U.S. NUCLEAR REGULATORY COMMISSION 

REGULATORY GUIDE 

OFFICE OF STANDARDS DEVELOPMENT 

REGULATORY GUIDE 3.38 

GENERAL FIRE PROTECTION GUIDE FOR 

FUEL REPROCESSING PLANTS

A. INTRODUCTION 

Section 50.34, "Contents of Applications; Technical 

Information," of 10 CFR Part 50, "Licensing of 

Production and Utilization Facilities," requires, among 

other things, that each application for a construction 

permit for a production or utilization facility, including 

a fuel reprocessing plant, include the principal design 

criteria for the facility.

particularly in locations vital (a) to the functioning of 

confinement barriers and systems, (b) to methods of 

controlling radioactive materials within facility, and 

(c) to the maintenance of safety cont unctions. The 

adverse effects of fires and expl n structures, 

systems, and components impo t to ety can be 

minimized by providing syst suffic t capacity 

and capability for detectin . ssing explosions 

and fires and for tra tt a to one or more 

central control area A cts may result from

A potential risk to the health and safety of the normal operati ct , or failure of a fire 

general public and plant personnel at a fuel reprocessing suppression sys t ortant to recognize these 

plant is the release and dispersal of radioactive materials potential se and eliminate or mitigate them 

due to a fire or explosion. Fire protection programs for by propr . allation. 

these plants should be designed to prevent, detect, 

extinguish, limit, or control fires and explosions and s ent of these overall objectives entails an 

their.concomitant hazards and damaging effects. Many "their~h~~t onnf such s'uch factors ftor thse as ve the expected ectived maximum maxim 

> acceptable bases and criteria for fire protection programs f combustible material in each area of the 

are available and have been used. This guide de~sc *• . areavilbl ad hveben se. hisgudede •p ; severity, intensity, and duration of credible fires; 

bases and criteria for fire protection programs iy Ithe p s evran y, in eens t o radioact iv e ad oer 

design and construction *of fuel reroessing fa .'es] urance of confinement of radioactive and other 

desig uad bconstrci of fuelrcessinfWsu , otentially dangerous contaminants; effects of exposure 

that should be considered by applicants* r b of construction and processing materials to high

tals for construction permit applications 1such cil- radiation fields and/or corrosive atmospheres; arrange

ties. ments and structural design features of buildings for 

-,.,-I.nI nf -n-I-- heat flame and combustible and

1. DISCtJWON The principal purpo f protection program 

for a fuel reproce I e protection of the 

general public, p oe and the environment 

from adverse rdi k cald se uences due to fire. 

Struct te d components important to 

safety sho e designed and located so they can 

continue to io their safety functions effectively 

under credible ire and explosion exposure conditions. 

Heat-resistant and noficombustible materials should be 

used. wherever practical throughout the facniity,

explosive gases; and systems for fire detection, 

confinement, control, and suppression. 

Selected areas of the plant having particular 

occupancy requirements, such as control rooms or 

control areas, should be designed to allow occupancy 

(I) for the safe operation of the plant under normal 

conditions and (2) for maintaining the plant in a safe 

condition under accident or other abnormal conditions. 

Consideration should be .given to the selection of 

systems for fire detection, confinement, control, and 

suppression suitable for use in these areas.

USNRC REGULATORY GUIDES Comments should be sent to the Secretary of the Commission. U.S. Nuclear Regulatory Commission. Washington, D.C. 20M5. Attention: Docketing and 

Regulatory Guides are issued to describe and make available to the public ServicguSectionr 

methods acceptable to the NRC staff of implementing specific parts of the 

Commission's regulations. Io delineate techniques used by the staff in evalu- The guides ors issued in the following tan broad divisions: 

ating apecific problems or postulated accidents, or to provide guidance to appli 

cents. Regulatory Guides are not substitutes for regulations. and compliance 1. Power Reactors S. Products 

with them is not required. Methods and solutions different from those set out in 2. Research and Test Reactors 7. Transportation 

the guides will be acceptable if they provide a basis for the findings requisite to 3. Fuels and Msterials Facilities B. Occupational Heahh 

the issuance or continuance of a permit or license by the Commission 4. Environmental and Siting 9. Antitrust Review 

Comments and suggestions for Improvements in these guides are encouraged . Materials end Plant Protection 10. General 

at all limes, and guides will be revised, as appropriate, to accommodate com. 

meants and to reflect new information or experience. However. comments on Copies of published guides may be obtained by written request indicating the 

this guide, if received within about two months alter its issuance, will be per divisions desired to the U.S. Nuclear Regulatory Commission. Washington. D.C. 

ticularly useful in evaluating the need for an early revision 2055M. Attention: Director. Office of Standards Development.

