NPP Fire Codes: Containment Penetrations and Electrical Ducts Temperature Limits

[Atomfritz]

There are many piping and electrical penetrations into the drywell and probably some into the torus as well. I am assuming those penetrations are sealed with a flexable material that has a maximum temperature limit, hence the maximum temp. rating of containment. May we assume that with no power, therefore no cooling of containment with a VERY hot reactor inside that most or all of those penetration seals were cooked early on? If so, movement of air into and out of containment would occur by convection if pressure reached atmospheric..

Enjoy. CEPA = Containment Electrical Penetration Assembly

http://www.osti.gov/bridge/servlets/purl/5338909-FPWlHy/5338909.pdf

Thanks for the link!
I feel really shocked that the electric drywell insulation specification (at least for Browns Ferry) does not exceed 436K for 15 min, and 411K long-term.

If this is nuclear building code/nuclear electric code conform then these codes are extremely lax.

I fear we have to consider the electric ducts as a possible contamination escape path also.

 

[zapperzero]

Thanks for the link!
I feel really shocked that the electric drywell insulation specification (at least for Browns Ferry) does not exceed 436K for 15 min, and 411K long-term.

If this is nuclear building code/nuclear electric code conform then these codes are extremely lax.

I fear we have to consider the electric ducts as a possible contamination escape path also.

Established fire codes have been switched temporarily to "enforcement discretion" which is just what it sounds like - every operator can make up his own fire prevention rules. Now the temporary measure has been prolonged. Gregory Jaczko disagrees, but the NRC has already decided on the issue and he's just the chairman...

http://www.propublica.org/documents/item/nuclear-regulatory-commission-comments-june-10-2011

EDIT: I swear I'm not trying to derail the thread, fwiw.

 

[NUCENG]

Established fire codes have been switched temporarily to "enforcement discretion" which is just what it sounds like - every operator can make up his own fire prevention rules. Now the temporary measure has been prolonged. Gregory Jaczko disagrees, but the NRC has already decided on the issue and he's just the chairman...

http://www.propublica.org/documents/item/nuclear-regulatory-commission-comments-june-10-2011

EDIT: I swear I'm not trying to derail the thread, fwiw.

Zapperzero, I will give you the benefit of the doubt, you only have half the story there. First, the request for the staggered review and approval originated with NRC staff not the industry.

http://www.nrc.gov/reading-rm/doc-collections/commission/secys/2011/2011-0033scy.pdf

I don't know why parts of that are redacted, but I can read behind the lines. NRC staffing requests to support this review have not been approved due to government funding cuts. Chairman Jaczko knows that the staff could not meet their required reviews within the required review period with available staff resources, so his vote is more frustration than reality. If the industry had its way they might want to see them held to schedule. First because this does not imply that the individual plant submittals will miss the deadline. Second if they all have to be approved at once they will not get the thorough review you would want. Finally a staggered approach often results in the staff coming up with new questions and jacks up review requirements so the last plants actually end up with a more rigorous review.

NFPA 0805 is a significant upgrade in detailed analysis and documentation. There are likely to be upgrades in fire equipment isolation or fire suppression systems at some plants. In other words at most plants this probably won't require any physical mods or they will be minor. Yet each plant will be spending millions of dollars to implement the new standard. NRC has regulated this upgrade for US plants. They are doing their job with the limits in their resources. And this request ensures their reviews won't be the kind of lax enforcement you imply.

Also see NRC website:

http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/fire-protection-fs.html

All plants have to maintain the existing standards to which they are licensing until their submittals for NFPA 0805 are approved. There is no "Making up their own rules" in the meantime. That is absolutely an unjustified claim.

 

[zapperzero]

There is no "Making up their own rules" in the meantime.

Sorry, I must have misread this:

http://edocket.access.gpo.gov/2008/pdf/E8-20972.pdf

Noncompliances Identified During
the Licensee’s Transition Process
Under this interim enforcement
policy, enforcement action normally
will not be taken for a violation of 10
CFR 50.48(b) (or the requirements in a
fire protection license condition)
involving a problem such as in
engineering, design, implementing
procedures, or installation, if the
violation is documented in an
inspection report and it meets all of the
following criteria:
(1) It was licensee-identified, as a
result of its voluntary initiative to adopt
the risk-informed, performance-based
fire protection program included under
10 CFR 50.48(c) or, if the NRC identifies
the violation, it was likely in the NRC
staff’s view that the licensee would have
identified the violation in light of the
defined scope, thoroughness, and
schedule of the licensee’s transition to
10 CFR 50.48(c) provided the schedule
reasonably provides for completion of
the transition within 3 years of the date
specified by the licensee in their letter
of intent to implement 10 CFR 50.48(c)
or other period granted by NRC;
(2) It was corrected or will be
corrected as a result of completing the
transition to 10 CFR 50.48(c). Also,
immediate corrective action and/or
compensatory measures are taken
within a reasonable time commensurate
with the risk significance of the issue
following identification (this action
should involve expanding the initiative,
as necessary, to identify other issues
caused by similar root causes);
(3) It was not likely to have been
previously identified by routine licensee
efforts such as normal surveillance or
quality assurance (QA) activities; and
(4) It was not willful.

