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{{Adams
{{Adams
| number = ML111230053
| number = ML110900445
| issue date = 05/02/2011
| issue date = 03/31/2011
| title = Reply to a Notice of Violation EA-10-255, NRC Inspection Report No. 50-280/2011-012 and 50-281/2011-012, NRC Office of Investigations Report 2-2010-029 and Notice of Violation
| title = IR 05000280-11-012 & 05000281-11-012, and Notice of Violation, on 01/28/11 - 02/16/11, Surry Power Station, Units 1 & 2
| author name = Hartz L
| author name = Mccoy G
| author affiliation = Virginia Electric & Power Co (VEPCO)
| author affiliation = NRC/RGN-II/DRP/RPB5
| addressee name =
| addressee name = Heacock D
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| addressee affiliation = Virginia Electric & Power Co (VEPCO)
| docket = 05000280, 05000281
| docket = 05000280, 05000281
| license number = DPR-032, DPR-037
| license number = DPR-032, DPR-037
| contact person =  
| contact person =  
| case reference number = 11-194, 2-2010-029, EA-10-255, IR-11-012
| case reference number = EA-10-255
| document type = Letter, Licensee Response to Enforcement Action, Licensee Response to Notice of Violation
| document report number = 2-2010-029, IR-11-012
| page count = 4
| document type = Inspection Report, Notice of Violation
| page count = 14
}}
}}


Line 18: Line 19:


=Text=
=Text=
{{#Wiki_filter:VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 May 2, 2011 United States Nuclear Regulatory Commission Attention:
{{#Wiki_filter:March 31, 2011
Document Control Desk Washington, D.C.20555-0001 Serial No.SPS:BAG Docket Nos.License Nos.11-194 50-280 50-281 DPR-32 DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 REPLY TO A NOTICE OF VIOLATION EA-10-255 NRC INSPECTION REPORT NOS.50-280/2011-012 AND 50-281/2011-012 NRC OFFICE OF INVESTIGATIONS REPORT 2-2010-029 AND NOTICE OF VIOLATION Virginia Electric and Power Company (Dominion)
has reviewed Inspection Report Nos.50-280/2011-012 and 50-281/2011-012 dated March 31, 2011 for Surry Units 1 and 2.The report contained a Notice of Violation (NOV)for the failure of an individual to perform his assigned fire watch rounds and then deliberately document that the fire watch rounds were complete.Dominion's response to the Notice of Violation is attached.If you have any questions, please contact Mr.David Sommers at (804)273-2823.Very truly yours, Vice President-Nuclear Support Services Attachment Commitment:
1.Management will continue to periodically verify the performance of workers assigned fire watch duties on backshifts and weekends when supervision is not present by reviewing fire watch logs records or direct observations.


cc: U.S.Nuclear Regulatory Commission, Region II Attn: Regional Administrator Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector Surry Power Station REPLY TO A NOTICE OF VIOLATION; EA-10-255 INSPECTION REPORT NOS.50-280/2011-012 AND 50-281/2011-012 NOTICE OF VIOLATION: "During an NRC 01 investigation completed on December 8, 2010 and an in-office review, a violation of NRC requirements was identified.
==SUBJECT:==
SURRY POWER STATION - NRC INSPECTION REPORT 05000280/2011012, 05000281/2011012, NRC OFFICE OF INVESTIGATIONS REPORT 2-2010-029 AND NOTICE OF VIOLATION


In accordance with the NRC Enforcement Policy in effect at the time, the violation is listed below: 10 CFR 50.48 Fire Protection, requires that a licensee must have a fire protection plan that, in part, outlines the plans for fire protection, fire detection and suppression capability, and limitation of fire damage.Surry Power Station Renewed Facility Operating License, Condition 3.1"Fire Protection," states, in part, that the licensee shall maintain in effect the provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR)and as approved in the Safety Evaluation Report (SER)and subsequent supplements.
==Dear Mr. Heacock:==
On December 8, 2010, the Nuclear Regulatory Commissions (NRC) Office of Investigations completed an investigation and in-office review at Surry Power Station to determine, in part, whether a former laborer failed to conduct a roving fire watch patrol and deliberately falsified subsequent documentation. Based on the results of the investigation, the NRC concluded that the individual deliberately failed to follow station procedure CM-AA-FPA-100, Revision 1, Fire Protection/Appendix R (Fire Safe Shutdown) Program, Attachment 2. The results of the investigation were discussed on March 30, 2011, with Mr. Bischof and other members of your staff. The enclosed inspection report presents the findings resulting from this investigation.


