**\[DNFSB LETTERHEAD\]**

February 14, 2005

Mr. Paul M. Golan

Acting Assistant Secretary for

Environmental Management

U.S. Department of Energy

1000 Independence Avenue, SW

Washington, DC 20585-0113

Dear Mr. Golan:

In November 2004, the staff of the Defense Nuclear Facilities Safety
Board (Board) reviewed procedures for responding to fires at the
Plutonium Finishing Plant (PFP) at the Hanford Site. PFP is in
transition from nuclear materials stabilization operations to
deactivation and decommissioning (D&D), although packaged plutonium
metal and oxide remain stored in its vaults. The Board's staff reviewed
PFP procedures for fire response to determine whether they would
adequately address a scenario similar to the May 2003 fire in Glovebox 8
in Building 371 at the Rocky Flats Environmental Technology Site
(RFETS). The staff's conclusions are summarized in the enclosed report.
Based upon the staffs review, the Board concludes that PFP's procedures
for fire response do not reflect the lessons learned from the fire at
RFETS and are not optimized for the conditions likely to be encountered
in a D&D environment.

The Board's staff also found that the Department of Energy (DOE) has
promulgated guidance that could help ensure a safe and effective
response to a fire during D&D work, but that this guidance does not
appear to have been implemented effectively at PFP. The Board notes that
DOE's letter of February 3, 2004, which provided an interim response to
the Board's letter on the Glovebox 8 fire at RFETS, committed to
conducting an independent study of fires involving radioactive materials
across the defense nuclear complex. The Board understands that this
effort was not successful. The Board believes it would be worthwhile to
renew this initiative, with a focus on evaluating prefire planning and
fire response procedures/training for facilities that are either
transitioning to or undergoing D&D. It would also be advisable for DOE
to consider whether improved guidance or a technical standard is needed
to better address fire protection in such facilities.

The Board requests, pursuant to 42 U.S.C. § 2286b(d), that DOE brief the
Board within 60 days of receipt of this letter on its response to the
issues and suggestions raised herein and in the enclosed staff report.
This briefing should also address the failings in feedback and
improvement which led to the incomplete implementation of lessons
learned from the RFETS fire.

Sincerely,

***John T. Conway***

***Chairman***

c: Mr. Mark B. Whitaker, Jr.

Mr. Keith A. Klein

Enclosure

**DEFENSE NUCLEAR FACILITIES SAFETY BOARD**

**Staff Issue Report**

February 2, 2005

**MEMORANDUM FOR:** J. Kent Fortenberry, Technical Director

**FROM:** H. W. Massie

**SUBJECT:** Fire Response Procedures, Hanford Plutonium Finishing Plant

This report summarizes a review by members of the staff of the Defense
Nuclear Facilities Safety Board (Board) of procedures for responding to
fires at the Plutonium Finishing Plant (PFP) at the Hanford Site. This
review was performed during a visit to the Hanford Site in November
2004. PFP is in transition from nuclear materials stabilization
operations to deactivation and decommissioning (D&D), although packaged
plutonium metal and oxide remain stored in its vaults. This report also
summarizes a review of Department of Energy (DOE) directives and
standards relevant to fire response for facilities in transition to or
undergoing D&D, performed subsequent to the staffs visit to the Hanford
Site.

**Background.** On December 2, 2003, the Board issued a letter to the
Secretary of Energy summarizing issues associated with the May 2003 fire
in Glovebox 8 in Building 371 at the Rocky Flats Environmental
Technology Site (RFETS). In addition to identifying broad deficiencies
in the implementation of Integrated Safety Management for D&D work at
RFETS, the Board's letter and the enclosed staff reports noted
deficiencies regarding preparedness for the fire and the D&D workers'
response to the fire. The prefire plan for a glovebox fire focused on
such hazards as burning plutonium metal instead of the potential for a
significant fire involving combustible wastes from glovebox
decontamination work. The D&D workers engaged in a concerted effort to
extinguish the fire, in violation of site procedures and training
dictating that workers in air-fed anticontamination suits ("bubble
suits") must evacuate the scene of a fire. In response to the Board's
letter, the DOE pursued extensive corrective actions at RFETS, including
improvements in prefire planning and retraining of D&D workers in the
proper response to fires.