 

[NUCENG]

Sorry, I must have misread this:

http://edocket.access.gpo.gov/2008/pdf/E8-20972.pdf

Noncompliances Identified During
the Licensee’s Transition Process
Under this interim enforcement
policy, enforcement action normally
will not be taken for a violation of 10
CFR 50.48(b) (or the requirements in a
fire protection license condition)
involving a problem such as in
engineering, design, implementing
procedures, or installation, if the
violation is documented in an
inspection report and it meets all of the
following criteria:
(1) It was licensee-identified, as a
result of its voluntary initiative to adopt
the risk-informed, performance-based
fire protection program included under
10 CFR 50.48(c) or, if the NRC identifies
the violation, it was likely in the NRC
staff’s view that the licensee would have
identified the violation in light of the
defined scope, thoroughness, and
schedule of the licensee’s transition to
10 CFR 50.48(c) provided the schedule
reasonably provides for completion of
the transition within 3 years of the date
specified by the licensee in their letter
of intent to implement 10 CFR 50.48(c)
or other period granted by NRC;
(2) It was corrected or will be
corrected as a result of completing the
transition to 10 CFR 50.48(c). Also,
immediate corrective action and/or
compensatory measures are taken
within a reasonable time commensurate
with the risk significance of the issue
following identification (this action
should involve expanding the initiative,
as necessary, to identify other issues
caused by similar root causes);
(3) It was not likely to have been
previously identified by routine licensee
efforts such as normal surveillance or
quality assurance (QA) activities; and
(4) It was not willful.

Yes, you are misinterpreting that. Licensees are currently licensed to previous requirements for fire protection. If a plant is found in violation of their previous licensing basis, this enforcement discretion does not apply. The enforcement discretion simply says that the requirements of the new regulation will not result in fines or escalated enforcement during the three years after a plant commits to the new standard, provided that the requirements listed above are met. Plants are still required to fix anything found during this process, but only the new rules are covered by the discretion period. NRC granted this discretionary period to give incentive to plants to agree to implement the new requirements.

If you look at the history of fire protection enforcement since the Browns Ferry fire, there is really no consistent set of rules. NFPA 0805 is a national standard and implements a risk-informed approach to fire protection consistent with NRC desires to implement state of the art srandards and methods in this area.

The problem the staff is facing is that plants had to meet the requirement of a three year period to complete their analysis and submit their license amendments implementing the new requirementse before the discretion period expired. Nearly all or all plants committed to the new requirements and the three years will expire for nearly all plants at once. The only exceptions are the so called pilot plants that may be ahead of the rest.

Note that the second (Edit:part of the first) requirement talks about NRC identified violations. That means they will already be inspecting the plants to the new requirements, just that they may not enforce penalties as long as they believe the licensee would have identified the issue.

 

[zapperzero]

Yes, you are misinterpreting that. Licensees are currently licensed to previous requirements for fire protection. If a plant is found in violation of their previous licensing basis, this enforcement discretion does not apply.

Let me quote again from the document I presented:

enforcement action normally
will not be taken for a violation of 10
CFR 50.48(b) (or the requirements in a
fire protection license condition)

This sounds like plain english to me and does not seem to refer to the new regulations. Perhaps some other document you know of could explain this?

If you look at the history of fire protection enforcement since the Browns Ferry fire, there is really no consistent set of rules.

That's... not so good, especially in the wake of the Browns Ferry fire.

Note that the second requirement talks about NRC identified violations. That means they will already be inspecting the plants to the new requirements, just that they may not enforce penalties as long as they believe the licensee would have identified the issue.

