Exemption Chap. II - Nevada U12u

Ni H NE Me™) Department of Energy A VA National Nuclear Security Administration Washington, DC 20585 IAPR 17 2012 MEMORANDUM FOR THE NEVADA SITE OFFICE MANAGER FROM: DONALD L. COOK DEPUTY ADMINISTRATOR FOR DEFENSE PROG: SUBJECT: Approval of the Request for Exemption from Automatic Suppression Requirements in the DOE F acility Safety Order for U12u Underground at the Nevada National Security Site REFERENCES: (1) Memorandum, S. Mellington to D. Cook, Request for Permanent Exemption from the Department of Energy (DOE) O 420.1B Requirement to Provide Automatic F, ire Suppression in the U12u Underground, dated August 8, 2011 I approve the subject exemption requested in Reference 1, based on evaluation by my staff in the Office of Nuclear Safety and Governance (NA-171). As required by the Department of Energy Order 420.1B (DOE O 420.1B), Facility Safety, comments were solicited from the Office of Health, Safety and Security (HSS); no objections were noted. Additionally, the Central Technical Authority has concurred since this is a radiological facility. CIRCUMSTANCES DOE O 420.1B, Chapter II, J 3.c (4) requires automatic suppression throughout facilities where the fire loss potential exceeds limits defined by DOE. However, the cost to install automatic suppression, water supplies and drains at U12u Underground at the Nevada National Security Site (NNSS) far exceeds the dollar value of the facility. SAFETY ASSURANCE NA-171 staff evaluated the request in accordance with procedures in DOE O 251.1C, Departmental Directives Program, and concluded that a combination of fire detection, fire alarm, grade-level exits, and administrative measures help to ensure the safety of workers at U12u. Operating conditions for U12u include limited access to the facility. ® Printed with soy ink on recycled paper APPROVAL CRITERIA DOE O 251.1C allows exemptions to be granted only if the following criteria are met: TERMS AND CONDITIONS a) [it] is not prohibited by law; i Section 5.b.2 of DOE O 420.1B identifies a responsibility of the DOE Secretarial Officers to review and approve requests for exemptions from requirements of the b) would not present an undue risk to public heal Order. facility workers, or security; and th and safety, the environment, U12u will have appropriate physical and administrative features which minimize risk to the workers, public, environment, facility and security from potential fires. is warranted under the circumstances. In the current stage of the project (construction), the cost to be fully compliant with the Order exceeds the replacement cost of Security Administration has balanced priorities of automatic suppression does not significantly the facility. The National Nuclear and determined that the addition increase safety of the worker or public health and safety. The exemption shall remain valid for the life of the current mission of the U12u tunnel. Changes to mission invalidate the exemption and require a new request. Prior to commencing operations at U12u, the following terms and conditions of approval shall be met: 1. The Nevada Site Office (NSO) must verify that the |fire detection and alarm system with local and remote annunciations in U12u complies with the National Fire Alarm Code (NFPA 72). NSO will verify that issues pertaining to emergency lighting illumination (as identified in the Fire Hazards Analysis) are addressed.

NNSS will document facility-specific fire prevention controls in the facility fire protection program. This includes controls for hot ork, housekeeping, storage and use of flammable and combustible materials, and control of electrical sources. A firefighting pre-plan detailing a baseline firefighting approach or plan of attack shall be documented. The contractor equivalency request for the Life Safety Code (NFPA 101) shall be approved with all NSO review or rejection comments satisfactorily addressed. A control to maintain facility occupancy levels at less than or equal to 50 personnel shall be implemented. If you have any questions regarding this approval, please contact Mr. Jim McConnell at (202) 586-4379 or have your staff contact Ms. Sharon Steele at (202) 586-9554. cc: D. Nichols, NA-SH-1 K. Keilholtz, NA-10.2 C. Deeney, NA-11 J. McConnell, NA-17 J. Blackburn, HS-32 J. Bisker, HS-32 Docketing Clerk, HS