Fire Protection Safety Management Program

Suggested lines of inquiry and review approach

Performance Objective 1: Program Documentation

The site (or facility) is governed by an up-to-date, comprehensive, documented fire safety program.

• A current policy statement or equivalent directive has been issued that articulates management expectations regarding fire safety and emergency services.
• Funding sources have been institutionalized to fully support the Site Fire Protection SMP, commensurate with established site priorities.
• Existing contracts reflect the essential elements of a complete fire safety program, commensurate with the nature and the scope of the work encompassed by the contracts.
• The elements of the fire protection engineering program can be found in a fire protection program manual (or equivalent documents).
• The facets of the site emergency services program are delineated in fire department/brigade operating procedures and equivalent documents.
• Fire safety and emergency services roles and responsibilities are clearly delineated.
• Site (or facility) organizational and physical changes (such as fire protection upgrades) that have occurred within the past few years have been reflected in the (fire safety) program documentation.
• Auditable training records exist for the fire safety staff (including emergency responders).
• Appropriate procedures and records are available which encompass the inspection, testing and maintenance of fire protection systems.
• A file(s) exists which contains the documented resolution of all significant fire safety issues related to new construction projects. This file(s) should also contain “as-built” or “record” drawings and calculations, procedures, procurement and specifications related to installed fire safety features.
• Applicable regulations, DOE fire safety directives, and industry standards (such as applicable NFPA standards) have been incorporated into the program.
• A file with documentation related to approved exemptions from and equivalencies to applicable fire safety and emergency response criteria.
• Appropriate documentation (policies and procedures, hazards analyses, self-assessment reports, etc.) have been developed and maintained for facilities undergoing decontamination and decommissioning
• Site-specific policies and practices have been implemented where DOE directives and industry standards may be insufficient to mitigate risk.
• Comprehensive written agreements exist with off-site organizations that have roles and responsibilities for site fire safety.
• A complete set of fire protection and emergency services "performance measures" have been adopted.
• An effective issues tracking system has been institutionalized, which encompasses all significant fire safety issues and complies with DOE O 414.1A, "Quality Assurance." This system should include a means to prioritize issues, to allocate funding on the basis of these priorities, and to implement "interim compensatory measures" when there will be a significant delay with the implementation of corrective measures.

Performance Objective 2: Program Implementation

2.1 Fire and related safety hazards: Fire and related safety hazards on site (or within the facility) have been identified and evaluated in conjunction with a current and comprehensive fire hazards analysis (FHA) and self-assessment.

Suggested lines of inquiry and review approach

• All facilities for which FHAs and fire safety self-assessments are required have been identified.
• A site program exists governing the periodic updating of these documents.
• FHAs and assessments are current as compared to the established schedule.
• FHAs and fire safety assessments have been performed for external areas (storage yards, substations, restricted/contaminated areas).
• The documents contain a complete description of the facility, including process operations and related hazards.
• The FHAs and assessments include a textual description of credible fire scenarios, including those involving radiological and chemical hazards.
• The documents identify external fire exposures and evaluate the potential for fire and smoke spread from one (fire) area to another within the facility. The potential for external smoke damage to safety systems and equipment (such as diesel generator intakes) has been evaluated.
• The FHAs and assessments describe the spectrum of fire prevention and protection features in relation to their ability to control fire and reduce risk.
• The documents identify significant variances from DOE directives and NFPA standards, to the extent that they adversely affect fire safety.
• The FHAs comprehensively describe and evaluate the intervention by site (and/or off-site) emergency services organizations.
• The information represented in typical FHAs and self-assessment was confirmed by a facility tour as part of the assessment.
• Noted inconsistencies in the site FHAs and self-assessment are not significant.
• The site USQD process has been applied adequately with regard to fire safety issues that have arisen.
• Fire models used have been subjected to an (evaluation) process that verifies their validity for the given situation.
• The models have been applied by experienced and qualified fire protection engineers.
• Risk assessment techniques are not utilized to reduce defense-in-depth.
• All assumptions and technical bases for the use of fire models have been identified and justified.
• Bracketing calculations for given fire scenarios are provided to validate conclusions regarding bounding results of the analyses.
• Quantitative analyses results are not used as the sole basis for deciding levels of fire protection.

