Fire Protection System Deactivation Process

April 2007

Rich Kobelski

Hanford Fire Marshal

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History of Changes/Requirements

• Prior to 1995 – Fire system deactivation was based on building value and environmental release limits.

• March 1995 – DOE published interim guidelines for abandoned facilities and facilities in the D&D process.– Should consider public, worker, and firefighter safety– “Stand-off and protect” tactical approach introduced

• September 1995 – DOE G 440.1-5, issued with Chapter 10 reflecting interim guidelines.

• Deactivation process at Hanford based on DOE Headquarters and local mandatory directives.

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FH Process for Fire System Deactivation

• Groundwork to implement a comprehensive deactivation process including the non-mandatory guidance in DOE G 440.1-5 began in early 2004, but initial process judged to be too cumbersome with too many approvals.

• March 2005 – Fire Marshal Advisory Bulletin issued to redefine the deactivation process.

• January 2006 – Chapter 10 of DOE G 440.1-5 added to FH Requirements Applicability Matrix – Chapter 10 of the Guide is now a mandatory set of contractor requirements.

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FH Process for Fire System Deactivation (cont.)

• The need to continue the development of a more formal comprehensive deactivation process grew as:

– Hanford Site work transitioned to facility deactivation and demolition activities

– Facility/project management sought cost savings for increasing number of unoccupied buildings primarily through:

• Elimination of heating and utility costs

• Elimination of Fire Systems Testing and Maintenance costs

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• Late 2006 – New process flow diagram was created to establish the basic deactivation steps. Fire system deactivation is not allowed if nuclear safety requirements cannot be achieved.

• Fire system deactivation may be allowed without a timetable for building demolition only if:

– DOE loss criteria will not be exceeded,

– Adequate water supply is available without the fire system,

– No unacceptable exposure hazards exist,

– Adequate fire control and firefighter safety is anticipated with existing resources, and

– The financial or political risks are considered acceptable.

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FH Process for Fire System Deactivation (cont.)

Hanford’s Path for Deactivation of Fire SystemsRequest for fire

protection system deactivation

Prepare FHA revision and deactivation analysis

Does facility

have an FHA?

No

Prepare fire protection deactivation analysis

FHA revision or deactivationanalysis includes:• MPFL determination• Exposure assessment• Water supply assessment• Life safety review• Firefighter safety

Do analyses confirm conditions below DOE Fire Protection limits?

Perform USQ and obtain PAAA review

Is there hazardous/radioactive

material present?

Must begin demolition within

30 days

Yes

Is deactivation acceptable per nuclear safety requirements?

STOP

No

Are financial and political risks

acceptable to senior management?

Abandon facility. No timetable for demolition.

Must begin demolition within

30 days

Yes

No

Evaluate potential company-level financial and political risks

• Environmental evaluation

• Hazardous material evaluation

• Radiological material release evaluation

• Groundwater evaluation for fire suppression runoff

Yes

Yes

No

Facility Action

Is this a nuclear facility?

Yes

YesNo

Fire Marshal permitPre-incident plan update

Fire Marshal permitPre-incident plan update

Fire Marshal permitPre-incident plan updateEstablish compensatory measuresObtain DOE authorization for “stand off and protect” as necessary

Facility Management submits letter

to HFD

11/06/06

Yes

No

** HFDConcurrence?

Yes

No

Yes

** HFD Concurrence could occur at any step of the process.

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FH Process for Fire System Deactivation

• Requirements Document HNF-RD-9717, Fire Prevention for Construction, Occupancy, Demolition Activities then revised to

define the new process.

– Facility submits request for fire system deactivation;– FPE prepare FHA revision per HNF-RD-9390, Fire Hazard

Analysis as applicable or– FPE prepares fire system deactivation analysis, including:

• MPFL determination

• Exposure assessment (SOG 4.10)

• Water supply analysis (SOG 4.10)

• Life Safety Code review

• Firefighter Safety determination (SOG 4.10)

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• New Process Requirements (cont.)

– Review analyses against DOE requirements

– Nuclear safety evaluation for acceptability of deactivation as applicable

– Perform USQ/PAAA screening as applicable

– Evaluate company level financial and political risks if hazardous and/or radioactive materials are present and submit risk acceptance letter to HFD as appropriate

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FH Process for Fire System Deactivation (cont.)

– Evaluation of deactivation request by the HFD for proposed tactical approach in the absence of the fire system including a possible “stand-off and protect” approach

– Prepare FM Permit for deactivation

– Obtain HFD Fire Chief concurrence for fire system deactivation based on:

• Sequential fire system deactivation in conjunction with building section demolition as applicable

• Fire system deactivation with the requirement that building demolition begin within 30 days

• Fire system deactivation with no timetable for building demolition

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FH Process for Fire System Deactivation (cont.)

FH Process for Fire System Deactivation

• HFD Internal Procedure – SOG 4.10, Deactivation of Facility Fire Protection Features, created to further detail the features of the process.

– Provides pertinent definitions

– Establishes individual/organizational responsibilities

– Identifies and details Deactivation Evaluation and Decision requirements

– Provides required analyses and assessment forms to be completed (minimum fire water flow, exposure analysis, and response assessment for firefighter safety and possible “stand-off and protect” posture)

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Summary of Process Implementation

• Since November 2006, HFD has received 10 formal requests for fire system deactivation.

– 1 declined (large wooden structure – HFD resource issues)

– 3 approved for fire system deactivation provided building demolition begins within 30 days

– 6 approved for fire system deactivation with no timetable for facility deactivation

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