Information Notice 2007-23, Inadvertent Discharge of Halon 1301 Fire Suppression System Due to Incorrect And/Or Out of Date Procedures
| ML071510558 | |
| Person / Time | |
|---|---|
| Issue date: | 08/08/2007 |
| From: | Michael Case, Pierson R NRC/NMSS/FCSS, NRC/NRR/ADRO/DPR |
| To: | |
| References | |
| IN-07-023 | |
| Download: ML071510558 (7) | |
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001 August 8, 2007 NRC INFORMATION NOTICE 2007-23 INADVERTENT DISCHARGE OF HALON 1301 FIRE-SUPPRESSION SYSTEM FROM
INCORRECT AND/OR OUT-OF-DATE
PROCEDURES
ADDRESSEES
All holders of operating licenses for nuclear power reactors, except those who have
permanently ended operations and have certified that fuel has been permanently removed from
the reactor vessel. All holders of licenses for fuel cycle facilities.
PURPOSE
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to inform
addressees of a recent event at a fuel cycle facility that involved the inadvertent discharge of a
Halon 1301 fire-suppression system, as well as deficiencies in fire protection program
elements, procedures, and administrative controls. NRC expects that recipients of this IN will
review the information for applicability to their facilities and consider actions, as appropriate, to
avoid similar problems. However, suggestions contained in this IN are not NRC requirements;
therefore, no specific action nor written response is required.
DESCRIPTION OF CIRCUMSTANCES
The following describes the site condition that existed, and sequence of events that occurred, which led to inadvertent discharge of a Halon 1301 fire-suppression system at an NRC licensed
fuel cycle facility.
In December 2006, a small fire started on a heat trace for piping that was located outdoors at a
licensed facility. A security station was contacted, the fire was announced, and the fire brigade
was dispatched. The fire was immediately extinguished and power was removed from the
circuit. After the fire was extinguished, supervision at the scene requested the security officer
who was manning the security station to activate a manual fire alarm pull station, since plant fire
protection procedures required the sounding of the plant fire alarm for any fire. As a result of
miscommunication, the security officer activated a manual pull station that was associated with
the Halon 1301 fire-suppression system, intended to protect the security station. Activation of
this pull station resulted in the discharge of Halon into the security station.
A manual fire alarm pull station had been previously located in the security station, but had
been removed for the installation of a new fire alarm panel and had not yet been re-installed. In
addition, the manual pull station associated with the Halon was in the area.
In this particular instance, the Halon 1301 fire-suppression system located in the security
station is not credited in the licensees safety basis to meet the requirements of either Title
10 of the Code of Federal Regulations (10 CFR) Sections 70.61 or 70.64 of 10 CFR Part 70,
Domestic Licensing of Special Nuclear Material, since neither process equipment nor special
nuclear materials exists in the security station.
After the Halon discharged, a plant supervisor directed that the Halon fire-suppression system
be reset. The facility industrial safety specialist responsible for fire safety attempted to reset the
Halon fire-suppression system. During this procedure, the Halon fire-suppression system was
again actuated and the back-up tank was discharged. The two discharges depleted all Halon, causing the Halon 1301 fire- suppression system for the security station to be out of service.
The licensee then implemented a fire-protection system impairment response, using
appropriate compensatory measures.
The licensees root cause evaluation determined that the lack of a manual fire pull station in the
security station was identified as early as July 2006. A letter was sent to the security
department from plant safety, noting the lack of a pull station, and that the security station
operator would simply need to announce the fire and location over the plant paging system.
This deviation from existing procedures was not communicated to shift operations personnel
and was not incorporated into applicable plant procedures. The lack of up-to-date fire response
procedures, coupled with poor communications, led directly to the inadvertent Halon discharge
and the disabling of the fire-suppression system. As a corrective action, the licensee installed a
fire alarm pull station in the security station.
The licensee also determined that there was no plant procedure for resetting the Halon
fire-suppression system and the reset had been performed via skill-of-the craft, by an Industrial
Safety Specialist who was generally knowledgeable of Halon fire-suppression systems.
However, the Halon fire-suppression system had been maintained and serviced by an outside
vendor. As a result, there was no specific procedural guidance for resetting the system back to
normal operations.