The second requirement says nothing about NRC-identified violations. I will quote it again in full:

(2) It was corrected or will be
corrected as a result of completing the
transition to 10 CFR 50.48(c). Also,
immediate corrective action and/or
compensatory measures are taken
within a reasonable time commensurate
with the risk significance of the issue
following identification (this action
should involve expanding the initiative,
as necessary, to identify other issues
caused by similar root causes);

 

[Atomfritz]

Established fire codes have been switched temporarily to "enforcement discretion" which is just what it sounds like - every operator can make up his own fire prevention rules. Now the temporary measure has been prolonged. Gregory Jaczko disagrees, but the NRC has already decided on the issue and he's just the chairman...

http://www.propublica.org/documents/item/nuclear-regulatory-commission-comments-june-10-2011

I don't know why parts of that are redacted, but I can read behind the lines. NRC staffing requests to support this review have not been approved due to government funding cuts. Chairman Jaczko knows that the staff could not meet their required reviews within the required review period with available staff resources, so his vote is more frustration than reality. If the industry had its way they might want to see them held to schedule. First because this does not imply that the individual plant submittals will miss the deadline. Second if they all have to be approved at once they will not get the thorough review you would want. Finally a staggered approach often results in the staff coming up with new questions and jacks up review requirements so the last plants actually end up with a more rigorous review.

All plants have to maintain the existing standards to which they are licensing until their submittals for NFPA 0805 are approved. There is no "Making up their own rules" in the meantime. That is absolutely an unjustified claim.

It is a bit more difficult.

Sorry, I must have misread this:

http://edocket.access.gpo.gov/2008/pdf/E8-20972.pdf

...compensatory measures are taken
within a reasonable time ...

Yes, corrective measures must be taken in a specified timeframe.
But, what are "corrective measures"?
http://pbadupws.nrc.gov/docs/ML0536/ML053620142.pdf" gives some definitions.

One of the "corrective measures" specified there is that the nuclear operator company has three years to make a statement that this problem is no safety risk.
Bingo, safety restored!

And most times the regulatory authority will not be able to check if that statement is correct.
One of the reasons is that the NRC is way understaffed to be able to perform its control duties. (Thanks to NUCENG for pointing this out!)

So it can take decades to have safety problems corrected.

They just make sure the problem is "being addressed" in a bureaucratically correct manner.
And, so it all is in order, no need to complain...

For example, there are reports stating that still about a dozen NPPs in USA have that old highly-flammable insulation used in Browns Ferry.
The operators state that this is safe and just use smoke generators instead of candles when checking insulation tightness.

And the NRC just has no time / manpower to check this and demand some real remedial action.

This bureaucracy phenomenon is well-known in other countries also.
So safety upgrades are often being installed in a "reasonable" timeframe of up to almost two decades, if at all.

Now if the statement is correct, and I am not extrapolating erroneously, that seems to suggest to me that EVEN IF the EDG had not failed the EDG provided power would have not been enough for the condenser to operate correctly.

In this case what would have been done to prevent meltdown ?
I can only think of external, out of loop, water injection and repeated venting.

This problem is well-known for long time, probably some decades.
It will be addressed by the nuclear industry in reasonable time, whatever this means. (see above)

 

[NUCENG]

Let me quote again from the document I presented:

enforcement action normally
will not be taken for a violation of 10
CFR 50.48(b) (or the requirements in a
fire protection license condition)

This sounds like plain english to me and does not seem to refer to the new regulations. Perhaps some other document you know of could explain this?



That's... not so good, especially in the wake of the Browns Ferry fire.



The second requirement says nothing about NRC-identified violations. I will quote it again in full:

(2) It was corrected or will be
corrected as a result of completing the
transition to 10 CFR 50.48(c). Also,
immediate corrective action and/or
compensatory measures are taken
within a reasonable time commensurate
with the risk significance of the issue
following identification (this action
should involve expanding the initiative,
as necessary, to identify other issues
caused by similar root causes);

License Condition.
A fire protection license condition is a requirement added to the front of the technical specifications committing to specific actions as part of the transition to the new requirements of 10 CFR 50.48(c). It may be something like agreeing to include the requirements in plant procedures and revised calculations. But the discretion only applies to fire protection conditions during the transition period.

Consistency.
No its not good and that is why the implementation of NFPA 0805 is supposed to finally provide a consistent set of rules and requirements. That will be better for both the regulators and the licensees.

NRC identified.
Sorry, meant the second part of the first requirement NRC identied violation. If I can I'll correct my post.

 

[zapperzero]

License Condition.
A fire protection license condition is a requirement added to the front of the technical specifications committing to specific actions as part of the transition to the new requirements of 10 CFR 50.48(c). It may be something like agreeing to include the requirements in plant procedures and revised calculations. But the discretion only applies to fire protection conditions during the transition period.

So, to summarize, the instructions I presented state that " specific actions as part of the transition to the new requirements of 10 CFR 50.48(c)" (your wording) may or may not be taken, at the operator's discretion, for the entirety of the transition period.

The transition period just got longer, so operators now have more time to do nothing.

