Information Notice 2023-04, Operating Experience Related to Fire Events at Decommissioning Nuclear Power Plants in the United States

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Operating Experience Related to Fire Events at Decommissioning Nuclear Power Plants in the United States
ML23088A143
Person / Time
Issue date: 09/13/2023
From: Russell Felts, John Marshall
Office of Nuclear Reactor Regulation, Reactor Decommissioning Branch
To:
References
IN 2023-04
Download: ML23088A143 (5)
v • d • e


UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, DC 20555-0001 September 13, 2023 NRC INFORMATION NOTICE 2023-04: OPERATING EXPERIENCE RELATED TO FIRE

EVENTS AT DECOMMISSIONING NUCLEAR

POWER PLANTS IN THE UNITED STATES

ADDRESSEES

All holders of and applicants for an operating license or construction permit for a nuclear power

reactor issued under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic

licensing of production and utilization facilities, including those that have permanently ceased

operations and certified that fuel has been permanently removed from the reactor vessel.

All holders of and applicants for a power reactor combined license, standard design approval, or

manufacturing license under 10 CFR Part 52, Licenses, certifications, and approvals for

nuclear power plants. All applicants for a standard design certification, including such

applicants after initial issuance of a design certification rule.

PURPOSE

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to inform

addressees of fire events in radiologically controlled areas; posted radiologically contaminated

areas; instances of failure to control combustible material and/or perform adequate fire watches;

or implement other fire protection activities at decommissioning power reactor sites. These fire

events have been documented in NRC decommissioning reactor inspection reports from 2018 to 2023. While the focus of this IN is based on fire incidents at, and the regulations for, decommissioning reactors; the root causes are not reactor-specific activities, and this

operational experience can be applicable to any operating or decommissioning nuclear power

plant. The significance of these events is the potential for the release of radionuclides, in and

outside of controlled areas of the site (outside of a restricted area but inside the site boundary)

and potentially to publicly accessible areas, occupational radiation exposure, and the impact on

industrial safety. The NRC expects that recipients of this IN will review this information for

applicability to their facilities and consider actions, as appropriate. The INs may not impose new

requirements, and nothing in this IN should be interpreted to require specific action.

BACKGROUND

In accordance with 10 CFR 50.48(f)(1), licensees that have submitted the certifications required

under 10 CFR 50.82(a)(1) shall maintain a fire protection program to address the potential for

ML23088A143

IN 23-04 fires that could cause the release or spread of radioactive materials (i.e., that could result in a

radiological hazard).

Fire protection for nuclear power plants uses the concept of defense-in-depth to achieve the

required degree of reactor safety by using echelons of administrative controls, fire prevention, fire detection, and suppression systems. These systems are relied upon by licensees to achieve

compliance with NRC fire protection requirements in 10 CFR 50.48, Fire protection, to protect

safety-related and important to safety structures, systems, and components (SSCs) that are

needed to achieve safe shutdown of the reactor in the event of a fire and to minimize radioactive

release to the environment in the event of a fire.

In accordance with 10 CFR 50.48, each operating nuclear power plant is required to have a fire

protection plan. The plan should establish the fire protection policy for the protection of SSCs at

each plant and the procedures, equipment, and personnel required to implement the program at

the plant site. The primary fire protection concern for permanently shutdown plants is protecting

the integrity of the remaining spent nuclear fuel in the spent fuel pool and preventing or

minimizing the release of radioactive material, resulting from fires involving contaminated plant

SSCs or radioactive waste.

The fire protection program for an operating reactor provides the basis for developing the fire

protection program for the decommissioning phase. The goal of the fire protection program

during decommissioning of nuclear power plants is to provide an appropriate level of defense-in- depth protection against the threat of fires. Defense-in-depth for fire protection involves a

comprehensive program of administrative controls, physical fire protection features, emergency

response capabilities, and protection of SSCs necessary to prevent or mitigate the potential of

an unacceptable release of radioactive materials. This combination of elements reduces both

the probability and consequences of fire events, and it ensures that the failure of any one

element within the fire protection program is adequately compensated for by the others, thereby

minimizing the risk to the public, environment, and plant personnel.

