Risk-Deformed Regulation: What Went Wrong with NFPA 805

Authors: Raymond HV Gallucci

Before proceeding, and lest opponents of nuclear power think this paper lends support to their efforts to shut down the nuclear industry, I must state the following. NFPA 805 will have been successful in that plants transitioning to it will be as safe as or safer than prior to transition. Plants that made no changes will have at least assessed their fire risks and be more knowledgeable of potential weaknesses that could compromise safety. Having found none, they will not have the need for changes. Plants that made effective changes will be safer than before. If you are one who believes the end justifies the means, then this “bottom line” is all that matters and you need read no further. However, if you are one who believes the means are also important, then you are the audience that I address. I am in no way contending that adoption of NFPA 805 compromised safety – I, too, believe that plants will be as safe or safer as a result of the transition. Why I wrote this paper is to express frustration over the “compromises” allowed by the NRC, and the “short-cuts” and “deviations” taken by the nuclear industry, to fulfill the promise of a “sea change” in fire protection at nuclear power plants through risk-informed, performance-based regulation. And, while no diminution of safety will have occurred, it is possible there were missed opportunities to improve safety if changes might have been made, or different changes substituted for those that were made, if not for these “compromises,” “short-cuts” and “deviations.” I must confess to being guilty of false optimism in December 2006 when I wrote “perhaps the single achievement most responsible for the improved regulatory environment for fire protection at commercial nuclear power plants has been the modification to 10CFR50.48 that allows licensees to ‘maintain a fire protection program that complies with NFPA 805 as an alternative to complying with [past, purely deterministic regulations]’” (Gallucci, “Thirty-Three Years of Regulating Fire Protection at Commercial U.S. Nuclear Power Plants: Dousing the Flames of Controversy,” Fire Technology, Vol. 45, pp. 355-380, 2009).

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[v1] 2018-05-21 13:52:40
[v2] 2018-09-05 16:47:39
[v3] 2018-09-17 09:01:12

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