive maintenance activities.
 
 

Symptoms

1. Obtain and review copies of the facility FHAs or other descriptive plant documents, fire protection deficiency tracking logs, and fire protection system information from the facility fire protection engineer for review and familiarization. Request a summary briefing of facility features, programs, hazards, and long-term initiatives from the facility fire protection engineer.

2. Obtain copies of current appraisals from DOE Field Office fire protection oversight organization for review. Request an interview with the DOE Field Office Fire Protection Engineer to discuss scope of oversight activities, Field Office technical support functions, and key issues relative to the facility.

3. Conduct a tour of the facility with a plant representative as guide. This allows the reviewer to ask additional questions and clarify issues at the site. Preferably, this should involve the facility fire protection engineer or at least an individual responsible for conducting plant fire safety inspections. Inspect and evaluate the following:

5. Request an interview with the facility manager to obtain an indication of management understanding and knowledge of fire protection programs at the plant. The interview should reveal general management interest in fire protection, the degree of involvement with FHAs and various exception requests from fire protection requirements, funding and support initiatives for fire protection, and knowledge of the Fire Protection Organization and support groups.

6. Request interviews with at least one maintenance supervisor, operations shift supervisor, crafts person, and operator to determine their knowledge and understanding of facility fire protection and prevention policies and procedures.

7. Subsequent to the survey, discuss with the facility fire protection engineer any unclear issues identified or concerns not specifically addressed by the facility FHA or other inspection reports presented at the beginning of this activity. Open issues encountered, which the fire protection engineer indicates will be corrected prior to the end of the appraisal, should have time frames and milestones established for their resolutions.

8. Request a close-out interview with at least the facility fire protection engineer to verify closure of issues to be completed during the appraisal and to obtain supporting information on other fire protection items not previously available.
 
 

Functional Area Coordination

This activity supports all of the fire protection key questions.

MQ1: The assessor conducting a fire hazards and protection survey may determine that the Maintenance Organization is responsible for certain fire hazards that may reflect a lack of personnel. If maintenance materials are not well stored or if job sites are particularly poorly maintained in terms of housekeeping, the fire protection assessor should inquire regarding the causes of this and should advise the maintenance program assessor.
 
 

Management Cause Analysis

2A.1: By comparing fire protection documentation with actual field conditions, the extent to which this material, so vital to continuing plant operations, is complete and current becomes apparent. Gross errors in hazards analysis conclusions or the use of obsolete drawings during fire protection maintenance activities directly indicate a failure in the facility design configuration and control system. Often it can be determined that fire protection drawings are not included within the normal drawing control system because they are not considered vital.

2A.2: Interviews with key managers and supervisors during the survey will quickly indicate their knowledge of fire protection documentation that could support efforts. Often changes in basic facility information or new fire protection analytical results are discussed in management meetings only briefly and never distributed as control copies to affected managers and supervisors. This may be true of inspection reports on fire protection and prevention, also.

2A.3: Even the most complete analytical documents, drawings, and inspection reports can be useless to managers if they do not know how to apply them to their routine responsibilities. Interviews during the survey should indicate the level at which the managers are informed on plant conditions. The reviewer should verify that the managers can effectively employ this information to set priorities, budgets, and to take corrective action.

2D: Poor maintenance of fire protection equipment and features, unresolved fire protection safety questions, and inadequately protected areas of the facility without funding or exception requests for fire protection requirements can be verified during the survey. The reviewer should look beyond the deficiencies themselves to the manner in which the DOE Field Office, PSO, and facility cooperate to address these concerns. Once the deficiencies are identified, the reviewer should question how aggressively they are dealt with and at what level of management involvement.

2E: Both the physical survey and integrated interviews can identify symptoms of staffing or resource deficiencies. The reviewer is cautioned to examine the nature of the organization and its ability to objectively address fire protection issues before concluding that the problem is merely a need for additional personnel. The reviewer should identify other areas of inquiry useful in determining whether or not the existing staff can meet the objectives of a DOE fire protection program.

2F: Through the physical review of the facility and interviews with supervisors and workers, it becomes apparent the degree of management interest in fire protection and the effectiveness of the programs and procedures. The reviewer should verify not only the content and extent of procedures provided in fire protection but the manner and effectiveness with which they are applied at all levels of the organization.
 
 

References

Policies and procedures are essential to ensure effective implementation at the facility level of the fire protection program in DOE 5480.7A. The policies of the PSOs reveal the level of their involvement in fire protection issues and offer specific guidance on effective hazards control. The DOE Field Office policies and procedures provide direction and ensure the comprehensiveness of implementation of fire protection program objectives at the facility level, as well as integrate these goals with overall safety and environmental issues (including nuclear safety). Facility-level policies give direction and indicate commitment by management to both the DOE fire protection program and degree of proactive involvement in risk management. Facility procedures on fire protection are the final and specific step in implementing these objectives through prescriptive measures, ideally integrated into the entire operating structure.

The bases for examining policies and procedures in fire protection are four-fold. First, policies and procedures are examined to establish that they meet at least minimum requirements of DOE 5480.7A, DOE 5480.4, and associated codes and standards. Second, they are examined to determine the degree to which managers at the PSO, DOE Field Office, and facility levels understand and are committed to these objectives. Third, policies and procedures are assessed for their effectiveness to address the issues and specific concerns of the facility. Finally, the degree is verified to which these policies and procedures are communicated and carried out by facility workers.

Due to the highly technical nature of fire protection issues within this area, a qualified fire protection engineer, as defined by DOE 5480.7A, should carry out the review and address associated questions.
 
 

Symptoms