An NRC-identified Green non-cited violation (
NCV) of Calvert Cliffs Nuclear Power Plant Renewed Facility Operating License
DPR-53, DRP-69, Condition E, was identified for Exelons failure to adequately assess the performance of the fire brigade during an announced fire drill. Specifically, Exelon failed to properly assess the command and control performance of the fire brigade leader (
FBL) which resulted in the fire drill being improperly evaluated as having met the assessment criteria. The inspectors determined that Exelons failure to properly assess fire brigade performance in accordance with
OP-AA-201-003, Fire Drill Performance, Revision 16, was a performance deficiency. Exelon has entered this issue into their corrective action program (
CAP) as action request (
AR) 04094397The inspectors reviewed
IMC 0612, Appendix B, Issue Screening, issued on September 7, 2012, and determined the issue is more than minor because it was associated with the protection against external events (fire) attribute of the
Mitigating Systems cornerstone and adversely affected its objective of ensuring the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. Specifically, failure to properly evaluate the performance of the fire brigade and correct identified deficiencies adversely affects the fire brigades ability to protect against the effects of a fire. In accordance with
IMC 0609, Attachment 4, Initial Characterization of Findings, issued on October 7, 2016, and
IMC 0609, Appendix A, The
Significance Determination Process for Findings at Power issued on June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) since it involved fire brigade training requirements, the fire brigade demonstrated the ability to meet the required times for fire extinguishment for the fire drill scenario, and the finding did not significantly affect the fire brigades ability to respond to a fire. The inspectors determined that the finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Self-Assessment, because Exelon did not conduct a self-critical and objective assessment of the fire brigades performance. Specifically, Exelon failed to conduct a self-critical and objective assessment of the
FBLs performance during the fire drill described above.
