One of the topics that keeps popping up in the ongoing coverage of U.S. nuclear power plants concerns how the reactors stay safe if a fire occurs. As simple as the concept is, there’s enough going on under the “fire protection” umbrella that perhaps a little explanation is in order.
Let’s start with the bottom line — every U.S. nuclear power plant complies with the relevant NRC requirements for protecting its reactor from fire hazards. There may be confusion over the “exemptions” sometimes issued to some plants under the NRC’s least flexible fire protection approach, called Appendix R.
Appendix R is effectively a one-size-fits-all approach for plants that are in fact custom-built projects. Newer plants tend to be built closer to Appendix R requirements, while older plants are more likely to have difficulty meeting the goals.
The NRC knew from the start that the appendix wouldn’t apply to every part of every plant, so plants were going to apply for exemptions where Appendix R didn’t make sense. The NRC has a well-established process for reviewing exemption requests, which must have solid technical support in order to get approved. The federal court covering southern New York recently upheld the agency’s process — in fact, the court’s ruling even noted the NRC rejects exemption requests if they’re not justified.
You can see an everyday example of exemptions at the DMV, when it comes to having “acceptable vision” for a drivers license exam. Since not everyone’s vision falls in the acceptable range, DMV regulations allow people to wear glasses or contacts. This can be considered an “exemption” from uncorrected vision requirements that’s still acceptable and compliant with the law.
Even if a plant has exemptions from parts of Appendix R, the NRC is satisfied that plant has an appropriate overall fire protection program.
Another problem is confusion between the exemptions and separate “compensatory measures” plants will put in place for specific issues until permanent solutions are in place. Exemptions are permanent in any case, and as we noted, plants must justify their requests with solid data. Compensatory measures, while they can be acceptable for extended periods of time, are not a basis for exemptions. As with exemptions, however, the NRC only accepts compensatory measures if they will provide acceptable fire protection capabilities.
Compensatory measures also have an everyday example on the roads — when a traffic light is malfunctioning, a police officer normally directs traffic at the intersection. Instead of the city closing the intersection until the traffic lights are fixed, officials compensate for the degraded traffic light in an acceptable way.
Bottom line? The fix for an exemption or a compensatory measure has to be safe. Otherwise it won’t fly with the NRC.
The NRC will soon start receiving and reviewing applications for plants to switch to an updated fire protection standard, called NFPA 805, which could be described as a way to customize fire protection to differing plant situations based on risk. For example, the risk of fire in an otherwise empty room with concrete walls with electrical cable trays is less than for the same room with a barrel of lubricating oil stored in a corner. Under this new standard, plants use advanced fire analysis tools to determine where their fire protection resources are most needed. It has been tested at two plants with pilot projects.
When plants transition to NFPA 805, their analyses can uncover new fire protection issues, and the NRC ensures those issues are appropriately handled as they’re identified. All new issues are accounted for with compensatory measures, and will either be fixed by a change to the plant or evaluated as part of the transition to NFPA 805. Since switching to the new standard is optional, the NRC uses its “enforcement discretion” in deciding whether to take action against plants that find new issues during the switch. That decision is made after the issues are identified and compensatory measures are put in place.
There is no question that a fire at a nuclear plant can be serious business. The NRC takes it very seriously. In reading stories about the NRC’s fire safety program, it is important to remember that not all fires carry the same risk, and the risk depends on the size and location of a fire. And do not forget that each plant has its own fire department and trained local firefighters to call on for additional help.
Going forward, the NRC Commissioners who set policy for the NRC recently voted on a proposal to be sure the NRC staff has the resources to more efficiently review NFPA 805 applications.
“I think long-term this is a good program,” Chairman Gregory Jackzo told a reporter recently. “We’ve seen from the pilot programs that it really enhances safety. And that’s what this is all about, is making sure we’re doing everything we can to have the right program for safety when it comes to fire protection.”
The NRC’s work on fire protection, as with all its efforts in overseeing U.S. nuclear power plants, is meeting its goal — ensuring the public remains safe.
Director, Office of Public Affairs