For those plants that are permanently shut down, are undergoing decommissioning, or both, the

licensing basis changes must be in accordance with the requirements in 10 CFR 50.82, Termination of License. For permanently shutdown reactors, 10 CFR 50.48(f) and Regulatory

Guide 1.191, Revision 1, Fire Protection Program for Nuclear Power Plants During

Decommissioning (Agencywide Documents Access and Management System (ADAMS) at

Accession No. ML20287A199), relate to fire protection.

The objectives of the fire protection program listed in 10 CFR 50.48(f)(1) are to: (1) reasonably

prevent fires from occurring, (2) rapidly detect, control, and extinguish those fires that do occur

and that could result in a radiological hazard, and (3) ensure that the risk of fire-induced

radiological hazards to the public, environment, and plant personnel is minimized. In addition, a

fire protection program that complies with 10 CFR 50.48(c), National Fire Protection

Association Standard NFPA 805, incorporates by reference, with exceptions, modifications, and supplementation, National Fire Protection Association (NFPA) Standard 805, Performance- Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants. The

2001 Edition is deemed to be acceptable for complying with the requirements of 10 CFR

50.48(f).

IN 23-04

DESCRIPTION OF CIRCUMSTANCES

Recent fire events at decommissioning power reactor sites provide useful lessons concerning

fire protection program implementation. These events are selected and summarized from

reports of NRC inspections performed from August 2018 to May 2023. During that period the

NRC assessed six reported occurrences of fires in radiologically controlled areas or potentially

radiologically contaminated areas at decommissioning power reactor sites. The six incidents are

described in the following NRC inspection reports:

  • Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 - NRC

Inspection Report Nos. 05000302/2021004, January 24, 2022, and 05000302/2022001, May 3, 2022 (ADAMS Accession Nos. ML22011A005 and ML22116A183, respectively)

  • Holtec Decommissioning International, LLC, Pilgrim Nuclear Power Station - NRC

Inspection Report No. 05000293/2022004, February 15, 2023 (ADAMS Accession

No. ML23031A208)

  • Fort Calhoun Station, NRC Inspection Reports 050-00285/2021-001, February 17, 2021,

050-00285/2022-001, February 25, 2022, and 050-00285/2022-002, April 28, 2022 (ADAMS Accession Nos. ML21048A322, ML22055A979 and ML22112A158, respectively)

The NRC also assessed four instances of failure to properly implement fire protection

procedures at decommissioning power reactor sites. The four incidents are described in the

following NRC inspection reports:

  • Holtec Decommissioning International, LLC, Indian Point Energy Center Units 1, 2 and 3

- NRC Inspection Report Nos. 05000003/2022004, 05000247/2022004,

05000286/2022004, and 07200051/2022002, March 13, 2023 (ADAMS Accession

No. ML23047A154)

05000362/2022-001, March 14, 2022 (ADAMS Accession Nos. ML18219B607 and

ML22068A233, respectively)

At Crystal River Unit 3, as described in above NRC inspection reports (ADAMS Accession

Nos. ML22011A005 and ML22116A183), NRC inspection staff identified incidents where the

licensee did not properly implement fire procedures during hot work activities. For example, an

area was left without a fire watch for the required amount of time after the completion of hot

work.

At Fort Calhoun Station in September 2020 (ADAMS Accession No. ML21048A322), hot work in

containment caused a fire because slag from torch cutting fell through multiple elevations into a

high radiation area and ignited combustible material.

