License Condition 2.C(6) requires the licensee to implement and maintain in effect all provisions of the approved
fire protection program as described in the Final Safety Analysis Report, as amended, and as approved through Safety Evaluation Report (
NUREG-0887) dated May 1982, and supplement numbers 1 through 10. Section 9A of Perrys
USAR describes the approved
fire protection program. Section 9A.5.B.5.(b) of the
USAR states, in part, Drills will be conducted according to procedures and instructions sub-tier to Perry Administrative Procedure (
PAP)-1910,
Fire Protection Program, which requires as a minimum, one drill per quarter per shift, and at least one annual drill with local fire department participation. In PAP-1910, Section 4.5.3 Member Training, the instruction states, in part, The fire brigade must be properly trained (qualified), receive routine updates and undergo requalification to ensure the team is prepared to combat fires. Further in PAP-1910 it states in subparagraph 2, The scheduling of fire brigade drills in accordance with Fire Protection Instruction (FPI)-A-B02, Fire Brigade Drills, is assigned to the fire protection staff to administer. In Section 1.0 of FPI-A-B02 under Purpose, the instruction states, in part, that This instruction identifies drills involving a credible simulated emergency that requires personnel to perform emergency response operations for the purpose of evaluating the effectiveness of the training and education programs and the competence of personnel in performing required response duties and functions. Similarly, Section 5.1 of FPI-A-B02 Fire Drills, the instruction states, in part, A fire drill is an exercise designed to evaluate the response actions of the fire brigade, Reactor Operator, Unit Supervisors, Shift Managers, Supervisor Nuclear Security Operations, Secondary Alarm Station Operators, and other support personnel to fire alarms and simulated fire emergencies. Further, Section 6.3 Drill Assessment, states, in part, that the drill assessment will, Assess the fire alarm effectivenss..., Members Knowledge..., Fire Fighting Methods..., Simulated Actions..., Brigade Leaders Response/Actions... and Organization Response/Actions... Contrary to the above, between December 6, 2011, and December 13, 2012, the licensee took credit for a fire response conducted outside the plant at the plant training center and, on at least five occasions, the licensee also took credit for fire responses when the fire brigade was toned out or activated for other activities, but not for actual fires. The finding was determined to be more than minor in accordance with
Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, because the finding was associated with the
Mitigating Systems Cornerstone attribute of Protection Against External Factors for Fire and adversely impacted the cornerstone objective of ensuring the reliability and capability of the fire brigade to respond to
initiating events to prevent undesirable consequences. The finding was evaluated using
IMC 0609,
Significance Determination Process (
SDP), Attachment 0609.04, Initial Characterization of Findings, dated June 19, 2012. Because the finding involved the Fire Brigade, Table 3,
SDP Appendix Router, Section E.1, Fire Protection, directed NRC staff to use
IMC 0609, Appendix A, The
SDP for Findings At-Power, dated June 19, 2012. Exhibit 2 of
IMC 0609, the
Mitigating Systems Screening Questions, Section D.1.a, Fire Brigade, was checked yes because the finding involved the Fire Brigade training and qualification requirements. The first condition under D.1.a., The fire brigade demonstrated the ability to meet the required times for fire extinguishment for the drill scenarios, was applicable and the finding did not significantly affect the ability of the fire brigade to respond to a fire, so the finding was determined to be of very low safety significance.