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June 1976

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Water should be the principal fire suppressor. Special 

consideration should be given to selection of water 

sources, water distribution systems, fire pumps, and 

automatic and manual fire extinguishing systems to 

control and extinguish a credible fire in any area. 

Automatic sprinkler or equivalent coverage should be 

provided throughout the facility with provisions for 

special hazard fire control measures where particular 

hazards exist, such as in processing operations involving considerable amounts of flammable, oxidizing, and* 

corrosive liquids and in areas where the presence of 

large quantities of highly radioactive materials requires 

massive shielding and remote controls for personnel 

safety. 

Incipient fires may be controlled by portable fire 

extinguishers. This phase of fire control is particularly 

important even though automatic sprinklers have been 

provided. Consideration should be given to the selection 

of portable fire extinguishers suitable for use on specific 

hazards that may be encountered. 

The need for fire detection devices and the type most 

desirable should be related to combinations of hazards 

involved, extinguishing controls' available, and avail

ability of public and private fire department services. 

Various fire detection devices operating on different 

principles are available. These include devices where fire 

detection is based on fixed temperature, rate of 

temperature rise, presence of combustion and pyrolysis products, or various combinations of these principles. 

Fire protection systems may be subject to effects of 

natural phenomena such as seismic motion and floods, 

missiles, fire and explosion, and other accidents. These 

systems should remain functional to the extent that 

sufficient protective and suppressive capabilities are 

maintained to prevent uncontrolled release of radioac

tive materials as a result of fire. Where possible, continuity of fire protection systems should be ensured 

by such means as standby equipment and fail-safe 

control systems. 

The ability of the systems to perform their safety functions effectively can be ensured by periodic testing 

of safety-related components to demonstrate their 

ability to perform at design efficiency and to verify their 

availability for emergencies. 

An important aspect of a fire protection program is 

the training of a firefighting organization and main. 

taining its competence with periodic drills. 

The fire protection program should provide for the 

use of appliances, equipment, and materials listed by 

such testing organizations as the Underwriters' Labora. 

tories, Inc. (UL) and the Factory Mutual Research Corp. 

(FM) as meeting their standards.

Fire protection programs should conform to the 

provisions of the following codes and standards, as 

applicable: 

1. National Fire Codes of the National Fire 

Protection Association (NFPA), 

2. Fire Prevention Code of the American In

surance Association (AIA), 

3. Fire Protection Standards and Bulletins of the 

Factory Insurance Association (FIA), 

4. Standards of the American Petroleum Institute 

(API), 

5. One of the four model building codes

a. National Building Code of the AIA, 

b. Uniform Building Code of the International 

Conference of Building Officials (ICBO), 

c. Southern Standard Building Code of the 

Southern Building Code Congress, 

d. Basic Building Code of the Building Officials 

Conference of America. 

C. REGULATORY POSITION 

Fuel reprocessing plants should be designed to ensure 

the confinement of hazardous materials during normal 

or abnormal conditions including fires and explosions. 

I. General Features 

a. Fire protection systems for fuel reprocessing 

plants should be designed to ensure that any credible fire 

or explosion will not prevent the operation or use of 

structures, systems, equipment, and components (herein

after referred to as "essential items") whose continued 

integrity and/or operability are essential to ensure 

confinement of radioactive materials. 

b. Where possible, each fire protection system should 

be designed so that the failure of any one component 

(equipment or control device) will not disable the entire 

fire protection system. Fire protection systems and 

components should have fail.safe features and audible 

and visual alarms for both operation and trouble. 

c. Onsite emergency power supply systems should be 

provided to operate fire protection systems and 

components as well as other systems and components 

important to safety. Fire protection systems should be 

capable of operating during normal power outage. The

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onsite emergency power sources and the electrical 

distribution circuits should have independence and 

testability to ensure performance of their safety 

-J functions assuming any single failure. 