The document I referred to makes specific reference to conditions set in 10 CFR 50.48(b), stating that violations will not be punished in the transition period. 10 CFR 50.48(b) in turn refers to an appendix (R) which is also present on the NRC website:

http://www.nrc.gov/reading-rm/doc-collections/cfr/part050/part050-appr.html

It covers such basic things as "you should have a fire brigade". It's amazing to me that enforcing such a requirement could be suspended. But maybe I am misreading again?

 

[NUCENG]

So, to summarize, the instructions I presented state that " specific actions as part of the transition to the new requirements of 10 CFR 50.48(c)" (your wording) may or may not be taken, at the operator's discretion, for the entirety of the transition period.

The transition period just got longer, so operators now have more time to do nothing.

The document I referred to makes specific reference to conditions set in 10 CFR 50.48(b), stating that violations will not be punished in the transition period. 10 CFR 50.48(b) in turn refers to an appendix (R) which is also present on the NRC website:

http://www.nrc.gov/reading-rm/doc-collections/cfr/part050/part050-appr.html

It covers such basic things as "you should have a fire brigade". It's amazing to me that enforcing such a requirement could be suspended. But maybe I am misreading again?

Yes and it is clear that your misreading is deliberate. The requirement to have a fire brigade is part of the current requirements and will remain so under the new commitment to NFPA 0805. You can't really think that would get enforcement discretion so you must be trying to waste my time.

 

[zapperzero]

Yes and it is clear that your misreading is deliberate. The requirement to have a fire brigade is part of the current requirements and will remain so under the new commitment to NFPA 0805. You can't really think that would get enforcement discretion so you must be trying to waste my time.

I am most emphatically NOT trying to do anything like that. Please excuse me if I have angered you with my continued lack of understanding. It is true that I am finding this bureaucratic language VERY hard to digest. It all started when I found a document that states

enforcement action normally
will not be taken for a violation of 10
CFR 50.48(b)

In turn, 10 CFR 50.48(b) says (and I am quoting in full here):

(b) Appendix R to this part establishes fire protection features required to satisfy Criterion 3 of appendix A to this part with respect to certain generic issues for nuclear power plants licensed to operate before January 1, 1979.

(1) Except for the requirements of Sections III.G, III.J, and III.O, the provisions of Appendix R to this part do not apply to nuclear power plants licensed to operate before January 1, 1979, to the extent that--

(i) Fire protection features proposed or implemented by the licensee have been accepted by the NRC staff as satisfying the provisions of Appendix A to Branch Technical Position (BTP) APCSB 9.5-1 reflected in NRC fire protection safety evaluation reports issued before the effective date of February 19, 1981; or

(ii) Fire protection features were accepted by the NRC staff in comprehensive fire protection safety evaluation reports issued before Appendix A to Branch Technical Position (BTP) APCSB 9.5-1 was published in August 1976.

(2) With respect to all other fire protection features covered by Appendix R, all nuclear power plants licensed to operate before January 1, 1979, must satisfy the applicable requirements of Appendix R to this part, including specifically the requirements of Sections III.G, III.J, and III.O.

and appendix R itself is here:

http://www.nrc.gov/reading-rm/doc-collections/cfr/part050/part050-appr.html

Of which I shall quote only III.G because it is specifically referenced in 10 CFR 50.48(b) :

G. Fire protection of safe shutdown capability. 1. Fire protection features shall be provided for structures, systems, and components important to safe shutdown. These features shall be capable of limiting fire damage so that:

a. One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station(s) is free of fire damage; and

b. Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station(s) can be repaired within 72 hours.

I am trying to understand which provisions of 10 CFR 50.48(b) will not be enforced, under the transitional period rules, the extension of which Gregory Jaczko is so strenuously and uselessly protesting.

Can you help with that?

 

[NUCENG]

I am most emphatically NOT trying to do anything like that. Please excuse me if I have angered you with my continued lack of understanding. It is true that I am finding this bureaucratic language VERY hard to digest. It all started when I found a document that states



In turn, 10 CFR 50.48(b) says (and I am quoting in full here):



and appendix R itself is here:

http://www.nrc.gov/reading-rm/doc-collections/cfr/part050/part050-appr.html

Of which I shall quote only III.G because it is specifically referenced in 10 CFR 50.48(b) :



I am trying to understand which provisions of 10 CFR 50.48(b) will not be enforced, under the transitional period rules, the extension of which Gregory Jaczko is so strenuously and uselessly protesting.

Can you help with that?

