Technical Specification 5.4.1 states, in part, that written procedures shall be implemented covering the
Fire Protection Program. Licensee Procedure 4-AWI-08.01.00,
Fire Protection Program Plan, implements the
TS 5.4.1 requirement. Operations Manual B.08.05-05, Fire Protection System Operation, is considered an implementing document that supports the
Fire Protection Program. Specification F.1 of Table A.2-1, Operating Requirements Fire Detection and Protection Systems, contained within B.08.05-05 states, in part, that the cable spreading room (CSR) halon system shall be
operable with the storage tanks having at least 90 percent of full charge pressure. Specification F.2 of Table A.2-1 states, in part, that if Specification F.1 cannot be met, a
continuous fire watch with backup fire suppression equipment in the CSR is to be established within one hour. Contrary to this requirement, on August 31, 2009, the licensee did not station a
continuous fire watch with backup fire suppression equipment in the CSR within one hour when the as-found pressure of one of four CSR halon system storage tanks resulted in the total available CSR halon system tank pressure being less than 90 percent full charge pressure. After recognizing the halon system storage tank pressure issue on September 1, 2009, the licensee immediately aligned the reserve halon bank and entered the issue into their corrective action program as
CAP 01183755. The inspectors applied
IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings to this finding. Using the Table 3b worksheet, the inspectors transitioned to
IMC 0609, Appendix F, Fire Protection
SDP Phase 1 Qualitative Screening Approach, Step 1.1. The inspectors selected the Fixed Fire Protection System finding category. Per Step 1.2, the inspectors used
IMC 0609, Appendix F, Attachment 2, Degradation Rating Guidance Specific to Various
Fire Protection Program Elements, to determine the degradation rating. Under the Gaseous Based Suppression section, the inspectors determined that the finding was associated with a
LOW degradation rating because the as-found halon discharge time would not have exceeded the allowable discharge time by more than 25 percent. This conclusion was based on the inspectors review of conservative licensee evaluations for worst case halon system storage tank pressure and resultant discharge time. Per Step 1.3 of
IMC 0609, Appendix F Phase 1 Qualitative Screening Approach, Initial Qualitative Screening, because the finding was assigned a
LOW degradation rating, it was considered to be of very low safety significance (Green) with no further analysis required