d. The design of the facility should include 

provisions to protect against adverse effects that mighl 

result from operation or failure of the fire suppressior 

system. For example, collection systems should be 

provided for runoff water from the normal or abnormal 

flow of an automatic sprinkler system. 

e. The fire protection systems should be designed to 

withstand tornado conditions and the effects of earth. 

quakes and remain functional to the extent that suffici. 

ent protective and suppressive capabilities are main. 

tained to prevent uncontrolled release of radioactive 

materials as a result of fire. 

f. Criteria for fire protection equipment, systems, 

components, and programs should comply with the 

intent of applicable provisions of the National Fire 

Codes of the NFPA (Ref. 1). Fire protection appliances, 

equipment, and materials that have been examined b) 

and meet the standards of such nationally recognized 

testing organizations as UL and FM should be used. 

2. Building Construction and Facilities 

a. The fuel reprocessing plant should be designed ani 

constructed using building components of heat-resistan 

and noncombustible material wherever practicable, pai 

ticularly in locations vital to the functioning of confine 

ment barriers and systems. 

b. Where practicable, materials and equipmer 

designed for minimum fire potential should be selectei 

Structural members including walls, partitions, column 

beams, floors, and roofs should be of noncombustibli 

fire-resistive construction with fire-resistance ratini 

sufficient for protection against credible fire exposure 

c. Assuming failure of any fire suppression systel 

that is not designed as an essential item, the structur 

shell (and its supporting members) surrounding any an 

handling radioactive material, where the radioactiO 

material could be accidentally dispersed and cau 

exposure to either operating personnel or the publi 

should be designed with sufficient fire resistance for it 1 

remain standing and continue to act as a confinemei 

structure during any credible accident conditioi 

resulting from fires. Penetrations in this shell shou 

incorporate, as a minimum, equivalent protection again 

credible fire exposures. 

d. Suspended ceilings and their supports should be, 

noncombustible construction as listed by UL (Ref. 2). 

> FM (Ref. 3). Insulation- for pipes and ducts, sore

attenuating materials, and the adhesives used for each 

I should also be noncombustible. Concealed spaces should 

be devoid of comnbustibles. Materials used should have a 

rating of 25 or less with respect to flame spread, fuel 

contribution, and smoke development (Ref. 4). 

e. Exits should be strategically located to ensure that 

L radiation exposure of personnel will be minimal during 

evacuation through a confinement barrier in the event of 

Sa breach of processing equipment confinement resulting 

from fires and explosions. Such a barrier would be a 

partition separating two different air zones (Ref. 5). The 

* airflow through the barrier should be opposite to the 

- direction of exit travel. 

. f. Electrical wiring systems and their supporting 

members (i.e., conduits, trays, troughs, raceways, and 

distribution frames) servicing essential items should be 

protected against fire. Cable enclosures, fire stops at fire 

barrier walls, floors, and ceilings, and non-flame

propagating electrical insulation should be used in the 

design of electrical wiring systems to minimize the 

spread of fire. 

g. Structures, systems, equipment, and components 

in processing areas requiring hydraulic, lubricating, 

cooling, insulating, and processing fluids should be 

protected from fire and its spread by use of minimum 

volumes of such fluids, by use of fire-resistant fluids, by 

fire barrier isolation, by provision for automatic fire 

A suppression, and by installation of curbs, catch basins, or 

t other confinement designs that minimize the spread of 

- fluid leakage. 

h. Provision should be made for -protection, of the 

plant against lightning damage. 

it 

atd. i. Protective barriers should be provided around 

s, high-pressure or other potentially dangerous systems. 

re, 

gs 3. Ventilation Systems 

5. 