It will all be enforced, just that it won't result in fines or escalated enforcement as long as plants are moving to implement 10 CFR50.48(c). Inspections will still happen. Violations will still be written. Prompt and Effective Corrective actions will still be required. Compensatory measures may be required until compliance is restored. None of that changes. But there won't be fines or shutdown orders during the discretion period if the 4 requirements are met. If the discretion period ends and the plant has not submitted their implementation amendment, then there is no protection from enforcement. Once everything is done and license amendments are approved the plants will no longer be subject to 10 CFR 50.48(b), but will be under 10 CFR 50.48(c)

 

[Atomfritz]

If NRC believes the licensee is deliberately stalling corrective actions, they can whthdraw enforcement discretion or apply enforcement action for violations of requirements for prompt and effective corrective action programs.

I remember only one action of this kind where NRC ordered a plant to shut down.
It was when a whistleblower revealed that the operators in the control room were sleeping, playing video games etc, but not caring for the reactor.

"And most times the regulatory authority will not be able to check if that statement is correct." Opinion based on nothing.

Your comment about under staffing is interesting. Could you please cite your sources?

You read this between the lines.

Are you trying to imply that the nuclear industry is making staffing decisions?

In Japan, Germany etc there are many discussions about this interesting phenomenon of fraternalization of the nuke industry and the authorities.
People work for one side, then change their side at early retirement.
There is much money at work to which motivates people working at the regulatory to be "cooperative".
If they cooperate well they might be thanked with a well-paid leisure job.
They get much money without really have to work.
They just have to do lobby working at their former colleagues in the regulatory authority.
So these know well: "Cooperate and you'll have good income without having to work later."

Internal disagreements within NRC are sometimes as close to warfare as this thread. And before you jump to conclusions, these battles are the engineers dilemna: "Better is the enemy of good enough."

In fact, I doubt that it is always for this reason.
In fact, the comments of some Commissioners regarding the extension of the discretion period from three to eight years remind me of a typical soviet style communist party sycophancy.

I am trying to understand which provisions of 10 CFR 50.48(b) will not be enforced, under the transitional period rules, the extension of which Gregory Jaczko is so strenuously and uselessly protesting.

Can you help with that?

As most national nuclear laws around the world are similar to the masterprint of the american system, I suspect it is like here in Germany.

In the wake of the final shutdown of many German reactors it came at light that thousands of safety improvements etc, not only regarding flammable insulation foam, have been delayed by reactor operators for up to 17 years after having been ordered by the authorities.

Just an example, the Brunsbüttel BWR at the Northern Sea.
It has been offline for some years now.
There had been a hydrogen explosion ripping open some tubes of the primary circuit and spraying radioactive steam.
But the reactor operator didn't consider this an important thing and insisted to operate the reactor until next planned shutdown about half a year later while just letting the leaking water flow into the sump (wetwell).

The nuclear authorities had to battle for three months until, with the help of the federal government, they finally got the reactor operator company agree to shut down the reactor.

In the aftermath of this accident it was revealed that this accident easily could have mutated into an uncontrollable LOCA if some piping cracked by the explosion would have severed the main cooling water circuit.

But the real reason why the authority was unable to allow to restarting the plant was the public pressure in sight of the fact that the NPP piled up more than 400 unremedied violations in a dozen years.

It will all be enforced, just that it won't result in fines or escalated enforcement as long as plants are moving to implement 10 CFR50.48(c). Inspections will still happen. Violations will still be written. Prompt and Effective Corrective actions will still be required. Compensatory measures may be required until compliance is restored. None of that changes. But there won't be fines or shutdown orders during the discretion period if the 4 requirements are met. If the discretion period ends and the plant has not submitted their implementation amendment, then there is no protection from enforcement.

Jaczko fruitlessly opposed the extension of the discretion period to eight years.
As there is not always the possibility of enforcement after the end of the discretion period, as Jaczko clearly indicates, there can be easily more than ten years from the finding of a violation to when the NRC can order the plant operators to do something about.

 

[zapperzero]

N: Your post belongs on the "Other Political Thread

I'm afraid the whole discussion belongs there. I am a repeat offender in that area :/

Anyway, I got my answers from you, so thanks a lot and, again, sorry for being pushy.

 

[NUCENG]

I'm afraid the whole discussion belongs there. I am a repeat offender in that area :/

Anyway, I got my answers from you, so thanks a lot and, again, sorry for being pushy.

You are welcome. I am trying to be clear that nothing made by men is perfect. I have admitted that fire protection issues have gone on way too long, but it is still better to get the reviews done thoroughly and correctly than based on arbitrary deadlines and inadequate staffing. There are issues facing the US nuclear industry and I've not hidden them (see MY rant on spent fuel and politics). I'm sorry it took so long to finally see what you were asking for. Keep pushing!