IN 23-04 Also, at Fort Calhoun Station in January 2022, as described in the above NRC inspection report

(ADAMS Accession No. ML22055A979), a fire started when the traveling river water screen was

being cut with a torch for removal. The workers thought the screen was constructed of stainless

steel. However, the screen was made of a polyethylene-type material, which reacted to the use

of a torch resulting in a fire. The fire watch immediately responded, but an offsite fire department

was requested to assist the site.

In February 2022 (ADAMS Accession No. ML22068A233) at, at San Onofre Nuclear Generating

Station NRC inspectors found Class A combustible materials, including non-covered wooden

planks, within the licensees procedural exclusion area or directly under where hot work was

being performed.

In July 2018 (ADAMS Accession No. ML18219B607), also at San Onofre Nuclear Generating

Station, NRC inspectors found that combustible materials were not removed from a room that

supported active plant equipment after work was completed. Debris, bags of waste, and leftover

distribution cables were stored in a cable tray that was located directly below active cable trays

without the required vertical separation from combustible materials.

In May 2022 (ADAMS Accession No. ML23031A208), NRC inspectors identified the licensees

failure to utilize a hot work permit to control the use of a halogen lamp in one room of the

radioactive waste facility at Pilgrim Nuclear Power Station. This led to a fire when the lamp

ignited combustible material.

In October 2022 (ADAMS Accession No. ML23047A154) at Indian Point Nuclear Generating

Station Units 1, 2 and 3, NRC inspectors determined that the licensee had failed to implement a

fire protection equipment surveillance procedure. Specifically, the piping associated with the

high-pressure fire water system had not been flow tested within the required surveillance

interval.

At Fort Calhoun Station in 2023, (ADAMS Accession No. ML23177A119) NRC inspectors found

that the licensee failed to perform and/or record all fire watch inspections in parts of the

decommissioning area without fire detection.

DISCUSSION

The operating experience events described in this IN highlight the importance of:

  • adequate procedures and field practices to ensure that combustible materials were

spaced the required minimum distance from hot work;

  • appropriate implementation of fire prevention control measures during use of heat, spark

or open flame for activities such as cutting, welding, and grinding;

  • the proper implementation of fire watch procedures for hot work and fire protection

equipment surveillance procedures, and;

  • appropriate storage requirements for transient combustible materials near energized

plant equipment.

Regulatory Guide 1.191 and, NUREG/BR-0522, Revision 1, Fire Protection for Operating

Nuclear Power Plants and Decommissioning Reactors (ADAMS Accession No. ML22340A499)

provides an overview of the fire protection requirements of 10 CFR 50.48 for decommissioning

facilities. The NFPA Standard 51B, Standard for Fire Prevention During Welding, Cutting, and

ML15226A446), can also be useful references for

fire protection programs for decommissioning facilities.

CONTACT

Please direct any questions about this matter to the technical contact listed below.

/RA/ /RA/

Jane Marshall, Director Russell Felts, Director

Division of Decommissioning, Uranium Division of Reactor Oversight

Recovery and Waste Programs Office of Nuclear Reactor Regulation

Office of Nuclear Material Safety

and Safeguards

Technical Contact:

Jack D. Parrott, NMSS

(301) 415-6634 E-mail: Jack.Parrott@nrc.gov

ADAMS Accession No.: ML23088A143 EPID No. L-2023-GEN-0002 OFFICE QTE NMSS/DUWP/RDB NRR/DRA/APLB NMSS/DUWP/RDB OE/EB NRR/DRA/APLB

NAME JDoughety JParrott NIqbal SAndrson JPeralta SMehta

DATE 4/10/2023 4/18/2023 8/11/2023 4/27/2023 8/4/2023 4/18/2023 OFFICE NRR/DRO/IOLB NRR/DRO/IOEB NMSS/DUWP NRR/DRO/IOEB NMSS/DUWP NRR/DRO

NAME IBetts PClark MFerdas LRegner JMarshall RFelts

DATE 8/16/2023 7/3/2023 8/4/2023 9/8/2023 9/12/2023 9/13/2023


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