**\[DNFSB LETTERHEAD\]**

June 24, 2008

The Honorable James A. Rispoli

Assistant Secretary for Environmental Management

1000 Independence Avenue, SW

Washington, DC 20585-0113

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 FilterPlenum
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.

Sincerely,

***A. J. Eggenberger***

***Chairman***

cc: Mr. Glenn S. Podonsky

Mr. Richard H. Lagdon, Jr.

Mr. Mark B. Whitaker, Jr.

Mr. Robert J. McMorland

[Enclosure](../AttachedFile/fb08u24a_att.pdf)