The ventilation systems should be designed to 

m withstand any credible fire and explosion and continue 

al to act as confinement barriers. Fire protection for 

-a ventilation systems is discussed in Regulatory Guide 

re 3.32 (Ref. 6). 

c, 4. Hot Ceils, Glove Boxes, Hoods, and Other Process 

to Enclosures 

nt 

ns a. Combustible materials should not be used in the 

Id construction of hot cells. Hot cells should contain the 

st minimum amount of combustibles consistent with 

operational requirements. Construction and processing 

materials should be selected that will not be degraded by 

of exposure to high-radiation fields or corrosive atmo

or spheres to the point where they will present a fire 

id hazard. Materials and equipment in a hot cell should not 

3.38-3

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be arranged in such a way as to contribute to the 

ignition or the spread of a fire or hinder the detection or 

suppression of a fire. 

b. Glove boxes and process enclosures should be 

provided with fire stops in connecting tunnels to prevent the spread of fire. The fire stops between enclosures 

should normally be closed. Where operations require that the fire stops be in the open position, they should 

be designed to close automatically upon operation of the 

fire detection system. Provision should also be made for manual operation of fire stops. Combustible materials 

that are an integral part of a glove box should be held to 

a minimum. 

c. The design of enclosures should be based on 

downdraft ventilation flow to minimize the spread of 

fire, Heat detectors and combustible gas and vapor detection meters should be provided on glove boxes or 

enclosures where fire or explosion hazards exist. 

Automatic fire suppression equipment should be 

provided in these boxes or enclosures. When automatic 

systems are not required, fire detectors should be installed and provisions made for manual fire 

suppression. 

d. Chemical fume or particulate exhaust hoods 

should be equipped with full-closing sashes and provided. with fire detectors. Provisions should be made for 

manual fire suppression where fire or explosion hazards 

exist. 

5. Sprinkler Systems 

a. Automatic water sprinkler coverage using com

ponents listed by UL (Ref. 7) or FM (Ref. 3) should be 

provided throughout the facility except in areas where 

nuclear criticality or other hazards specifically preclude its use. Nonaqueous systems using components listed by UL (Ref. 7) or FM (Ref. 3) should be used in areas not 

protected by automatic water sprinklers or for other, special applications (see regulatory position 6). 

b. Automatic water-type extinguishing systems Include wet-pipe, preaction sprinkler, open head deluge, water spray, and systems utilizing automatic "on-off" 

flow control. Selection of a specific type of system should take into account system characteristics such as 

speed of operation, ambient temperature, and required volume- and optimum use of water. 

c. Wet-pipe conventional automatic sprinklers should 

be used in nonprocess areas of the facility. 

d. Whern used in process areas, the sprinkler system selected should minimize the quantity of water used, the 

unintentional operation of sprinkler heads, the spread of 

contamination by water, the extent of cleanup operations, and the possibility of criticality.

6. Special Automatic Extinguishing Systems 

a. Areas not protected by automatic water sprinklers should be protected by some other fire suppression agents such as inert gas, carbon dioxide, high-expansion foam, or halogenated organic compounds. 

b. Selection of a carbon dioxide extinguishing system should take into account such considerations as type of 

fire hazard, protection of personnel, and process enclosure pressurization. 

c. Selection of a halogenated extinguishing system should take Into account such considerations as process enclosure pressurization, protection of personnel, type of fire hazard, adverse reaction with pyrophoric metals, and corrosive thermal decomposition products. 

d. For other special applications, consideration 

should be given to inert gas, dry chemical, high expansion foam, and "wet water" fire extinguishing 

systems. When dry chemical systems are used, consideration must be given to protect filters against fouling. 

7. Fire Protection Water Systems 

a. Potable and process water systems should be 

arranged so they can be shut down without affecting the 

water supply to the fire systems. Fire protection water 

supply and distribution systems required for essential 

item protection should be designed and constructed so 

that continuity of protection in the event of any credible accident conditions is ensured. 

b. The water supply for the permanent fire 

protection installation should have a minimum of two 

reliable, independent sources and sufficient capacity (based on the maximum water demand) for firefighting 

until other sources of water become available. Water 

-supplies containing salt or other materials deleterious to 

the fire protection systems should be avoided wherever 

possile. 

c. Water for firefighting and fire suppression systems 

should be furnished to the site by a loop distribution 

system encircling the site buildings. Hydrants served by this system should be strategically located around the 

loop. Valves or valve assemblies listed by UL (Ref. 7) or 

FM (Ref. 3) should be provided for proper sectional 

control of the loop. 

d. Fire water pumps should be equipped with 

automatic starting features and listed by UL (Ref. 7) or 

FM (Ref. 3) for fire service. Where water supply pressure 

is provided by pumps only, there should be a minimum 

of two pumps, at least one of which should be driven by 

nonelectrical means, preferably diesel engine. Emergency 

power should be supplied to an electric-driven fire pump

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in the event of failure of the normal power supply (sec 

regulatory position l.c). Multiple fire water pumps 

should be selected so that the maximum water demand 

for firefighting will be supplied with the lhgest pumI 

out of service. 