Additionally, it was noted that over several years, pressure in the Halon 1301 cylinders was
allowed to decrease approximately 100 pounds per square inch gauge (psig) below the initial
charging pressure (360 to 400 psig). This conflicts with National Fire Protection Association
12A, Standard on Halon 1301 Fire Extinguishing Systems, which indicates refilling or
replacing a Halon 1301 cylinder when the pressure drops by 10 percent or more. Although
monthly tank readings taken by the licensee, as well as an outside contractor, indicated that a
slow system leak was in progress, no corrective action was taken and the deficiency was not
entered into the licensees corrective action system.
BACKGROUND
10 CFR 70.61, Performance Requirements, requires that certain fuel cycle licensees
authorized to possess a critical mass of special nuclear material meet performance
requirements for all credible high- or intermediate consequence events including radiological or
chemical releases as a result of fires. Licensees and certificate holders regulated under
10 CFR Part 40, Domestic Licensing of Source Material, or 10 CFR Part 76, Certification of
Gaseous Diffusion Plants, must also meet fire safety requirements that may require an
operable automatic suppression system.
Additionally, 10 CFR 50.48, Fire Protection, states that each operating nuclear power plant
must have a fire protection plan that satisfies Criterion 3, Fire Protection, in Appendix A,
General Design Criteria for Nuclear Power Plants, to 10 CFR Part 50, Domestic Licensing of
Production and Utilization Facilities, and that this plan must describe specific features
necessary to implement the fire protection program such as automatic and manually operated
fire detection and suppression systems.
Recent NRC Generic Communications Related to Fire Protection
- NRC IN 2007-19, Faulty Active Fire Protection Equipment, May 21, 2007;
- NRC IN 2007-17, Fires at Nuclear Power Plants Involving Inadequate Fire Protection
Administrative and Design Controls, May 3, 2007;
- NRC IN 2005-32, Product Alert for Fire Hydrants, December 23, 2005;
- NRC IN 2005-01, Halon Fire-Extinguishing System Piping Incorrectly Connected, February 4, 2005; and
- NRC Regulatory Issue Summary 2005-07, Compensatory Measures to Satisfy the Fire
Protection Program Requirements, April 19, 2005.
DISCUSSION
Fire protection suppression and detection system reliability and performance capabilities are a
primary feature of defense-in-depth and must be maintained to achieve effectiveness in
preventing fire damage to structures, systems, and components important to safety.
In this event, the licensees fire protection program failed to provide adequate procedural, administrative, and design controls to prevent inadvertent Halon 1301 fire-suppression system
actuation.
CONTACT
S
This IN does not require any specific action nor written response. Please direct any questions
about this matter to the technical contacts listed below or to the appropriate Office of Nuclear
Reactor Regulation (NRR) or Office of Nuclear Material Safety and Safeguards (NMSS) project
manager.
/RA/ /RA by TQuay for/
__________________________ _____________________________
Robert C. Pierson, Director Michael J. Case, Director
Division of Fuel Cycle Safety Division of Policy and Rulemaking
and Safeguards Office of Nuclear Reactor Regulation
Office of Nuclear Material Safety
and Safeguards
Technical Contacts:
Rex Wescott, NMSS Naeem Iqbal, NRR
301-492-3107 301-415-3346 E-mail: rgw@nrc.gov E-mail: nxi@nrc.gov
Enclosure: List of Recently Issued FSME-NMSS Generic Communications
Note: A full listing of NRC generic communications may be viewed on the NRC public Web Site:
http://www.nrc.gov, under Electronic Reading Room/Document Collections.
CONTACT
S
This IN does not require any specific action nor written response. Please direct any questions
about this matter to the technical contacts listed below or to the appropriate Office of Nuclear
Reactor Regulation (NRR) or Office of Nuclear Material Safety and Safeguards (NMSS) project
manager.
/RA/ /RA by TQuay for/
__________________________ _____________________________
Robert C. Pierson, Director Michael J. Case, Director
Division of Fuel Cycle Safety Division of Policy and Rulemaking
and Safeguards Office of Nuclear Reactor Regulation
Office of Nuclear Material Safety
and Safeguards
Technical Contacts:
Rex Wescott, NMSS Naeem Iqbal, NRR
301-492-3107 301-415-3346 E-mail: rgw@nrc.gov E-mail: nxi@nrc.gov
Enclosure: List of Recently Issued FSME-NMSS Generic Communications
Note: A full listing of NRC generic communications may be viewed on the NRC public Web Site:
http://www.nrc.gov, under Electronic Reading Room/Document Collections.
