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should be revised to address emergency response drills on fires. Item 6 provided approval to
discontinue the current 6 month and 12 month full-flow surveillance of the automatic and
manual deluge systems to prevent further degradation of the HEPA filters. Item 8 indicated that
the issue of degraded HEPA filters should be evaluated in the updated Building 991 draft Final
Safety Analysis Report. These items have been addressed by RMRS and by this update to the
Building 991 Complex FSAR. Full-flow deluge system testing for the Building 991 Complex
filter deluge systems was discontinued on April 30, 1998 in accordance with memorandum
FPH-058-98. This addressed Item 6. Items 3, 4, and 8 were addressed by memorandum
FPH-069-98. For Item 8 specifically, this FSAR does not credit the Building 991 or
Building 985 exhaust filtration systems specifically in the accident analysis, but does indicate
that the Building 991 system is a defense-in-depth system and should be maintained in
accordance with the requirements specified in the TSRs (AC 5.5). The Building 985 exhaust
filtration system is not considered a defense-in-depth system. The automatic sprinkler system is
credited in the accident analysis (LCO 3.1) but the plenum deluge system is specifically
excluded from the portion of the automatic sprinkler system being credited (Reference
Chapter 5).
USQD-RFP-97.0106-CAS (Ref. 30) evaluated a non-compliance discovery issue and
JCO concerning Site pressure relief devices and the overall Pressure Safety Program. The Site,
over the past ten years has not met the requirements of HSP 1 1.03. HSP 11.03 references Rocky
Flats Environmental Technology Site (RFETS) Standard SM-137 which establishes the
replacement frequency for pressure relief devices (PRDs) and other maintenance requirements
JCO-RI?P-98.0288-KGH (Ref. 19) was initiated to provide temporary authorization to conduct
continued operations at the Site while an acknowledged USQ condition exists. The JCO serves
as part of the facility AB until compliance is restored, or until authorized otherwise by
Kaiser-Hill. The USQD evaluation resulted in a positive USQ but indicated that the various
failure mechanisms and the resultant release mechanisms associated with PRD failures are not
significant in terms of overall public risk. The USQD concluded that spills, explosions, fires,
and compromises to vital safety system operability considered in the existing ABS for the
various facilities are either of substantially higher probability or consequences than those
represented by potential failure of pressure relief devices or pressure vessels to the extent that the
overall public risk from such failures can be considered to be within present facility safety
envelopes. The primary concern from pressure safety feature malfunction is the impact on
worker safety. Required actions are specified in the JCO that will remove the hazard where
possible, and also serve to heighten personnel awareness of the issue. This JCO was approved
by DOE on May 20, 1998 with additional technical direction. The approval allowed continued
Site operations with an acknowledged USQ issue. Compensatory measures included (a) annual
inclusion of Pressure Safety in Monthly Safety Meeting Kit Topics, (b) identification of any
currently pressurized systems that are candidates for depressurization and rendering them so, and
(c) expansion of the Job Hazard Analysis (JHA) process as it is used in the IWCP. The use of
pressure relief devices and the stored energy in pressure systems is evaluated in this FSAR in
NSTR-011-98 (Ref. 3) and identified no concerns that would result in a release of radioactiw
materials.
Revision 1
Sephmber 1999
1-21 Building 991 Complex FS *R ,