DEFENSE NUCLEAR FACILITIES SAFETY BOARD

November 4, 1994

MEMORANDUM FOR:               G. W. Cunningham, Technical Director

COPIES:                       Board Members

FROM:                         J. Blackman

SUBJECT:                      Los Alamos National Laboratory (LANL) - Review of Chemistry
                              and Metallurgy Research (CMR) Facility Hot Cell Upgrades and
                              the Fire Resistant Pit (FRP) Test Program

1.    Purpose:  This trip report documents a Defense Nuclear Facilities Safety
      Board (DNFSB) technical staff and outside experts' review of hot cell
      upgrades being installed in Wing 9 of the CMR at LANL.  These upgrades are
      being performed to support the FRP Test Program.  This review was performed
      by staff members J. Blackman, A. Hadjian, A. Jordan, C. Keilers and
      R. Zavadoski and by outside experts W. Hall, J. Stevenson and N. Vaidya on
      August 24-25, 1994.

2.    Summary:  The DNFSB staff believes that both the process by which the CMR
      Wing 9 Seismic Upgrade Project has been implemented and the technical
      execution are not technically satisfactory.  Fundamentally, the project has
      not been conceived and implemented based on a thorough understanding of the
      potential hazards posed by the FRP experiment or other future CMR missions. 
      It is uncertain that the project will achieve its stated objective,
      containing hazardous materials in the hot cells, unless these and other
      planned building structural and ventilation upgrades are designed and
      installed in a technically adequate manner.

3.    Background:  CMR is a large, 550,000 square foot facility, primarily used
      for analytical chemistry, chemistry research, and actinide metallurgy.  Most
      of CMR was built in 1952. The Department of Energy (DOE) and LANL have
      recognized that CMR needed to be either upgraded or replaced; current plans
      are to upgrade the facility to extend its life.

      In 1993, LANL contracted with Merrick & Company (Merrick) to design
      structural and ventilation system upgrades that will ensure hazardous
      material confinement within the building envelope following a design-basis
      event.  EQE International (EQE) is assisting Merrick in this effort. 
      Ventilation system upgrades, including a new standby electrical system, are
      also planned as part of a multiphase upgrade program.  The Wing 9 Seismic
      Upgrade Project, however, is being funded and implemented separately from
      the CMR Upgrade Project.

4.    Discussion:  LANL briefed the DNFSB staff on the planned fire resistant pit
      experiments and conducted a tour of Wing 9.  Merrick and EQE then described
      the hot cell seismic upgrades to be installed in support of the experiments
      and the other building seismic upgrades now in conceptual design. 

      The DNFSB staff believes that while the hot cell upgrades being installed
      will improve the seismic resistance of Wing 9, the upgrades as currently
      conceived are not adequate to satisfactorily mitigate potential hazards
      posed by the FRP experiment.  Modifications to the safety-related
      structures, systems and components (SSC), necessary to minimize and mitigate
      the consequences of an accident, such as the ventilation system, need to be
      evaluated  before the FRP experiments can begin.  Detailed comments are
      provided below:

      a.    Design Process:

            1.    According to DOE Order 5480.23, a "Safety Analysis means a
                  documented process: (1) to provide systematic identification of
                  hazards within a given DOE operation; (2) to describe and analyze
                  the adequacy of measures taken to eliminate, control, or mitigate
                  identified hazards; and (3) to analyze and evaluate potential
                  accidents and their associated risks."  It is clear that the "graded
                  safety analysis report" that LANL has subcontracted was not being
                  used as DOE Order 5480.23 requires.

                  LANL is still reviewing a draft "graded" safety analysis report
                  (SAR) on the experiments and does not plan to complete the review
                  and submit it to DOE before December 1994.  However, the hot cell
                  seismic upgrades have already been developed, and designed, and are
                  being installed before the hazards, potential accident consequences,
                  and possible accident mitigation systems involved with the FRP
                  experiments are established.  For example, it is unclear whether the
                  seismic performance goals chosen are appropriate or how they could
                  be chosen before first identifying the hazards and consequences.  

                  The DNFSB staff has not had an opportunity to review the graded SAR. 
                  However, based on the potential consequences of an unmitigated
                  radionuclide release during an accident, consideration of the use of
                  more stringent seismic performance goals than those currently
                  selected may be prudent.  Such goals would consider the full range
                  of future mission hazards and the anticipated extension of the CMR
                  service life, possibly another 20 years.  At the very least, the
                  hazards need to be understood to validate the current choice of
                  performance goals.

            2.    Based on discussions with LANL regarding responsibilities and
                  accountability, it is unclear who at LANL is responsible and
                  accountable for assuring that the hot cell seismic upgrades will
                  perform their stated functions.  Other than budgetary
                  responsibility, LANL management responsibility for these upgrades is
                  diffuse.

            3.    The design review process used by LANL to review the hot cell
                  seismic upgrade design was weak and ineffective.  Based on DNFSB
                  staff review and discussions with LANL during the presentations
                  concerning the technical substance of a design review, the DNFSB
                  staff observed that the comments generated by LANL personnel were
                  essentially non-technical in nature.  They did not focus on whether
                  or not the facility upgrade was adequate to prevent initiation of
                  collapse mechanisms, as well as minimize and mitigate the FRP
                  hazards and consequences.  In particular, the comments of the LANL
                  seismic reviewer merely requested that the comments previously
                  prepared by the DOE reviewer be resolved.   This suggests that LANL
                  has not provided technical oversight of its contractors.