Audible alarms for pump startup and operation anc 

for power failure should be provided for the pumi 

system and arranged to sound in a constantly attende( 

location. A small pressurizing pump should be providec 

to automatically maintain the desired static pressure or 

the fire protection water supply system and minfllz4 

unnecessary operation of the fire water pumps. 

e. Water should be supplied to each water spra] 

extinguishing system from the water main loop arount 

the facility. A water spray system may be used for hea 

removal for the high-efficiency filtration.system servini 

as a final means of effluent cleaning for the ventilatioj 

systems. This water spray system should have 

dedicated water supply, in addition to the normal wate 

supply, sized to operate the system during a credible fir 

or explosion even if all other water supplies fail. 

f. Collection systems should be provided for runof 

water from firefighting activities or water breaks or leak 

in process areas. Nuclear criticality, confinemeni 

sampling, volume determination, and retrievability o 

liquids and solids should be considered in the design o 

collection systems. The size of the collection system fo 

> firefighting water should be based on the maximur, 

amount of water that could be used in fighting a credibl 

fire. 

8. Manual Firefighting Equipment 

a. Provision should be made for portable fir 

extinguishers listed by UL (Ref. 7) or FM (Ref. 3) an 

suitable for use on specific hazards that may b 

encountered. The number of fire extinguishers require 

should be determined considering the area an 

arrangement of the plant or occupancy, the severity c 

the hazards, the anticipated classes of fires, and th 

distances to be traveled to reach extinguishers. 

b. Standpipe and hose systems using pomponeni 

listed by UL (Ref. 7) or FM (Ref. 3) should be provide 

and Installed in both process and nonprocess area 

Standpipes should be so located that they are protecte 

against mechanical and fire damage. Hose outlets shoul 

be easily accessible. 

9. Fire Detection, Signal, and Alarm Systems 

a. Provision should be made for fire detection an 

alarm systems using components listed by UL (Ref. 7) 

FM (Ref. 3). These systems should consist of fu 

detectors, signaling devices, and audible and vLsu: 

indicators in a constantly attended location, as well as I

appropriate locations about the plant. A means should 

be provided to monitor the status and functioning of the 

I fire detection, signal, and alarm systems as well as other 

fire protection system components located throughout 

the plant. Provision should be made for periodic testing 

and checkout of these systems. 

b. A plant-wide public address and two-way corm

I munication system should be provided. 

I 

I c. Manual fire alarm stations should be installed 

• throughout the facility at readily accessible locations. 

These stations should be connected to the plant-wide 

alarm system. 

I d. Fires should be indicated audibly by alarms that 

t are set off by fire suppression and detection systems. 

g Each sprinkler system should be equipped with a flow 

i alarm on the plant-wide alarm system. 

I 

r e. Glove boxes and enclosures should be equipped 

ift fire and/or smoke detectors to provide both a local 

alarm and a zone and location signal on the plant-wide 

alarm system. 

s f. The Inlet duct to a multistage high-efficiency filter 

plenum serving as a final means of effluent cleaning for 

'f the ventilation systems should be provided with.heat and 

if smoke detectors' that actuate a local alarm and an 

cr automatic fire alarm station on the plant-wide alarm 

a system. 

10. Flammable Materials 

a. Special control should be exercised over the 

handling of flammable, toxic, and explosive gases, 

e chemicals, and materials admitted to or produced in 

d process areas. Solvents and other flammable liquids, 

e other than small quantities in use, should be stored in a 

d separate building or unexposed storage area. Safety cans 

d listed by UL (Ref. 8) or FM (Ref. 3) should be used for 

if flammable liquids. Covered noncombustible containers 

e listed by UL (Ref. 8) or FM (Ref. 3) should be provided 

for combustible wastes. 

ts b. Provisions should be made for isolation between 

ýd Incompatible chemicals, materials, and processes such as 

s. solvent extraction. 

d 

d c. Flammable and combustible materials should not 

be stored in finished product storage areas or shipping 

areas. 