2.2 Fire Prevention and Protection Procedures: Fire prevention procedures have been implemented and fire safety features have been installed to mitigate fire risk.

Suggested lines of inquiry and review approach

• Fire safety "defense-in-depth" exists across the site and encompasses all significant facilities and activities for which fires and related hazards represent a credible threat.
• Fire and related hazards that are unique to DOE and are not addressed by industry standards are protected by isolation, segregation or special fire control systems (e.g. inert gas, explosion suppression).
• Passive fire safety features (such as fire walls or "defensible areas" around facilities and utilities) are favored over active systems. Engineering and design controls are favored over administrative controls.
• Fire prevention procedures, fire protection systems, and manual fire fighting capabilities have been confirmed by representative "vertical slice" reviews. Reviews of procedures should include those governing smoking restrictions and hot work, among others
• Required fire safety features have been confirmed in comparison with authorization basis documents, FHAs, DOE directives, and NFPA standards. Confirmation of features should include those associated with emergency notification and egress.
• Fire protection features have been appropriately classified as “safety class,” “safety significant,” "essential," "important to safety," or "defense in depth."
• Fire protection systems are designed, installed and maintained such that their inadvertent operation, inactivation, or failure of structural stability will not result in the loss of vital safety functions, inoperability of safety class systems, or personal injury.
• Appropriate fire safety systems and features are being maintained operable for facilities undergoing decontamination and decommissioning.
• An effective corrective maintenance program is established to assure the timely repair of defective systems, support systems, and equipment, and the adequacy of the material condition of systems and equipment.
• A program to track and trend fire protection system failures, malfunctions and related phenomenon has been instituted. Appropriate records and analysis are being retained in an auditable form.
• Fire protection systems and equipment that have been removed from service or “impaired” for maintenance are adequately controlled, documented, and restored to service and any necessary compensatory measures are implemented during the outage.
• Post maintenance testing is effectively utilized to assure the adequacy of preventive or corrective maintenance and the operability of the system or equipment.
• A program of controls is in place to monitor and effectively mitigate the impact of aging on fire protection systems, equipment and components.
• The site has a program in place governing the review of construction project design packages by a qualified fire protection engineer.
• Projects cannot proceed without the (signature) approval of the cognizant fire protection engineer.
• The DOE field office and program office fire protection staffs are involved with the approval of significant projects involving fire safety.
• The utilization of industry standards was confirmed by a select review of construction plans and specifications, authorization bases documents, and self-assessment reports.
• Conformance with industry standards was confirmed on the basis of facility tours.
• Fire protection system inspection, testing and maintenance programs (scope and frequencies) conform to NFPA 25 and 72, as amended by DOE Implementation Guidance.
• A QA/QC program on site, which complies with DOE O 414.1A, governs the specification, purchase, inspection, acceptance-testing, and maintenance of fire protection components and systems.

2.3 Personnel Qualification: Personnel are appropriately qualified and trained to perform their work safely and responsibly when confronted by fire hazards and related dangers.

Suggested lines of inquiry and review approach

• A program exists on site, which provides all employees with an appropriate level of fire safety training upon initial employment and on a regular follow-on basis.
• Appropriate fire safety training is provided to subcontractors who perform work involving significant fire risk.
• A documented program exists which identifies which employees and other personnel who live, work, study or respond on site and are subjected to fire safety hazards that represent a unique risk.
• Appropriate training is available to employees who have been identified as needing special fire safety training (such as fire fighters, first responders, cutters, welders, and fire watchers, among others)
• Special fire safety training has been reviewed by a qualified fire safety specialist (such as a fire protection engineer of fire department safety officer) and has been presented by an individual with more than a rudimentary level of knowledge of the risks involved.
• The fire safety staff is encompassed by a professional development or comparable program. This includes the establishment of acceptable “minimum qualifications” for fire protection engineers, fire protection equipment technicians, fire department offices and other specialists (where applicable) and managers who have responsibility for fire protection and emergency services.
• During a given year, the staff has received an appropriate level of continuing education and training in accordance with their individual needs.