**PFP Procedures for Fire Response.** In light of the issues identified
at RFETS, the Board's staff reviewed the following PFP procedures to
evaluate whether PFP was prepared to respond properly to a fire similar
to the Glovebox 8 fire at RFETS:

-   ZCR-005, *Fire Alarm/Fire/Explosion,* Revision B, Change 0, dated
    August 20, 2003

-   ZCR-015, *Glovebox Fire,* Revision A, Change 3, dated April 26, 2000

-   *Operator Training Material for Use of Bayonet Fire Extinguishers,*
    Course \# 202351**,** Revision 1

-   *Firefighting in Radiologically Posted Areas,* provided in
    HNF-IP-0939, Hanford Fire Department Internal Policy, dated October
    17, 2002*,* Revision 8

The first three procedures appear to apply primarily to bulk plutonium
operations, such as stabilization of plutonium metal and oxide, and have
not been revised to account for the hazards associated with D&D
activities. While the first two of the above procedures are clear in
stating that if personnel see an immediate danger to life or health,
they must evacuate the area and notify the Hanford Fire Department and
the Building Emergency Director, neither encompasses the case of burning
plutonium-contaminated waste materials, such as those involved in the
Glovebox 8 fire at RFETS. There are also discussions of response to
burning plutonium metal and use of a "bayonet"-type fire extinguisher to
penetrate a glove of the glovebox to extinguish a plutonium fire which
do not apply to D&D activities. Glovebox procedure ZCR-015 needs to be
revised to address fire scenarios for D&D activities within gloveboxes.
This would include topics such as emphasizing the need for workers to
evacuate the immediate area and call the fire department, before
engaging in any other activities, in response to a real or suspected
fire. It should also explain under what conditions a worker can use a
fire extinguisher. The PFP procedures for fire response do not
specifically address the proper response by D&D workers in air-fed
anticontamination suits or other unique personal protective equipment.

PFP procedures should explain that these D&D workers must immediately
evacuate the area and may only use fire extinguishers to extinguish
clothing or personal protective equipment, or to assist in the safe
evacuation of the work area.

The fourth procedure above is for the firefighters and addresses a
variety of topics related to fighting fires in radiological areas. This
procedure, like the others, does not address unique conditions that the
fire department may encounter in a D&D environment, due to the changing
conditions in the facility. Some of the topics that need to be addressed
include details of the incident command structure (who is in charge) and
how information such as the potential for criticality is communicated to
the incident commander. One of the lessons learned at RFETS was that the
use of water by the fire department to extinguish a fire can be
expedited by establishing ahead of time whether criticality is a concern
for a particular area of the building or glovebox, based upon valid
estimates of fissile material loading.

**Standards for Fire Response.** The staff reviewed DOE directives and
standards to assess whether they adequately address fire response for
facilities in transition to or undergoing decommissioning. The
introduction to DOE Standard 1120-98, *Integration of Environment,
Safety, and Health into Facility Disposition Activities,* states that it
"provides guidance for integrating and enhancing worker, public, and
environmental protection during facility disposition activities." There
is no specific discussion of fire protection issues, even though fire
remains a significant hazard through all phases of a facility's life
cycle.

DOE Order 420.1A**,** *Facility Safety,* does not directly address D&D
facilities. However, DOE Guide G-420.1/B-0**,** *Implementation Guide
for Use with DOE Orders 420.I and 440.I, Fire Safety Program,* provides
useful guidance regarding the need for personnel from the fire
department and the fire protection engineering staff to perform routine
inspection of facilities undergoing D&D, and for fire department
personnel to tour D&D facilities to remain familiar with existing
conditions and revalidate prefire plans. The guide also suggests
conducting drills and training exercises at D&D facilities at a
frequency commensurate with the fire risks and complexity of the
facility. This guidance appears sound. The staff's observations at RFETS
and PFP, however, indicate that this guidance is not being implemented
effectively. More specific guidance or more prescriptive requirements
may be appropriate to ensure that defense nuclear facilities are better
prepared for the potential of a fire during D&D.

**Conclusions.** Based upon this review, the Board's staff concludes
that revising fire response procedures and prefire planning at PFP to
reflect the lessons learned at RFETS would improve the ability of D&D
workers and firefighting personnel to respond safely and effectively to
a fire similar to the Glovebox 8 fire at RFETS.

In a letter dated February 3, 2004, responding to the Board's letter on
the Glovebox 8 fire at RFETS, DOE discussed interim corrective actions
being pursued at RFETS and committed to conducting an independent study
of fires involving radioactive materials across the defense nuclear
complex. The Board's staff understands that this effort was not
successful. Based on its observations at PFP, the staff believes it
would be worthwhile to renew this initiative, with a focus on evaluating
whether prefire planning, fire response procedures, and training have
been updated to reflect facility conditions and hazards associated with
D&D work for facilities either transitioning to or undergoing D&D. It
would also be advisable for DOE to evaluate the need for improved
guidance or a technical standard addressing fire protection in such
facilities.