Scott Burnell
Public Affairs Officer
This week, the NRC took enforcement action against Duke Energy Carolinas LLC for failing to meet an important deadline in improving its fire safety program at the Oconee nuclear plant in
South Carolina. In a Confirmatory Order, the agency set a new timeline
for Duke to make the necessary changes, including interim milestones
that will each result in safety enhancements as Oconee completes the
process.
Fire
safety is an important and evergreen topic when discussing the safety
of U.S. nuclear power plants. NRC regulations include two approaches to
fire protection and the issue is easily misunderstood or misrepresented,
so it benefits from a refresher on everything that fits under the “fire
protection” umbrella.
Let’s
start with the bottom line — every U.S. nuclear power plant meets the
relevant NRC requirements for protecting its reactor from fire hazards.
Even if a plant has an “exemption” from a part of the NRC’s
least-flexible fire protection approach, called Appendix R, that plant
can still shut down safely in case of a fire.
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 specific mandates.
When
it was issued, he NRC knew that the appendix wouldn’t apply to every
part of every plant, so plants would 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 be approved. When the federal court covering southern New York
upheld the agency’s process, the ruling even noted the NRC rejects
exemption requests if they’re not justified.
You
can see an everyday example of exemptions when you take an eye exam to
get a driver’s license. Since not everyone’s vision falls in the
acceptable range, 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 Appendix R exemptions, the NRC inspects the plant’s
overall fire protection program to ensure it maintains safety.
Exemptions
are sometimes confused with 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 NRC will not accept any fix for an exemption or a compensatory measure unless it’s safe.
Oconee
is switching to the second approach, an updated fire protection
standard called NFPA 805. You can think of this standard as a way for
plants to customize their fire protection based on risk information. 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. Oconee was one of two plants
testing the transition as pilot projects.
The
NRC is currently evaluating applications from several plants to switch
to the NFPA 805 standard. 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.
Also, each plant has its own fire department and trained local
firefighters to call on for additional help.
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.
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