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At 1330 on January 12, 2005, station perso … At 1330 on January 12, 2005, station personnel identified an error in connection of pilot lines to the manual-pneumatic actuator on halon bottles required for fire suppression. The vendor was contacted to confirm the configuration. The vendor indicated that the halon bottles would not properly discharge if the pilot lines were not properly connected.</br>The system engineer inspected the halon systems. It was determined that five of six fire areas protected by halon systems were affected. Fire watches were implemented for the affected fire areas.</br>Affected areas:</br>A-27, Load Center/MG set Room, main - correct, reserve - 1 valve correct/1 valve incorrect</br>A-17, South Electrical Penetration Room, main - correct, reserve - incorrect</br>A-18, North Electrical Penetration Room, Main - correct, reserve - correct</br>C-9, ESF Switchgear room 1*, main - incorrect, reserve - incorrect</br>C-10, ESF Switchgear room 2*, main - incorrect, reserve - incorrect</br>C-27, Control room cable trenches/chases**, bottle 1 - correct, bottle 2 - incorrect</br>The main bank is sufficient to suppress a fire in a fire area.</br>* One halon system protects both of the fire areas.</br>** One halon bottle will provide general area coverage. The second bottle ensures sufficient halon concentration for upper portions of the cable chases in the control room.</br>The design and licensing basis for the fire protection system does not require consideration of a fire in more than one fire area at a time. No degraded fire barriers between the above fire areas were identified which would have allowed a fire to affect more than one of the fire areas at a time.</br>Repairs were immediately initiated to correct the condition. As of 2010 CST, the repairs have been completed for the affected fire areas and restored to operable status.</br>The licensee notified the NRC Resident Inspector.</br>* * * RETRACTION FROM H. BRADLEY TO W. GOTT AT 1225 ON 2/23/05 * * *</br>Investigation - Informational tests conducted by the Vendor (Chemetron) and witnessed by Wolf Creek, Callaway, and NRC personnel on January 26, 2005 determined that the Halon systems would have properly actuated in the as-found incorrect configuration (port 'A' and 'B' connections reversed). The only identified difference in the actuation sequence between the tests conducted in the incorrect configuration versus the correct configuration is a delay of less than 2 seconds from the time the solenoid received the discharge signal until the first cylinder actuated. There is no regulatory or National Fire Protection Association standard or guideline that places a time requirement on this interval. This very slight time delay would have had no effect on the designed function of the Halon suppression system to extinguish a fire. Additional details are provided in the Chemetron report, 'Report on Actuation Arrangements for Halon Extinguishing System Units,' (Correspondence ULNRC 05-121) that includes the test procedure and results. Halon system function is to establish sufficient halon concentration for sufficient time to suppress a fire. This capability was not lost with the delay in actuation.</br>Regulatory Evaluation - Guidance for reporting to the criterion of 10 CFR 50.73(a)(2)(ii) is provided in section 3.2.4 of NUREG 1022 rev 2, 'Event Reporting Guidelines 10 CFR50.72 and 50.73.' This guidance states that an LER is required for a seriously degraded principal safety barrier or an unanalyzed condition that significantly degrades plant safety.</br>Operating License Condition 2.C(5)(c) states the following:</br>The Operating Corporation shall maintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 15, the Callaway site addendum through Revision 8, and as approved in the SER through Supplement 4, subject to provisions d below.</br>Conclusion: - Based upon the information provided, the Halon suppression system would have operated to extinguish a fire. This condition is not considered reportable to the requirements of 10 CFR 50.72(b)(3)(ii)(B), 10 CFR 50.73(a)(2)(ii), nor is it a violation of the Operating License Condition 2.C(5)(c). Consistent with this conclusion, ENS notification number 41326 for this event is to be retracted.</br>The licensee notified the NRC Resident Inspector.ensee notified the NRC Resident Inspector.