            4.    Technical inconsistencies exist between what is actually being done
                  in the CMR building upgrade design and what is described in program
                  documents, and also between key program documents themselves. 
                  Furthermore, the quality assurance requirements imposed on Merrick
                  and EQE for these upgrades are not adequately specified in program
                  documents.  Reference to DOE Order 5700.6C, Quality Assurance is not
                  sufficient to specify implementing requirements for a quality
                  assurance program.

            5.    The furnace that will be used to heat the pit has been procured and
                  has been installed in a mockup.  When questioned as to what codes
                  and standards were used in the design and fabrication of the
                  furnace, LANL could not immediately identify any.  It was merely
                  suggested that the codes and standards that the manufacturer
                  normally used might be sufficient.

      b.          Structural Upgrade Evaluation:  The stated function of the hot cell
                  seismic upgrades is to contain the material within the hot cells
                  after a design basis event.  However, numerous technical issues
                  discussed below suggest that this design objective may not be
                  achieved due to potential deficiencies in the evaluation.  Detailed
                  concerns are as follows:

            1.    The upgrades currently being installed will only remedy deficiencies
                  of the hot cell support structure.  Other identified structural
                  deficiencies in Wing 9 will not be remedied until Phase II, which
                  has not been funded, is complete.  Therefore, the FRP experiments
                  are planned to proceed without remediation of other known structural
                  deficiencies.  While representatives from the design contractor
                  stated that the other structural deficiencies will not affect the
                  integrity of the hot cell, the validity of this conclusion is not
                  apparent, since the lateral resistance of the hot cell support
                  system is dependent on the integrity of the adjoining structural
                  components.

            2.    The seismic evaluation of Wing 9 was performed assuming that the
                  structure is fixed at the foundation elevation.  Soil-structure
                  interaction analysis has not been included based on the assumption
                  that its effect on the building is minimal.  In attempting to
                  validate this assumption, an approximate analysis was performed that
                  only included horizontal motion effects--rocking and vertical motion
                  were not included.  Since horizontal and rocking modes are usually
                  coupled, neglecting rocking is not demonstrably conservative.

                  Furthermore, since certain parameters of rocking and horizontal
                  stiffnesses and damping values are functions of different powers of
                  a characteristic dimension of the foundation, the assumption that
                  the actual footing geometry is equivalent to one large foundation is
                  erroneous.  Characteristic parameters of rocking and translation
                  stiffness and damping would be larger or smaller when considering
                  the actual footing geometry.

            3.    Wing 9 of the CMR Building consists of two structures, Lot 1 and 2,
                  separated by a three inch isolation joint that extends for the
                  entire height of the building sections.  The structures have been
                  modeled as two separate entities, and potential interaction effects,
                  such as pounding, have not been considered.  Examination of the
                  joint revealed that the filler material is a wood fiber that can be
                  easily deformed with a pocket knife.  However, it has been the
                  experience of the DNFSB staff that at high strains, similar
                  materials begin to exhibit high stiffness.  If, during a seismic
                  event, the lateral displacements of Lots 1 and 2 were to be
                  sufficient to compress the joint filler material to high strain
                  levels, significant interaction between Lots 1 and 2 might occur.

            4.    It is not apparent that the margins of safety reported during the
                  presentation are valid.  The hot cell seismic upgrades, as well as
                  all of the CMR facility structural upgrades, are based on
                  conformance with a combination of provisions from various codes and
                  standards (i.e., using ACI-349 load combinations with ACI-318 or
                  Uniform Building Code (UBC-91) capacities).   If only one of the
                  referenced codes were used to evaluate design margins, then the
                  consistency of the results would be established.  However, since
                  this approach could not be followed, it is not obvious that the mix
                  of various code provisions forms a consistent bases for margin
                  evaluation.  Therefore, the DNFSB staff believes that it is prudent
                  for knowledgeable individuals, thoroughly familiar with the three
                  codes used, evaluate the consistency of the code provisions used in
                  this design upgrade to insure that valid margins of safety result.

      c.          Safety System Upgrade Evaluation:

            1.    The ventilation system that serves CMR, including the Wing 9 hot
                  cells, is not designed for design accident conditions.  For example,
                  there is no emergency power for the ventilation systems, including
                  those in Wing 9.  The DNFSB staff believes that any systematic
                  engineering approach to mitigate the FRP experiment and other
                  mission hazards, must consider the necessary role played by the
                  ventilation system in hazardous material confinement in design basis
                  accident scenarios.

            2.    The structural evaluation of the building does not include the
                  effect of possible severing of distribution systems that span from
                  lot to lot, nor does it account for potential loss of safety
                  systems, such as ventilation, that are needed to ensure hazardous
                  material confinement.  Since the building and essential safety
                  systems may not withstand a severe earthquake, the hot cell upgrades
                  may not be able to perform their intended function due to these
                  neglected interaction effects.

5.    Future Planned Activities:  The DNFSB staff and its outside experts intend
      to review the graded SAR for the FRP experiments when it becomes available
      to determine if the seismic performance goals have been appropriately
      chosen.  The staff will also closely follow progress of the CMR structural
      upgrade project.