Distribution:
IN r/f FFLD r/f ECB r/f
ADAMS Accession Number: ML071510558 OFFICE FFLD FFLD FSME Tech Ed FFLD NRR
NAME RWescott LWilliamson AMcIntosh EKraus (via fax) BSmith SWeerakkody
DATE 06/01/07 06/04/07 05/29/07 06/15/07 06/07/07 07/24/07 OFFICE NRR NRR NRR NRR FCSS
NAME CHawes DBeaulieu MMurphy TQuay for MCase RPierson
DATE 07/30/07 07/30/07 08/06/07 08/06/07 08/08/07 OFFICIAL RECORD COPY Recently Issued
Federal and State Materials and Environmental Management Programs/
Nuclear Material Safety and Safeguards Generic Communications
Date GC No. Subject
Addressees
02/02/07 IN 07-03 Reportable Medical Events All NRC medical use licensees
Involving Patients Receiving and NRC Master Materials
Dosages of Sodium Iodide Licensees. All Agreement State
Iodine-131 less than the Radiation Control Program
Prescribed Dosage Because Directors and State Liaison
of Capsules Remaining in Officers.
Vials after Administration
02/28/07 IN 07-08 Potential Vulnerabilities of All NRC licensees and all
Time-reliant Computer-based Agreement State Radiation
Systems Due to Change in Control Program Directors and
Daylight Saving Time Dates State Liaison Officers.
03/15/07 IN 07-10 Yttrium-90 Theraspheres All NRC Medical Licensees and
and Sirspheres Impurities NRC Master Materials Licensees.
All Agreement State Radiation
Control Program Directors and
State Liaison Officers.
04/04/07 IN 07-13 Use of As-Found Conditions All licensees authorized to
to Evaluate Criticality-related possess a critical mass of special
Process Upsets at Fuel nuclear material.
Cycle Facilities
05/02/07 IN 07-16 Common Violations of the All licensees who are
Increased Controls implementing the NRC Order
Requirements and Related Imposing Increased Controls
Guidance Documents (EA-05-090), issued
November 14, 2005, and
December 22, 2005.
03/01/07 RIS 07-03 Ionizing Radiation Warning All NRC licensees and certificate
Symbol holders. All Radiation Control
Program Directors and State
Liaison Officers Date GC No. Subject
Addressees
03/09/07 RIS 07-04 Personally Identifiable All holders of operating licenses
Information Submitted to the for nuclear power reactors and
NRC holders of and applicants for
certificates for reactor designs.
All licensees, certificate holders, applicants, and other entities
subject to regulation by the NRC
of the use of source, byproduct, and special nuclear material.
03/20/07 RIS 07-05 Status and Plans for All NRC materials licensees, Implementation of NRC Radiation Control Program
Regulatory Authority for Directors, State Liaison Officers, Certain Naturally-occurring and NRCs Advisory Committee
and Accelerator-produced on the Medical Uses of Isotopes.
Radioactive Material
04/05/07 RIS 07-07 Clarification of Increased All NRC licensees issued NRCs
Controls for Licensees That Order Imposing Increased
Possess Collocated Controls and all Radiation Control
Radioactive Material During Program Directors and State
Transportation Activities Liaison Officers.
05/04/07 RIS 07-09 Examples of Recurring All holders of, and applicants for, Requests for Additional a: (1) 10 CFR Part 71 certificate
Information for of compliance (CoC) for a
10 CFR Part 71 and 72 radioactive material transportation
Applications package; (2) 10 CFR Part 72 CoC
for a spent fuel storage cask; and
(3) 10 CFR Part 72 specific
license for an independent spent
fuel storage installation.
05/15/07 RIS 07-10 Subscriptions To New List All NRC medical-use licensees
Server For Automatic and NRC Master Materials
Notifications Of licensees. All Radiation Control
Medical-Related Generic Program Directors and State
Communications, Federal Liaison Officers.
Register Notices And
Newsletters
Note: A full listing of NRC generic communications may be viewed on the NRC public Web Site:
http://www.nrc.gov, under Electronic Reading Room/Document Collections.
Enclosure