19:30:00, 12 January 2005 +
41,326 +
21:48:00, 12 January 2005 +
19:30:00, 12 January 2005 +
At 1330 on January 12, 2005, station perso … At 1330 on January 12, 2005, station personnel identified an error in connection of pilot lines to the manual-pneumatic actuator on halon bottles required for fire suppression. The vendor was contacted to confirm the configuration. The vendor indicated that the halon bottles would not properly discharge if the pilot lines were not properly connected.</br>The system engineer inspected the halon systems. It was determined that five of six fire areas protected by halon systems were affected. Fire watches were implemented for the affected fire areas.</br>Affected areas:</br>A-27, Load Center/MG set Room, main - correct, reserve - 1 valve correct/1 valve incorrect</br>A-17, South Electrical Penetration Room, main - correct, reserve - incorrect</br>A-18, North Electrical Penetration Room, Main - correct, reserve - correct</br>C-9, ESF Switchgear room 1*, main - incorrect, reserve - incorrect</br>C-10, ESF Switchgear room 2*, main - incorrect, reserve - incorrect</br>C-27, Control room cable trenches/chases**, bottle 1 - correct, bottle 2 - incorrect</br>The main bank is sufficient to suppress a fire in a fire area.</br>* One halon system protects both of the fire areas.</br>** One halon bottle will provide general area coverage. The second bottle ensures sufficient halon concentration for upper portions of the cable chases in the control room.</br>The design and licensing basis for the fire protection system does not require consideration of a fire in more than one fire area at a time. No degraded fire barriers between the above fire areas were identified which would have allowed a fire to affect more than one of the fire areas at a time.</br>Repairs were immediately initiated to correct the condition. As of 2010 CST, the repairs have been completed for the affected fire areas and restored to operable status.</br>The licensee notified the NRC Resident Inspector.</br>* * * RETRACTION FROM H. BRADLEY TO W. GOTT AT 1225 ON 2/23/05 * * *</br>Investigation - Informational tests conducted by the Vendor (Chemetron) and witnessed by Wolf Creek, Callaway, and NRC personnel on January 26, 2005 determined that the Halon systems would have properly actuated in the as-found incorrect configuration (port 'A' and 'B' connections reversed). The only identified difference in the actuation sequence between the tests conducted in the incorrect configuration versus the correct configuration is a delay of less than 2 seconds from the time the solenoid received the discharge signal until the first cylinder actuated. There is no regulatory or National Fire Protection Association standard or guideline that places a time requirement on this interval. This very slight time delay would have had no effect on the designed function of the Halon suppression system to extinguish a fire. Additional details are provided in the Chemetron report, 'Report on Actuation Arrangements for Halon Extinguishing System Units,' (Correspondence ULNRC 05-121) that includes the test procedure and results. Halon system function is to establish sufficient halon concentration for sufficient time to suppress a fire. This capability was not lost with the delay in actuation.</br>Regulatory Evaluation - Guidance for reporting to the criterion of 10 CFR 50.73(a)(2)(ii) is provided in section 3.2.4 of NUREG 1022 rev 2, 'Event Reporting Guidelines 10 CFR50.72 and 50.73.' This guidance states that an LER is required for a seriously degraded principal safety barrier or an unanalyzed condition that significantly degrades plant safety.</br>Operating License Condition 2.C(5)(c) states the following:</br>The Operating Corporation shall maintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 15, the Callaway site addendum through Revision 8, and as approved in the SER through Supplement 4, subject to provisions d below.</br>Conclusion: - Based upon the information provided, the Halon suppression system would have operated to extinguish a fire. This condition is not considered reportable to the requirements of 10 CFR 50.72(b)(3)(ii)(B), 10 CFR 50.73(a)(2)(ii), nor is it a violation of the Operating License Condition 2.C(5)(c). Consistent with this conclusion, ENS notification number 41326 for this event is to be retracted.</br>The licensee notified the NRC Resident Inspector.ensee notified the NRC Resident Inspector.
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