The UFSAR requires, in part, that the fire protection program (FPP)meet Appendix A to Branch Technical Position (BTP)APCSB 9.5-1,"Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1, 1976," dated August 23, 1976." Section C.2 of Appendix A to BTP APCSB 9.5-1 requires, in part, that inspections, tests, administrative controls, fire drills and training that govern the fire protection program should be prescribed by documented instructions, procedures or drawings and should be accomplished in accordance with these documents.
During this inspection, the NRC staff examined activities conducted under your license as they relate to public health and safety and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel.


Dominion Administrative procedure CM-AA-FPA-100, Revision 1,"Fire Protection/Appendix R (Fire Safe Shutdown)Program," Attachment 2, North Anna Power Station and Surry Power Station Program Requirements, Section 3.6.2.g, states in part that, a fire watch shall document their rounds on the Fire Watch Tour Documentation Sheet (Attachment 14).Contrary to the above, from approximately 2100 on May 4,2010 to 0400 on May 5, 2010, an individual assigned as a fire watch deliberately documented the completion of fire watch rounds (Fire Watch Tour Documentation Sheet, Attachment 14)for locations in which he did not conduct the fire watches.The affected plant locations were in the Unit 1 Emergency Switchgear Room (ESGR), Unit 2 ESGR, Unit 1 Cable VaultlTunnel and Unit 2 Cable VaultlTunnel.
Based on the staffs review of the facts and circumstances in this case, the NRC has determined that a Severity Level IV violation of NRC requirements occurred. The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site at (http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html).


This is a Severity Level IV violation (Supplement VII)."
The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in the enclosed inspection report. The violation is being cited because of the willful aspects, and because of the repetitive nature of the employees missed fire watches, in accordance with Section VI.A.1 of the NRCs Enforcement Policy in effect at the time of the violation. The NRC also notes that Surrys internal investigation identified numerous additional examples of missed fire watches and related falsified documentation involving this employee.


REPLY TO A NOTICEOFVIOLATION; EA-10-255 INSPECTION REPORT NOS.50-280/2011-012 AND 50-281/2011-012 1.Reason for the Violation, or, if Contested, the Basis for Disputing the Violation or Severity Level Virginia Electric and Power Company (Dominion)
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
does not contest the violation.


Based upon the conclusions of a company initiated investigation, a laborer who was assigned fire watch duties on May 4 and May 5, 2010 for affected areas of the plant in theUnit1 Emergency Switchgear Room (ESGR),Unit2 ESGR, Unit 1 Cable VaultlTunnel, andUnit2 Cable VaultlTunnel, failed to complete the fire watch rounds and willfully documented the completion of these rounds in fire watch logs.This individual had been properly trained and qualified to conduct fire watches.He was briefed by his supervisors on the duties, responsibilities, and expectations for conducting and documenting fire watches, and prior to performing fire watches, the laborer had been briefed on the status and assignment of the fire watches.As a result of the company investigation, Dominion concludes that the individual understood his duties, responsibilities, and expectations, but chose to violate Dominion policies and procedures, including the Fire Protection Procedure.
VEPCO


2.Corrective Steps Which Have Been Taken and the Results Achieved Upon discovering the laborer's misconduct on May 5, 2010, an operator was properly briefed and assumed the fire watch requirements for the affected areas.The laborer was escorted out of the Protected Area and his badge was deactivated.
Additionally, as discussed above, Surrys internal investigation of this matter identified numerous additional examples of missed fire watches and related falsified documentation, occurring over several months. In light of the above, the NRC requests that your response address corrective actions that have or will be implemented to permit or allow for early identification of similar non-compliances, should they occur in the future.


The company initiated an investigation to determine and document the extent of the laborer's misconduct.
Based on the results of this inspection, no findings of significance were identified. However, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. NRC is treating this violation as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy because of the very low safety significance of the violation and because it is entered into your corrective action program. If you contest this non-cited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Surry Power Station.