11. Quality Assurance Program 

id 

or A quality assurance program should be established for 

re the design, construction, testing, operation, and 

&l maintenance of all structures, systems, equipment, and 

in components of fire protection systems in accordance 

3.38-5

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with the criteria in Appendix B, "Quality Assurance 

Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," of 10 CFR Part 50. Regulatory Guides 3.3 

(Ref. 9) and 3.21 (Ref. 10) describe, respectively, methods of complying with this regulation with regard 

to overall program requirements and requirements for 

protective coatings. 

12. Procedures, Organization, and Training 

a. Fire emergency procedures should be established 

for plant personnel. A plant fire protection organization should be trained and equipped to deal effectively with 

fire or explosion emergencies. Selected personnel should 

be specifically trained in firefighting techniques. Opera ting personnel and new employees should be periodically instructed in the proper use of plant firefighting equip

ment and emergency fire procedures. Decontamination 

procedures should be covered in training programs. Drills 

should be held periodically. 

h. Arrangements should be made with offslte fire 

departments for providing assistance to the plant fire 

protection organization in the event of an onsite fire. 

Offsite fire departments should be familiarized with 

plant emergency fire procedures, fire protection

organization, layout, and unusual hazards. Drills should 

be held periodically. 

c. An approved recorded watchman service, central 

station supervisory service, or constant occupancy of all 

important areas should be provided to maintain a 

satisfactory degree of surveillance of the property at all 

times. 

D. IMPLEMENTATION 

The purpose of this section is to provide information 

to applicants regarding the NRC staff's plans for using 

this regulatory guide. 

Except in those cases in which the applicant proposes 

to use an acceptable alternative method for complying 

with specific portions of the Commission's regulations, 

the methods described herein will be used In the 

evaluation of submittals for construction permit applica

tions docketed after March 1, 1977. If an applicant wishes to use this regulatory guide in developing 

submittals for an application docketed prior to March 1, 

1977, the pertinent portions of the application will be 

evaluated on the basis of this guide.

REFERENCES

I. National Fire Codes, National Fire Protection 

Association. Copies may be obtained from National 

Fire Protection Association International, 470 

Atlantic Avenue, Boston, Mass. 02210. 

2. Underwriters' Laboratories Building Materials List 

(latest edition). Copies may be obtained from Under

writers' Laboratories, Inc., 207 East, Ohio Street, 

Chicago, IM1. 60611. 

3. Factory Mutual Approval Guide (latest edition). 

Copies may be obtained from Factory Mutual 

Research Corporation, 1151 Boston-Providence Turn

pike, Norwood, Mass. 02062. 

4. ASTM E84-70, "Method of Test for Surface Burning 

Characteristics of Building Materials," American 

Society for Testing and Materials. Copies may be 

obtained from American Society for Testing and 

Materials, 1916 Race Street, Philadelphia, Pa. 19103. 

5. Regulatory Guide 3.18, "Confinement Barriers and 

Systems for Fuel Reprocessing Plants," US. Nuclear 

Regulatory Commission, Washington, D.C. 

. Regulatory Guide 3.32, "General Design Guide for

Ventilation Systems for Fuel Reprocessing Plants," 

US. Nuclear Regulatory Commission, Washington, D.C.

7. Underwriters' Laboratories Fire Protection Equip

ment List (latest edition). Copies may be obtained 

from Underwriters' Laboratories, Inc., 207 East Ohio 

Street, Chicago, Ill. 60611. 

8.: Underwriters' Laboratories Gas and Oil Equipment 

List (latest edition). Copies may be obtained from 

Underwriters' Laboratories, Inc., 207 East Ohio 

Street, Chicago, Ill. 60611. 

9. Regulatory Guide 3.3, "Quality Assurance Program Requirements for Fuel Reprocessing Plants and for 

Plutonium Processing and Fuel Fabrication Plants," 

U.S. Nuclear Regulatory Commission, Washington, 

D.C. 

10. Regulatory Guide 3.21, "Quality Assurance Require-' 

ments for Protective Coatings Applied to Fuel 

Reprocessing and to Plutonium Processing and Fuel 

Fabrication Plants," U.S. Nuclear Regulatory Corn

mission, Washington, D.C.

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