Information Notice 2007-23, Inadvertent Discharge of Halon 1301 Fire Suppression System Due to Incorrect and/or Out of Date Procedures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 |
| Revision: | 0 |
| From: | Case M J, Pierson R C NRC/NMSS/FCSS, NRC/NRR/ADRO/DPR |
| To: | |
| References | |
| IN-07-023 | |
| Download: ML071510558 (7) | |
August 8, 2007
NRC INFORMATION NOTICE 2007-23INADVERTENT DISCHARGE OF HALON 1301FIRE-SUPPRESSION SYSTEM FROM INCORRECT AND/OR OUT-OF-DATE PROCEDURES
ADDRESSEES
All holders of operating licenses for nuclear power reactors, except those who havepermanently ended operations and have certified that fuel has been permanently removed from the reactor vesse All holders of licenses for fuel cycle facilities.
PURPOSE
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to informaddressees 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 control NRC expects that recipients of this IN will review the information for applicability to their facilities and consider actions, as appropriate, to avoid similar problem However, suggestions contained in this IN are not NRC requirements; therefore, no specific action nor written response is required. DESCRIPTION OF CIRCUMSTANCESThe 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 alicensed facilit A security station was contacted, the fire was announced, and the fire brigade was dispatche The fire was immediately extinguished and power was removed from the circui 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 fir 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 statio Activation of this pull station resulted in the discharge of Halon into the security statio A manual fire alarm pull station had been previously located in the security station, but hadbeen removed for the installation of a new fire alarm panel and had not yet been re-installe 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 securitystation is not credited in the licensee's 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 systembe rese The facility industrial safety specialist responsible for fire safety attempted to reset the Halon fire-suppression syste During this procedure, the Halon fire-suppression system was again actuated and the back-up tank was discharge The two discharges depleted all Halon, causing the Halon 1301 fire- suppression system for the security station to be out of servic The licensee then implemented a fire-protection system impairment response, using appropriate compensatory measures. The licensee's root cause evaluation determined that the lack of a manual fire pull station in thesecurity station was identified as early as July 200 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 syste This deviation from existing procedures was not communicated to shift operations personnel and was not incorporated into applicable plant procedure 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 syste 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 Halonfire-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 system However, the Halon fire-suppression system had been maintained and serviced by an outside vendo As a result, there was no specific procedural guidance for resetting the system back to normal operation Additionally, it was noted that over several years, pressure in the Halon 1301 cylinders wasallowed 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 mor 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 licensee's corrective action syste
BACKGROUND
10 CFR 70.61, "Performance Requirements," requires that certain fuel cycle licenseesauthorized to possess a critical mass of special nuclear material meet performance requirements for all credible high- or intermediate consequence events including radiological orchemical releases as a result of fire 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 plantmust 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 ProtectionAdministrative 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 FireProtection Program Requirements," April 19, 2005.DISCUSSIONFire protection suppression and detection system reliability and performance capabilities are aprimary 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 licensee's fire protection program failed to provide adequate procedural,administrative, and design controls to prevent inadvertent Halon 1301 fire-suppression system actuatio
CONTACT
SThis IN does not require any specific action nor written respons Please direct any questionsabout 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 SafeguardsTechnical Contacts:Rex Wescott, NMSS Naeem Iqbal, NRR301-492-3107 301-415-3346 E-mail: rgw@nrc.gov E-mail: nxi@nrc.gov
Enclosure:
List of Recently Issued FSME-NMSS Generic CommunicationsNote: 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 Collection
CONTACT
SThis IN does not require any specific action nor written respons Please direct any questionsabout 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 SafeguardsTechnical Contacts:Rex Wescott, NMSS Naeem Iqbal, NRR301-492-3107 301-415-3346 E-mail: rgw@nrc.gov E-mail: nxi@nrc.gov
Enclosure:
List of Recently Issued FSME-NMSS Generic CommunicationsNote: 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/fFFLD r/fECB r/f ADAMS Accession Number: ML071510558OFFICEFFLDFFLDFSMETech EdFFLDNRRNAMERWescottLWilliamsonAMcIntoshEKraus (via fax)BSmithSWeerakkodyDATE06/01/0706/04/0705/29/0706/15/0706/07/0707/24/07OFFICENRRNRRNRRNRRFCSSNAMECHawesDBeaulieuMMurphyTQuay for MCaseRPiersonDATE07/30/0707/30/0708/06/0708/06/0708/08/07OFFICIAL RECORD COPY EnclosureRecently Issued Federal and State Materials and Environmental Management Programs/ Nuclear Material Safety and Safeguards Generic Communications DateGC No.Subject
Addressees
02/02/07IN 07-03Reportable Medical EventsInvolving Patients Receiving Dosages of Sodium Iodide Iodine-131 less than the Prescribed Dosage Because of Capsules Remaining in Vials after AdministrationAll NRC medical use licenseesand NRC Master Materials Licensee All Agreement State Radiation Control Program Directors and State Liaison Officers.02/28/07IN 07-08Potential Vulnerabilities ofTime-reliant Computer-based Systems Due to Change in Daylight Saving Time DatesAll NRC licensees and allAgreement State Radiation Control Program Directors and State Liaison Officers.03/15/07IN 07-10Yttrium-90 Theraspheresand Sirspheres ImpuritiesAll NRC Medical Licensees andNRC Master Materials Licensee All Agreement State Radiation Control Program Directors and State Liaison Officers.04/04/07IN 07-13Use of As-Found Conditionsto Evaluate Criticality-related Process Upsets at Fuel Cycle FacilitiesAll licensees authorized topossess a critical mass of special nuclear material.05/02/07IN 07-16Common Violations of theIncreased Controls Requirements and Related Guidance DocumentsAll licensees who areimplementing the NRC Order Imposing Increased Controls (EA-05-090), issued November 14, 2005, and December 22, 2005.03/01/07RIS 07-03Ionizing Radiation WarningSymbolAll NRC licensees and certificateholder All Radiation Control Program Directors and State Liaison Officers DateGC No.Subject
Addressees
Enclosure03/09/07RIS 07-04Personally IdentifiableInformation Submitted to the NRCAll holders of operating licensesfor nuclear power reactors and holders of and applicants for certificates for reactor design All licensees, certificate holders, applicants, and other entities subject to regulation by the NRC of the use of source, byproduct, and special nuclear materia /20/07RIS 07-05Status and Plans forImplementation of NRC Regulatory Authority for Certain Naturally-occurring and Accelerator-produced Radioactive MaterialAll NRC materials licensees,Radiation Control Program Directors, State Liaison Officers, and NRC's Advisory Committee on the Medical Uses of Isotope /05/07RIS 07-07Clarification of IncreasedControls for Licensees That Possess Collocated Radioactive Material During Transportation Activities All NRC licensees issued NRC'sOrder Imposing Increased Controls and all Radiation Control Program Directors and State Liaison Officer /04/07RIS 07-09Examples of RecurringRequests for Additional Information for 10 CFR Part 71 and 72 ApplicationsAll holders of, and applicants for,a: (1) 10 CFR Part 71 certificate of compliance (CoC) for a radioactive material transportation 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.05/15/07RIS 07-10Subscriptions To New ListServer For Automatic Notifications Of Medical-Related Generic Communications, FederalRegister Notices AndNewslettersAll NRC medical-use licenseesand NRC Master Materials licensee All Radiation Control Program Directors and State Liaison Officers.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.