The inspectors identified a non-cited violation of Units 1 & 2
Technical Specification 6.8.1.f for the licensees failure to implement procedures required for
fire protection program implementation. Specifically, the licensee failed to evaluate six minimum critical objectives on December 5, 2011, during a fire drill as required by TVA-SPP-17.16, Conduct and Evaluation of Fire Drills, revision 0. This issue was entered into the licensees corrective action program as Problem Evaluation Reports (PERs) 538996, 568242, and 568248. The performance deficiency was determined to be greater than minor because it was associated with the protection against external events attribute of the
mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. Specifically, the lack of adequate drill performance could negatively affect the fire brigades capability to combat a fire. Findings associated with performance of the fire brigade are not evaluated using
IMC 0609, Attachment F, Fire Protection
Significance Determination Process, and Appendix M,
Significance Determination Process Using Qualitative Criteria, as described in NRC
Inspection Manual Chapter 0609.04, Table 3b, Phase 1 - Initial Screening and Characterization of Findings. The NRC concluded that the finding was of very low safety significance (Green) because the defense-in-depth attribute of the fire brigade was minimally affected, in that, the evaluated crew was only one of four crews of the site fire brigade team, the other crews had adequately been evaluated, and that the overall condition of the fire detection and suppression systems has been satisfactory. The finding was determined to have a crosscutting aspect in the area of Problem Identification and Resolution because of inadequate oversight and self-assessment of fire operations department activities, specifically fire brigade training.
