Manual Shutdown of U.S. Reactors on Fire May Be Allowed

WASHINGTON, DC, August 3, 2004 (ENS) - The Nuclear Regulatory Commission is poised to allow manual shutdown of nuclear power plants in the event of fire, instead of insisting that plant operators protect electric cabling with physical fire barriers as required by law. The manual strategy allows operators to dispatch station personnel throughout a reactor facility to turn valves, pull circuit breakers, or flip switches to shut down the reactor.

According to documents obtained by the Nuclear Information and Resource Service (NIRS) under the Freedom of Information Act, many reactor operators already have adopted manual action strategies that are unapproved by the commission, unanalyzed for reactor and worker safety, and illegal under federal law.

Current federal law requires that nuclear power station operators physically protect emergency backup electrical systems - power, control and instrument cables - used to remotely shut down the reactor from the control room in case of fire.


Turkey Point Nuclear Power Plant, 25 south of Miami, Florida, uses manual actions rather than fire barriers. (Photo courtesy NRC)
The Nuclear Regulatory Commission (NRC) states that nuclear power plants will encounter "three or four significant fires over their operating lifetime," in its 1999 report "Severe Accident Risks; An Assessment for Five U.S. Nuclear Power Plants."

The regulation at issue requires the physical fire protection of electrical cabling to be independently tested to American Society Test and Measure standards for rating as qualified fire barriers.

These fire protection systems are to be designed, installed and maintained to resist the passage of flame and hot gas to protect the encased electrical cables from excessive temperatures for either:

But documents obtained by NIRS show that instead of requiring nuclear utilities to upgrade and maintain physical fire protection features at reactors, the commission and the nuclear industry association, the Nuclear Energy Institute, are seeking to abandon the requirement by substituting “operator manual actions.”

“The Nuclear Regulatory Commission is lowering the fire protection bar at nuclear power plants to bring its regulations into compliance with widespread nuclear industry violations,” said Paul Gunter, director of NIRS' Reactor Watchdog Project.

“The federal retreat from fire code enforcement simultaneously raises the risk to public health, safety and security around the nation’s nuclear power stations,” Gunter warned.

The fire code was put in place for U.S. nuclear power stations following the fire at Alabama’s Browns Ferry nuclear power station on March 22, 1975 to ensure that no single fire could destroy a control room’s ability to safely and remotely shut down the reactor.

The Browns Ferry fire was started by an employee using a candle flame to check for air leaks along electrical cable trays under the reactor control room, initially igniting polyurethane foam insulating material. The fire burned out of control for seven and half hours destroying over 1,600 electrical cables including 628 safety related cable systems.


Browns Ferry Nuclear Power Plant (Photo courtesy TVA)
"The Browns Ferry fire demonstrated that a high number of circuit failures can occur in a relatively short period of time, in this case within 15 minutes from the ignition of the foam material," wrote Patrick Madden of the NRC in a July 28, 1998 report.

In an assessment of the fire in 1976, the Union of Concerned Scientists wrote that it demonstrated that the federal government’s non-regulation of fire protection requirements at nuclear power stations was a principle contributing factor to the seriousness of the fire. Station nuclear engineers privately confided a catastrophic release of radiation was avoided only by “sheer luck,” the UCS report said.

In 1992, the majority of the U.S. nuclear power industry, 79 out of 104 nuclear plants, was found to be using “inoperable” Thermo-Lag 330 fire barriers in an unsuccessful effort to protect the reactor safe shutdown systems from fire damage.

Other nuclear power station operators were found to be in violation of the alternate requirement for 20 feet of separation between backup safe shutdown wiring.

By 1998, NRC began issuing a series of Confirmatory Orders requiring licensees to replace the non-functioning Thermo-Lag fire barriers and restore fire barrier operability at nuclear power stations. Through a set of Confirmatory Orders licensees responded that they would come into compliance with the law by restoring operability to the fire barriers.

Between 2000 and 2004, renewed NRC fire inspections discovered that a large number of nuclear power station operators never fulfilled their obligations to restore fire barrier operability or achieve cable separation.

While a few NRC inspectors had, on a case-by-case basis, provided approval for a small number of simple operator manual actions through the regulatory exemption process, the industry had adopted a wholesale application of manual actions that never sought to get NRC approval nor completed adequate safety reviews, NIRS found.

One station operator was discovered with over 100 unapproved and illegal manual actions.

NRC identified that licensees had taken manual actions to the “extreme interpretation” resulting in a significant increase in risk of reactor core damage in the event of fire.

One NRC official, John Hannon, wrote in a November 2001 letter to Alex Marion of the Nuclear Energy Institute, “This condition is similar to the condition Browns Ferry was in prior to the 1975 fire.” The letter was disclosed as part of NIRS' Freedom of Information Act request.

