Moving from Automatic to Manual CO2 Systems

NRC Presentation by:
D. M. Frumkin, Fire Protection Engineer,
Plant Systems Branch, Division of Systems Safety and Analysis, Office of Nuclear Reactor Regulation
NEI Fire Protection Information Forum, San Francisco, CA, August 29-31, 2005


  • NEI White Paper on "Carbon Dioxide Suppression System Design Changes"

NEI letter dated 01-31-05 to NRC transmitting CO2 White Paper
NRC response dated 07-20-05 to NEI with comments

NRC Letter Included seven comments on NEI White Paper
1. Enhance manual fire fighting and reduce personnel hazards
2. Consider physical protection requirements and security orders
3. Consider Defense-In-Depth for removal of CO2 systems
4. Treatment of compensatory measures
5. Use of Risk-Informed methods
6. Consideration of "adverse affect"
7. Reliance on NEI 02-03 for determining "adverse affect"
  • Millstone Request (pending)

MS Deviation Request To NRC - dated 04-17-03
RAI Response - dated 01-23-04

MS LAR - dated 04-15-04
RAI Response - dated 06-23-05

NRC Approval of LAR (pending)

  • Salem Request (pending)

Submittal To NRC: Not Publicly Available

NRC Response (pending)

  • Methods
    Deterministic (Salem, Peach Bottom, Millstone)
    Risk-Informed (Millstone)

  • Conclusion

From NRC response to NEI White Paper:
Licensees who wish to make design changes to their CO2 fire suppression systems must evaluate whether prior NRC approval is needed in accordance with their current licensing basis. Potential plant security implications associated with the CO2 fire suppression systems design changes must be addressed . . .