DEFENSE NUCLEAR FACILITIES SAFETY BOARD

                                                   April 22, 1993


MEMORANDUM FOR:     Technical Director

COPY TO:            Board Members

FROM:               R. E. Kasdorf, Program Manager
                    Rocky Flats Plant

SUBJECT:            Rocky Flats Plant - Trip Report on the Review
                    of Building 371 Seismic and Systems Design
                    Bases, Special Nuclear Material Storage, and
                    Systematic Evaluation Program Status 

1. Purpose:  This memorandum provides a summary report of a
   March 23 - 25, 1993 trip by the DNFSB staff and outside
   experts (Haltiwanger, Stevenson, and Rizzo) to review
   Building 371 seismic issues, Special Nuclear Material (SNM)
   storage, and the status of the Systematic Evaluation Program
   (SEP) at the Rocky Flats Plant (RFP).

2. Summary:
   
   a.  Geotechnical data and the structural analyses for
   Building 371 were reviewed.  The geotechnical data for the
   building appeared to be adequate.  The analyses for the
   building appear to indicate that the building may be
   structurally adequate for the design basis earthquake at RFP. 
   However, neither EG&G nor DOE-RFO had a sufficient
   understanding to discuss the details of the site conditions
   or the analyses performed by the original architect-engineer. 
   It is particularly noted that the foundation design is not
   understood by DOE-RFO or EG&G.  There was not enough
   information that had been reviewed and understood by EG&G or
   DOE-RFO to make an independent assessment of the adequacy of
   the structural analyses. 

   b.  During a tour of the Building 371 it was noted that a
   drainage system below the sub-basement portion of the
   building appeared to be partially blocked, indicating that
   the drain had not been adequately maintained.  This system
   appears to provide a dewatering function; perhaps to minimize
   hydrostatic and corrosion effects on the structure.  The
   drain system would also serve to reduce bouyancy forces on
   the structure in conjunction with an earthquake.  EG&G
   indicated they would take action to ensure proper drainage
   from this system.

   c.  The design documentation for three vital safety systems
   (fire protection, emergency power and criticality alarm) was
   reviewed.  These systems do not appear to have been
   seismically designed.  EG&G has not performed a detailed
   review of these systems to determine their seismic
   qualification.  However, based on outside expert observations
   during a tour of the building, it would appear that these
   systems could be made seismically adequate with a minimum of
   hardware modifications.

   d. EG&G presented a discussion on SNM storage at RFP.  EG&G
   considered further review was necessary to address how safety
   envelope considerations are covered during vault inspections
   and surveillances; and how material is controlled to ensure
   safety analysis assumptions are still valid when material is
   moved.

   e. EG&G presented the status of the SEP program at RFP. 
   Pilot applications to demonstrate a revised SEP process is
   ongoing.  It is anticipated that DOE will propose changes to
   the Implementation Plan for Recommendation 90-5 in the near
   future consistent with the revised process.

3. Background:    Building 371 is one of five buildings that
   compose the Plutonium Recovery and Waste Treatment complex at
   the RFP.  It first began limited operations in 1981.  Scrap
   materials containing plutonium were processed through
   dissolution, ion exchange, and precipitation processes to
   form plutonium buttons.  The facility also cleaned and
   prepared plutonium-contaminated material for discard.  These
   processes were shut down because the processing rates were
   unsatisfactory, and the remotely-operated equipment was
   difficult to operate and maintain.  DOE has recently
   indicated that this building will be the primary building
   used for consolidation of SNM at the RFP.  The building is
   currently being prepared to receive SNM from Building 991. 


4. Discussion:  The following discussion summarizes the material
   presented by EG&G and DOE-RFO and discussed with the DNFSB
   staff and outside experts:

   a. EG&G presented information concerning Building 371,
      including layout of the building, overview of the safety
      analysis, geotechnical data, structural and safety system
      design; SNM storage at RFP; and the status of SEP.  The
      detailed agenda and list of attendees are available
      separately.

   b. Geotechnical data and the structural analyses for Building
      371 were reviewed.  The geotechnical data for the building
      appeared to be adequate.  The analyses for the building
      appear to indicate that the building may be structurally
      adequate for the design basis earthquake at RFP.  However,
      neither EG&G nor DOE-RFO had a sufficient understanding to
      discuss the details of the site conditions or the analyses
      performed by the original architect-engineer, C. H. Braun
      and Company.  It is particularly noted that the foundation
      design is not understood by DOE-RFO or EG&G.  There was
      not enough information that had been reviewed and
      understood by EG&G or DOE-RFO to make an independent
      assessment of the adequacy of the structural analyses.  To
      understand the adequacy of the structural analyses would
      require someone with the appropriate technical background
      to review the design analyses to better understand such
      items as the modelling used for both static and dynamic
      analyses, the bases for the input parameters, the design
      features of the building, applied loadings and primary
      load-carrying members.  EG&G (Berman) agreed a better
      understanding of the previous analyses was needed,
      especially as this facility begins to store large
      quantities of weapons grade plutonium and highly enriched
      uranium being removed from other RFP buildings.    

   c. During a tour of the building it was noted that a drainage
      system below the sub-basement portion of the building
      appeared to be partially blocked, indicating that the
      drain had not been adequately maintained.  This system
      appears to provide a dewatering function; perhaps to
      minimize hydrostatic and corrosion effects on the
      structure.  The construction drawings reviewed indicated
      that the floors are mounted on drilled reinforced concrete
      caissons socketed into bedrock.  By design, it appears a
      gap (typically between one and two feet) was maintained
      between the excavation bottom and the floor slabs for all
      basement floor levels to allow for expansive heave of the
      foundation soils.
      
