Section 6.4.2.a of Procedure DB-FP-00005, Fire Brigade, Revision 17, permitted table-top exercises to be credited for fire drills. License Condition 2.C(4) requires the licensee to implement and maintain in effect all provisions of the approved
Fire Protection Program as described in the Updated Safety Analysis Report (
USAR). Section 9.5.1 of the
USAR states that the FHAR is incorporated in the
USAR by reference. In Appendix D, Compliance Matrix to Appendix A, of the FHAR, the licensee indicated that they complied with Position B5.b of NRC-Guidelines of Appendix A to Branch Technical Position 9.5-1 with respect to fire drills. Position B5.(b) stated fire brigades must operate as a team, drills provide fire brigades the opportunity to test itself in the major areas of the plant, drills should include the simulated use of equipment, and drills permit supervising personnel to evaluate the effectiveness of communications. The use of table-top exercises for drills did not allow for training as a team, testing themselves in major areas of the plant, simulating use of equipment in each area, and evaluating the effectiveness of communications. The inspectors determined that this issue was licensee identified because, at the time of the inspection, the licensee was in the process of reviewing the conduct of fire drills as documented by CR-2013-03331, Review of NRC Inspection Report issued for Kewaunee Power Station related to Fire Brigade Drills, dated March 7, 2013. The inspectors determined that the issue was of very low safety significance using
IMC 0609, Appendix M,
Significance Determination Process Using Qualitative Criteria, because the licensee took only minimal credit for table-top exercises. Specifically, in the prior year, 2012, the licensee took credit for only one table-top exercise involving three individuals for a drill. Each of the shift crews had participated in drills in the plant each quarter during 2012. The licensee had entered this issue into their Corrective Action Program as CR-2013-04610, NRCFP2013: NRC Observations on Fire Drills and Pre-Fire Plans and planned to revise their procedure to be consistent with their licensing basis.
