**\[DOE LETTERHEAD\]**

May 21, 2004

The Honorable John T. Conway

Chairman

Defense Nuclear Facilities Safety Board

625 Indiana Avenue, NW, Suite 700

Washington, DC 20004-2901

Dear Mr. Chairman:

The purpose of this letter is to provide a response to concerns
identified by your letter of March 23, 2004. The Defense Nuclear
Facilities Safety Board (DNFSB) asked how the Department of Energy (DOE)
will ensure the Bechtel National, Inc. (BNI) proposed methodology for
developing requirements for fire resistance for structural steel used in
Waste Treatment and Immobilization Plant (WTP) facilities receives
adequate review and comment through a peer review process, consistent
with the process that would be expected of any consensus code
requirement. The DNFSB further requested DOE to discuss why the proposed
methodology should be used in lieu of recognized methods already in use
in the fire protection and structural engineering communities, and
address any potential structural or safety impacts on the WTP
facilities.

This letter and the enclosed response address the DNFSB questions. As
noted in the DNFSB's letter, the BNI methodology for justifying a
reduction in fire resistance ratings of structural steel was still
evolving when the DNFSB letter was issued. As discussed in the enclosed
response, a revised methodology has been proposed that is significantly
different than the methodology previously discussed with DNFSB staff.
Specifically, BNI does not intend to use the performance-based approach
of performing heat transfer analyses coupled with limiting temperature
criteria from British Standard BS 5950-8:2003, *Structural use of
steelwork in building*, to determine the response of structural columns
to fire effects. Instead, BNI will use qualitative analyses to determine
the adequate protection requirements set and controls. BNI believes that
the structural steel elements in the WTP process buildings may be
adequately protected from postulated fire events by the existing
automatic fire suppression system (wet pipe sprinkler system) and the
installation of additional sprinkler heads located to protect the lower
portions of structural steel columns from the effects of postulated
worst-case fires. However, the potential need for fire-resistance
coating will be evaluated as part of the equivalency approach. The
qualitative analyses will include consideration of room heights,
sprinkler actuation set points, and multiple fire magnitudes. The
project Preliminary Fire Hazard Analysis reports will be revised
accordingly. This approach for protecting WTP structural steel does not
involve the development of an ad hoc fire protection code or standard.
Rather, the equivalency provisions of the International Building Code,
2000 Edition, and DOE Standard DOE-STD-1066-97 will be used.

DOE will retain the services of an independent technical expert
knowledgeable of the building code, National Fire Protection Association
standards, and DOE requirements to perform an independent technical
review of the BNI analyses and conclusions. The independent technical
review will assess the use of active systems and passive systems. From
this information and the revised BNI equivalency methodology, DOE will
determine the structural steel fireproofing requirements for the
W\'I\'P. The results of this review will be provided to the DNFSB.

Thank you for meeting with us on May 18. I realize that the Board has
continuing concerns regarding the WTP and we have scheduled a follow-on
meeting on June 2. As a result, we may need to provide refinements to
this response.

If you have further questions, please call me at (202) 586-7709 or Ms.
Patrice Bubar, Deputy Assistant Secretary for Integrated Safety
Management and Operations Oversight, at (202) 586-5151.

Sincerely,

***Jessie Hill Roberson***

***Assistant Secretary for***

***Environmental Management***

[Enclosure](../TB04Y21D.pdf):

Response to DNFSB Letter