Fire Protection at Shearon Harris: Other than being unsafe and illegal, no problems at all

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1 Fire Protection at Shearon Harris: Other than being unsafe and illegal, no problems at all David Lochbaum Director, Nuclear Safety Project March 22, 2007

2 Defense-in-depth Nuclear plants feature numerous redundant safety systems so that one broken pump or busted pipe won t trigger a meltdown.

3 On March 22,1975, a worker using a lit candle to check for air leaks in the cable spreading room at the Browns Ferry nuclear plant in Alabama started a fire that disabled all of the emergency cooling systems on Unit 1 and most of those systems on Unit 2. Defense on fire

4 Defense on fire One guy with a candle disabled dozens of pumps and nearly a dozen relief valves. Defense-in-depth got very, very shallow.

5 Defense on fire That fire did and other fires could disable all of the safety systems needed to prevent meltdown. At Browns Ferry, heroic operator manual actions averted that disaster.

6 Fire Hazard After Browns Ferry, NRC revised its regulations to require plants to be designed such that a fire in one area does not disable all of the equipment needed to safely shut down the nuclear reactor.

7 Fire Regulations To comply with the post-browns Ferry regulations, the NRC requires a safe shutdown analysis (SSA) that steps through each fire area in the plant one at a time assuming that all equipment in that fire area is fire damaged. The analysis must show that enough undamaged equipment outside that single fire area remains to allow the reactor to be safety shut down and cooled. Fire areas must be separated by: 20 feet separation with no intervening combustibles and installed fire detection and fire suppression systems 3-hour rated fire barrier 1-hour rated fire barrier with installed fire detection and fire suppression systems

8 Fire Regulations At Harris, Progress Energy had substituted unapproved (and thus illegal) operator manual actions for non-conforming, unreliable fire barriers. Even though heroic operator manual actions saved the day at Browns Ferry, NRC s post-browns Ferry (and pre-shearon Harris) fire protection regulations did not permit operator manual actions. When caught, Progress Energy opted for restoring compliance with National Fire Protection Association (NFPA) Standard 805.

9 Fire Standard Fire sub-standard National Fire Protection Association standard 805 reports where manual operator actions are relied on to provide the primary means of recovery in lieu of providing fire protection features, risk may be increased. [1] [1] NRC Presentation The Use of Manual Operator Actions For Achieving and Maintaining Fire Safe Shutdown, NRC/NRR/Regions I, II, III, IV Quarterly Workshop, November 14, Slide 9

10 Browns Ferry then, Shearon Harris now Recent inspection [sic] have found that some licensee s [sic] have taken manual actions to the extreme interpretation such that no wrap is provided with operators solely relying on responding to mal-operations after they occur in III.G.2 fire areas. This condition is similar to the condition Browns Ferry was in prior to the 1975 fire. [1] [1] NRC Presentation The Use of Manual Operator Actions For Achieving and Maintaining Fire Safe Shutdown, NRC/NRR/Regions I, II, III, IV Quarterly Workshop, November 14, Slide 10

11 Browns Ferry then, Shearon Harris now On January 29, 2007, the NRC approved its post- 9/11 security regulations. The NRC revised its security regulations assuming that if any one attacked a nuclear plant from the air, fire protection features and operator manual actions would protect the public. Slide 11

12 Browns Ferry then, Shearon Harris now Shearon Harris is not in compliance with fire protection regulations established as a result of the Browns Ferry fire. The safety and security threat Shearon Harris faces is greater than the safety threat Browns Ferry faced. NRC dismisses the aircraft hazard part of the security threat based on fire protection regulations that are not being met. NRC is betting with your lives that terrorists attacking Shearon Harris will be no more successful than one guy with one candle at Browns Ferry. Slide 12

13 Ignorance of the law is not an excuse Progress Energy s slide 3 from its August 11, 2005, presentation to the NRC speaks volumes. Actions may speak louder than words, but sometimes inaction speaks the loudest. Slide 13

14 Ignorance by the law is apparently an excuse Per page 49 of the transcript of NRC s November 13, 2006, public meeting, NRC knows Progress is not in compliance with the regulations but intentionally looks the other way. The NRC enables, not regulates. Slide 14

15 What can you do? Hope for continued good luck. It s been more luck than Progress non-compliance and NRC s nonchalance protecting you so far. Contact your elected officials and urge them to pressure the NRC to enforce federal safety regulations. It makes no sense for NRC inspectors to walk by violation after violation looking for some aspect of the fire protection program that s compliant. Hope for continued good luck. It may be all the protection you get. Slide 15

DRAFT NFPA 805 TRANSITION PILOT PLANT OBSERVATION GUIDANCE

Revision D January 14, 2005 DRAFT NFPA 805 TRANSITION PILOT PLANT OBSERVATION GUIDANCE I. INTRODUCTION The Commission s requirements for fire protection of nuclear power plants allow licensees to voluntarily