2.4 Emergency Services Organization: The site (or facility) is protected by a fully capable emergency services organization.

Suggested lines of inquiry and review approach

• The fire department (or fire brigade) has comprehensively defined its roles and responsibilities for site emergency services.
• Off-site emergency response obligations are defined in a "mutual aid" agreement or equivalent document.
• Collateral duty roles and responsibilities have been identified and justified.
• The mobile apparatus inventory is sufficient for anticipated site emergencies, with appropriate reserve capability.
• Fire department (or brigade) staffing levels have been evaluated, defined and met.
• Emergency equipment inventories are complete.
• The site fire alarm, signaling system and emergency radio communications capability is reliable and effective.
• A clear line of responsibility exists between the fire department/brigade and other site organizations that may also respond to an emergency.
• Run statistics are complete and current.
• Fire department representatives are represented on facility design reviews and the development of authorization basis documentation.
• The fire department (or brigade) has developed pre-fire plans for all significant facilities and areas on site.
• A complete set of written standard operating procedures (or equivalent) exists which govern the activities of the fire department (or brigade).
• The fire fighter training program is complete and current.
• Emergency response apparatus and equipment are within acceptable service lives.
• Apparatus and equipment are inspected, tested, and maintained in accordance with an established schedule.
• The emergency services organization effectively implements the "Incident Command System."
• Fire prevention inspections are being performed in accordance with established frequencies.
• Fire department/brigade personnel meet required levels of competency and certification.
• Fire department facilities (stations, training facilities, alarm centers, etc.) comply with applicable NFPA standards and other governing criteria.
• The site has defined its emergency services needs in relation to off-site fire departments and related organizations.
• Appropriate agreements (MOUs, fees for services, etc.) are in place between the site and off-site emergency responders.
• Site familiarization tours (including hazardous and radiologically contaminated areas) and related training are performed routinely by responsible off-site emergency services organizations.
• Off-site emergency responders comply with all site-specific training requirements so as to be able to respond safely and effectively to site emergencies.
• Plans for extended operations, radiological monitoring, and personnel accountability have been developed and practiced.

2.5 Performance Improvement: Data, statistics, "lessons learned" and other "feedback" from the site (or facility) fire safety program are disseminated on site and within the DOE (fire) safety community.

Suggested lines of inquiry and review approach

• Fire safety data and statistics are accurately and consistently documented and reported as part of the required annual summary of the fire protection program.
• Fires and related events are accurately and consistently documented via the CAIRS and ORPS systems, as applicable.
• Input for the annual DOE Fire Protection Program Summary is submitted in a timely manner and is complete.
• Site-specific documentation is available to confirm that small fires and other related occurrences are distributed within the contractor organization as "near misses."
• Documentation or other information exists to verify that the DOE field office and program office are informed of fire safety-related "near misses" and related information on a regular basis.
• The DOE "lessons learned" program is utilized to distribute information on fires and related events that may have relevance elsewhere within the Complex.

Performance Objective 3:  DOE Line Management Oversight:  The Federal Field/Site Office Staff has assigned personnel with competence commensurate with the responsibility to manage and oversee the fire protection SMP across the site. A documented oversight program is implemented to verify the effectiveness of the fire protection SMP across the site and at each nuclear facility.

Suggested lines of inquiry and review approach

• Requirements for contractor assessments of site wide and facility specific fire protection SMPs with consideration to hazard categorization of the individual facilities.
• Requirements for Site Office assessments of contractor fire protection SMPs and Site Office performance in oversight of contractor fire protection SMP.
• Expectations for development, review, and approval of FHAs
• Expectations for incorporation of results of FHAs into DSAs.
• Organization and expectations for technical competence of fire protection professional and managerial personnel.
• Completion of scheduled formal assessments and other oversight activities
• Evaluation and communication of assessment results including expected actions for resolution of identified issues
• Development, tracking, and closure of corrective actions
• Evaluation of effectiveness of specific corrective actions

< BACK TO PREVIOUS PAGE