**\[DNFSB LETTERHEAD\]**

February 4, 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:

Enclosed is a report detailing observations of members of the staff of
the Defense Nuclear Facilities Safety Board (Board) concerning fire
protection for the Hanford Waste Treatment Plant. These observations
were developed through document reviews and discussions with
representatives of the Office of River Protection (ORP) and Bechtel
National Incorporated (BNI) on November 16-18 and December 20-23, 2004.

In general, ORP and BNI personnel recognize the need for follow-up
actions that would address the issues noted by the Board's staff. A
detailed discussion of these issues is provided in the enclosed report,
which is forwarded for your information and use as appropriate.

Sincerely,

***John T. Conway***

***Chairman***

c: Mr. Roy J. Schepens

Mr. Mark B. Whitaker, Jr.

Enclosure

**DEFENSE NUCLEAR FACILITIES SAFETY BOARD**

**Staff Issue Report**

January 13, 2005

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

**COPIES:** Board Members

**FROM:** C. March

**SUBJECT:** Review of Fire Protection, Hanford Waste Treatment Plant

This report documents a review of fire protection for the Waste
Treatment Plant (WTP) at the Hanford Site, conducted November 16-18,
2004, and follow-on teleconferences conducted on December 20 and 23,
2004. Members of the staff of the Defense Nuclear Facilities Safety
Board (Board) discussions with personnel from the Department of Energy's
(DOE's) Office of River Protection (ORP) and Bechtel National
Incorporated (BNI) to conduct this review.

**Purpose.** The purpose of the staffs site visit was to review the
current state of fire protection at WTP facilities and receive an update
on the status of open fire protection issues. During the visit, the
Board's staff observed the initial fire protection system installations
and discussed the status of the pending structural steel fire resistance
coatings with the installation contractor. The staff also reviewed the
Preliminary Fire Hazards Analyzes (PFHA), International Building Code
Evaluations, and Life Safety Code Evaluations, as well as the status of
other specific fire protection issues.

**Observations.** The following issues were discussed during the staffs
visit and will require follow-on action as noted.

*Status of Design of Structural Fire Resistance Coatings*―BNI has
prepared preliminary design drawings identifying the structural steel
requiring fire resistance ratings, based on the requirements of the
International Building Code (IBC), 2000 edition, and DOE Standard
1066-97, *Fire Protection Design Criteria*. Three types of coatings
(intumescent, high-density cementitious, and low-density cementitious)
and rated walls will be used in various areas, depending on cost and the
impact resistance needed for the coatings.

All of the primary structural steel for the Pre-Treat Facility will be
protected in accordance with the requirements of the IBC, given the size
and building code hazard classification of the building. Much of the
primary steel in the high-level waste and low-activity waste
vitrification facilities will be protected according to the requirements
for fire area separations in DOE Standard 1066-97; exceptions are the
roof and isolated areas of the other floors, where no fire area
separations are required. The excepted areas are allowed since the IBC
requires no steel ratings after application of IBC Section 503.1.2,
given the size and building code hazard classification of the building.
Some isolated primary steel in the Analytical Laboratory Facility (LAB)
will be protected in accordance with the requirements for fire area
separations in DOE Standard 1066-97. Other areas of the LAB will not be
protected since the IBC requires no steel ratings for these areas given
the size and building code hazard classification of the building.

BNI has provided drawings showing the extent of the structural steel
fire resistance ratings based on BNI's qualitative analysis. The staff's
preliminary review of the areas that will not require structural steel
protection revealed that the lack of protection for many of these areas
is justified. BNI has agreed to furnish additional documentation on the
basis for exempting specific areas from protection. The Board's staff is
continuing to review the drawings provided by BNI.

*Status of Installation of Structural Steel Fire Resistance
Coatings*―BNI recently contracted with Clayton Coatings, Incorporated to
install the structural steel fire resistance coatings. The contractor is
mobilizing and outfitting a temporary building where intumescent
coatings will be shop applied to the steel requiring intumescent
coatings prior to erection. The contractor is also preparing to start
coating of the erected steel. When asked about the ability to install
the coatings on the already erected steel, representatives of Clayton
Coatings explained that there were no areas in which the required
coatings could not be applied, although some areas could be difficult
given the equipment already installed.

*Discussions with Hanford Fire Department*―The Hanford Fire Department
(HFD) provides fire suppression services for WTP. The firefighters
conduct frequent familiarization tours of WTP to remain aware of
changing conditions. The current HFD Baseline Needs Assessment (BNA)
recommends construction of a new fire station near WTP to provide
adequate long-term response for the site, anticipating future closings
of HFD facilities as the Hanford Site undergoes decommissioning and
demolition work. This new fire station is not planned as part of the WTP
project. While existing response requirements are being met, future
reductions may challenge the HFD's ability to respond promptly to
emergencies at WTP. Given the location and nature of the hazards
involved, mutual aid from nearby municipal fire departments would be of
little value. The HFD is planning to update the BNA in 2005 and will
revisit the need for a new fire station. The staff will continue to
follow the implementation of the BNA's recommendations.

*Other Discussions*―ORP and BNI addressed a series of questions
resulting from the staff's review of the Preliminary Fire Hazards
Analyzes, the International Building Code Evaluations, and the Life
Safety Code Evaluations. All the staff's questions were addressed during
the review. Two questions remain open and will require further
information from DOE and BNI:

-   The staff questioned BNI's building code hazard classification of
    ceric nitrate (used in decontamination of the high-level waste glass
    canisters) as a less hazardous Class 1 oxidizer instead of a more
    conservative Class 2. Based on the research conducted by Hughes
    Associates, Incorporated after the fire at the Rocky Flats
    Environmental Technology Site in May 2003, the Board's staff
    believed this material might qualify as a Class 2 oxidizer.
    Subsequent to the staffs visit, BNI provided additional information
    on the classification of the ceric nitrate. Based on this
    information and discussions during a teleconference held on December
    20, 2004, the staff now agrees that the ceric nitrate in solution
    with 0.5 molar nitric acid, as stored and used in decontamination of
    the high-level waste canisters, is properly classified as a Class 1
    oxidizer. In accordance with the Rocky Flats fire investigation,
    however, the PFHA needs to be updated to reflect the hazard that can
    result from contact of the 0.5 molar ceric nitrate solution with
    organic materials and to incorporate appropriate safety controls.

-   The WTP PFHAs state that all electrical cabling is required to meet
    the flame-testing requirements of Institute of Electrical and
    Electronics Engineers (IEEE) Standard 383-1971, *Standard for Type
    Test of Class IE Electric Cables, Field Splices, and Connections for
    Nuclear Power Generating Stations,* and IEEE Standard 1202-1991,
    *Standard for Flame Testing of Cables for Use in Cable Tray in
    Industrial and Commercial Occupancies,* as well as Underwriters
    Laboratory (UL) standards, as applicable. During the visit, BNI
    informed the staff that some specialty tray cables for WTP may not
    be compliant with the requirements of these two IEEE standards,
    although they will at least be UL listed for cable tray use. All
    important-to-safety cabling will be rated in accordance with the two
    IEEE standards. During a conference call on December 23, 2004, BNI
    confirmed that specifications for all non-important-to-safety tray
    cables will require IEEE Standard 1202 qualification.