June 24, 2008
The Honorable James A. Rispoli
Assistant Secretary for Environmental Management
Dear Mr. Rispoli:
The staff of the Defense Nuclear Facilities Safety Board (Board) recently reviewed Authorization Basis Amendment Request (ABAR) 24590-WTP-SE-ENS-06-0199, Revision 1, Tailoring of DOE-STD-1066-97, Fire Protection Design Criteria, Section 14, Nuclear Filter Plenum Protection Based on Hazard Analysis. The request was submitted by Bechtel National Incorporated (BNI) to modify fire safety design requirements for the Waste Treatment and Immobilization Plant (WTP) for protection of confinement ventilation systems from the effects of a fire. The intent of the request was to provide an alternative means of protecting the final exhaust high efficiency particulate air (HEPA) filters of the confinement ventilation systems in a manner equivalent to that of the features prescribed in Department of Energy (DOE) Standard 1066. The Board notes that DOE-STD-1066 permits the use of equivalent (or superior) methods of fire protection for nuclear final filter plenums. However, the Board's staff identified significant issues pertaining to the proposed tailoring of the standard, adherence to higher-tier policies, and the underlying technical justification for the request, as detailed in the enclosed report. The following issues were of particular concern:
The ABAR proposed tailoring of DOE-STD-1066 that relied substantially on I3NI's Integrated Safety Management (ISM) process for final design decisions regarding fire protection for the final exhaust HEPA filters, instead of providing a clear request for use of alternative design features. This approach could have comprised the effectiveness and timeliness of DOE'S oversight of the design.
The fire protection posture described in the ABAR and supporting documentation may not have provided adequate protection of the safety-class confinement
ventilation systems for the High Level Waste and Pretreatment facilities as specified by DOE Order 420.1 B, Facility Safety, and Ventilation System Evaluation Guidance , for Safety-Related and Non-Safety-Related Systems.
The request proposed use of computational technical analyses to justify the elimination of design features prescribed by DOE-STD-1066 (e.g., ember screens and prefilters). Formal validation of the technical adequacy of such analyses would be required. An initial assessment by the Board's staff of the technical analyses in support of the ABAR revealed discrepancies and errors.
The ABAR addressed gaps identified during the evaluation of the confinement ventilation systems for WTP performed according to Ventilation System Evaluation Guidance for Safety-Related and Non-Safety-Related Systems. The involvement of the Program Secretarial Office and Central Technical Authority in review and approval of an ABAR involving ventilation system design needs to be clarified to ensure the intent of the Implementation Plan for the Defense Nuclear Facilities Safety Board's Recommendation 2004-2, Active Confinement Systems, regarding resolution of any gaps is met.
The Board notes that Department of Energy-Office of River Protection (DOE-ORP) has recently rejected the ABAR due to its weak technical basis, failure to clearly identify equivalent fire protection features, confusing methodology, and prolonged schedule for completion of supporting technical analyses. DOE-ORP, as part of the rejection, provided direction to BNI to resubmit the proposal.
The Board observes that this particular issue may be an example of the concern with the WTP project's Decision to Deviate process noted in the Deputy Assistant Secretary for Safety Management and Operations - Environmental Management memorandum of April 29, 2008 to the Manager, DOE-ORP; specifically, the delay in resolution of safety concerns resulting in cost and schedule risks.
The enclosed report, prepared by the Board's staff, is provided for your information and use as appropriate in resolution of this issue.
A. J. Eggenberger
cc: Mr. Glenn S. Podonsky
Mr. Richard H. Lagdon, Jr.
Mr. Mark B. Whitaker, Jr.
Mr. Robert J. McMorland