The NRC has found that the violations are so numerous throughout the industry that an enforcement effort “creates a prospect of significant resource expenditure without clear safety benefits."

In its June 2003 document, "Rulemaking Plan On Post-Fire Operator Manual Actions," the NRC wrote, "Licensees faced with enforcement actions might flood NRC with exemption or deviation requests, which would divert NRC resources from more significant safety issues and may not result in any net safety improvement if the operator manual actions are determined to be acceptable.”

“NRC is abandoning front line fire protection features at nuclear power stations and falling back to what should be considered desperate last ditch efforts, just to provide industry with a less costly compliance strategy,” responded Gunter.

But the industry sees the new approach to fire protection as a step in the right direction. "The NRC and the industry agree that, in general, regulations should become more risk-informed and performance-based," the NEI says in a July 2003 statement.

"A risk-informed and performance-based approach to fire safety in a nuclear power plant would include an assessment of the actual risks in various areas - the amount of combustible material, potential ignition sources, whether fire suppression systems have been installed and so on," the NEI says.


Oyster Creek Nuclear Power Plant nine miles south of Toms River, New Jersey has been issued a Compliance Order to install fire barriers, but has not complied, according to documents discovered as part of NIRS' Freedom of Information Act request. (Photo courtesy NRC)
"It also would consider the relative importance of the systems and components in that area to achieving and maintaining safe shutdown of the plant. Fire protection measures would then be based on a more realistic assessment of the actual fire hazard than is assumed in existing requirements," the industry association says.

“There is no assurance that workers sent into the reactor to manually operate safety equipment won’t encounter hazardous conditions, such as fire, smoke, radiation, or even terrorists, that prevent them from accomplishing vital tasks,” Gunter said. “That’s why qualified fire barriers for electrical cable protection and separation were mandated to provide adequate safe shutdown margins in the first place."

But the NEI says the "automatic" fire barrier regulation creates problems for power plant operators. "If something triggers the system falsely, there is a potential for electrical equipment to be damaged by the suppression system when no fire threat exists." So some companies have asked the NRC’s permission to use manually activated suppression in areas where electrical equipment is located, and some 1,200 exemptions have been granted.

The industry complains that the three hour and one hour fire barrier ratings are "somewhat arbitrary."

"They apply equally to all areas where fire barriers are used, regardless of the actual fire hazard in a given area. In practice, however, the NRC has granted limited exemptions for plant areas where the fire hazard is low and where features of the plant would make it extremely difficult to install a fire barrier," the NEI says.

NIRS is not the only organization concerned about the commission's move to allow manual shut downs in case of fire. The Project On Government Oversight, a Washington, DC organization which has investigated safety and security issues at nuclear power plants since the mid-1990s, also opposes the NRC's draft revision to the fire protection regulations. "The NRC's acquiescence to the nuclear power industry is extremely distressing," this group wrote in January.

The agency struggled with the non-compliant and non-cooperating nuclear industry until 1998 before issuing Orders to restore compliance, wrote NIRS in public comments to the commission on the "Draft Criteria for Determining Feasibility of Manual Actions to Achieve Post-Fire Safe Shutdown.”

"The industry blatantly failed to comply with agency Orders and further violated fire code law by instituting illegal operator manual actions without NRC review," wrote NIRS. "These compounded violations didn’t start turning up until the Triennial Fire Protection Inspections were instituted in 2000."


Comanche Peak Nuclear Power Plant four miles north of Glen Rose, Texas, was issued a Compliance Order for fire barriers that it has yet to comply with. (Photo courtesy NRC)
NRC manager Sunil Weerakkody documents that after years of noncompliance, the industry and the commission agreed to forgive and forget the fire protection violations. "NRC and nuclear industry agreed to suspend debate over past history and focus on regulatory actions that would permit these actions provided their feasibility could be assured," he stated for the record on November 12, 2003.

So, today the NRC proposes to provide nuclear power plant licensees with an option to voluntarily abandon physical fire protection requirements and adopt an alternate set of criteria that would bring “feasible” manual actions into interim “compliance.”

Through subsequent rulemaking, the NRC proposes to codify the interim criteria into law, deeming industry designated manual actions not only legal but providing the equivalent level of safety as independently tested and qualified fire barriers, sprinkler and smoke detection systems and designed physical separation for reactor shutdown electrical systems.

But NIRS contends this decision "is extremely disturbing and does not warrant the trust of the public and the fire protection community."

In public comments to the Nuclear Regulatory Commission Gunter writes, "NIRS sternly advises NRC not to attempt to 'suspend' enforcement of Confirmatory Orders along as part of the so-called 'historical debate' over inadequate fire protection and industry non-cooperation to remediate these dangerous inadequacies. In our view to do so is a serious dereliction of the agency’s mandate and duty to protect the public health and safety."