      EG&G did not know the impact on the structural capability
      of the building from hydrostatic pressure, buoyancy forces
      or material degradation which could arise from inadequate
      drainage from the drainage system.  EG&G noted that the
      outlet of the drainage system was now considered a
      wetlands area so maintenance could be hampered.  EG&G
      (Berman) indicated they would take action to ensure that
      the system is draining properly and to determine if the
      drainage system should be considered a safety system with
      all the appropriate surveillance and maintenance
      requirements.  Also, if such action would be needed, a
      review of the drainage system outfall would be performed
      to determine if this is a federal wetland area and if any
      special permitting actions are necessary to adequately
      maintain the drainage system.

   d. EG&G indicated that the fire protection system, emergency
      power system, and the criticality alarm system should be
      seismically qualified.  However, based on review of the
      design documentation provided by EG&G and a physical
      walkdown these systems do not appear to have been
      seismically designed.  Additionally, EG&G had not found
      any analyses for qualification to the appropriate
      standards (e.g., ANSI 8-3 for criticality).  EG&G has not
      yet performed a detailed review of these systems, as well
      as other vital safety systems not specifically discussed,
      sufficient to determine their seismic qualification. 
      However, based on outside expert observations during a
      tour of the building it would appear that these systems
      could be made to be seismically adequate with a minimum of
      hardware modifications using procedures similar to those
      developed for the K-reactor at the Savannah River Site.

   e. There were no personnel in the EG&G engineering group who
      were specialized in seismic engineering.  At other DOE
      sites (e.g., SRS, Hanford), the operating contractors have
      such technical expertise.  EG&G (Berman) indicated they
      needed to give consideration to development of a group in
      engineering dedicated to seismic engineering.    

   f. During a tour of Building 371 the following items were
      noted:
 
      1. Numerous pieces of equipment (e.g., ladders, carts,
         welding equipment) that had not been adequately secured
         were observed through out the building.  Industrial
         safety practices per OSHA requirements would call for
         equipment to be secured to preclude its inadvertent
         movement (which may occur during an earthquake or
         during routine work if bumped into by mistake) from
         becoming a safety hazard or affecting vital safety
         systems.  

      2. Criticality detectors were tied down with cloth/canvas
         straps.  This type of tie down which depends on
         friction has not performed satisfactorily during
         earthquakes in the past.  Components of vital safety
         systems should be held down with positive lateral and
         vertical restraints.

   g. EG&G presented a discussion on SNM storage at RFP.  Most
      of this discussion was classified since it presented
      specific amounts, forms, and types of SNM in specific
      building locations.  The information presented identified
      that ultimately almost all SNM on site would eventually
      (over a ten to twenty year period) be moved to Building
      371 for interim storage.  During this discussion, two
      items were raised which EG&G (Berman) considered required
      further review.  These were:

      1. Considering most storage locations are only opened and
         inspected for safeguards and security purposes, how are
         safety envelope considerations covered by safeguards
         and security procedures for vault inspections and
         surveillances?  These procedures likely do not include
         inspection provisions for design items typically
         referred to as "in service inspection" that might
         impact safety envelope considerations.  For example,
         safeguards and security inspections may only look for
         holes or cracks that would allow access by someone and
         would not be concerned with water in-leakage (e.g., as
         previously seen in Building 991) or structural cracking
         (smaller than a certain size for safeguards and
         security considerations) which may result in a larger
         pathway for material release than assumed in current
         safety analyses.

      2. There was not a clear understanding of how material
         (amount, forms, and locations) is controlled in the
         vaults to be consistent with safety analysis
         assumptions.  Also, it was not clear whether the safety
         analysis group would be included in appropriate reviews
         to ensure planned material moves were within the
         facilities' safety bases.

      EG&G noted that a study of the aircraft crash hazard had
      been recently produced and that this study demonstrated
      that the probability of radiological release in excess of
      specified limits is below 10-6/year.  Based on this study,
      EG&G does not consider aircraft crash as a design basis. 
      The DNFSB outside experts expressed an interest in
      reviewing this study to verify its conclusions and to
      determine if might serve as an example for other DOE
      sights for the evaluation of the aircraft crash hazard.

   h. EG&G presented the current status of the SEP program at
      RFP.  A report on completion of Phase 1 of the DOE
      Implementation Plan for Board Recommendation 90-5 has been
      issued.  Sixteen SEP evaluation topics have been developed
      and topic evaluation plans have been issued.  Phase 2
      evaluations in Buildings 559 and 707 have been started but
      are not yet complete.  Changes to the SEP process have
      been proposed to DOE to reflect the new mission of RFP. 
      Two pilot applications - seismic structural and Zone II
      confinement ventilation - to demonstrate the new process
      are ongoing in Building 707.  It is anticipated that DOE
      will propose changes to the Implementation Plan for
      Recommendation 90-5 in the near future.

5. Conclusions:   This was the first staff and outside expert
   review of Building 371 seismic issues and specific plans for
   SNM storage at RFP.  Based on the items discussed above,
   follow-up reviews of these matters are planned by the staff
   later in 1993.
   The change in mission of RFP, including a recent announcement
   that Building 707 will no longer be considered a contingency
   building for weapons production, makes it necessary for DOE
   to revise the Implementation Plan for Recommendation 90-5 on
   SEP.  The staff will follow DOE's preparation of this
   revision.