The investigation concluded that the occurrences extended back to September 2009 and occurred on nights and weekend shifts when no direct supervision was present.The individual remained offsite during the investigation and after the completion of the investigation, the laborer's employment was terminated.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).


The investigation also reviewed the performance of other workers used for fire watch duties, but did not find that any other workers engaged in misconduct with respect to their assigned fire watch duties.Management confirmed the results of the investigation by comparing key card entry records with fire watch logs and identified no additional cases of misconduc Management met with workers assigned fire watch duties to reiterate expectations regarding the performance of fire watch duties, as well as reminding them of their duty to report violations of policy or procedures, the responsibility to report to work fit for duty, and their duty to report fitness for duty (FFD)issues.It was communicated that compliance with these expectations maintains employee trustworthiness and is a condition of unescorted access to the station.3.Corrective Steps Which Will be Taken to Avoid Further Violations Management will continue to periodically verify the performance of workers assigned fire watch duties on backshifts and weekends when supervision is not present by reviewing fire watch logs records or direct observations.
Sincerely,
/RA/


4.The Date When Full Compliance Will be Achieved Full compliance has been achieved.
Gerald J. McCoy, Chief
 
Reactor Projects Branch 5
 
Division of Reactor Projects Docket Nos.: 50-280, 50-281 License Nos.: DPR-32, DPR-37
 
cc w/Encls: (See Page 3)
 
===Enclosures:===
1. Notice of Violation
 
2. Inspection Report 05000280/2011012, 05000281/2011012
 
w/Attachment: Supplemental Information
 
3. OI Synopsis, Investigation 2-2010-029
 
_ ML110900445_________________
 
X SUNSI REVIEW COMPLETE OFFICE RII:DRP RII:DRP RII:EICS
 
SIGNATURE
/RA/
/RA/
/RA/
 
NAME DArnett GMcCoy CEvans
 
DATE 3/29/11 3/29/11 3/30/11
 
E-MAIL COPY?
YES NO YES NO YES NO YES NO YES NO YES NO YES NO
 
VEPCO
 
REGION II==
Docket Nos.:
50-280, 50-281
 
License Nos.:
DPR-32, DPR-37
 
Report No:
05000280/2011012, 05000281/2011012
 
Licensee:
 
Virginia Electric and Power Company (VEPCO)
 
Facility:
 
Surry Power Station, Units 1 and 2
 
Location:
 
5850 Hog Island Road
 
Surry, VA 23883
 
Dates:
 
January 28, 2011 through February 16, 2011
 
Inspectors:
 
D. Arnett, RII Project Engineer
 
Approved by:
Gerald J. McCoy, Chief
 
Reactor Projects Branch 5
 
Division of Reactor Projects
 
Enclosure 2
 
=SUMMARY OF FINDINGS=
IR 05000280/2011012, 05000281/2011012; 1/28/2011 - 2/16/2011; Surry Power Station; Fire
 
Protection
 
The report covered an in-office review of NRC Office of Investigations (OI) Report No. 2-2010-029 by a project engineer. One Severity Level IV violation was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609,
Significance Determination Process. Findings for which the Significance Determination Process does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 4, dated December 2006.
 
===NRC Identified and Self Revealing Findings===
===Cornerstone: Mitigating Systems===
C Severity Level IV: The licensee identified a violation of 10 CFR 50.48 Fire Protection requirements when it was determined that a laborer failed to conduct a roving fire watch patrol. The licensee took substantial disciplinary actions and entered the deficiency into the corrective action program for resolution as CR 379888.
 
This issue was dispositioned using traditional enforcement due to the deliberate aspects of the performance deficiency. Furthermore, the failure to provide complete and accurate information has the potential to impact the NRCs ability to perform its regulatory function.
 
An individual assigned as a fire watch deliberately documented the completion of fire watch rounds (Fire Watch Tour Documentation Sheet, Attachment 14) for locations in which he did not conduct the fire watches. This issue was considered more than minor due to the deliberate aspects of the performance deficiency. In accordance with the guidance in Supplement VII of the Enforcement Policy, this issue is considered a Severity Level IV violation because it involved information that the NRC required to be maintained by a licensee that was incomplete or inaccurate and of more than minor safety significance. No cross-cutting aspect was identified because this performance deficiency was dispositioned using traditional enforcement.
 
===Licensee Identified Violations===
A violation of very low safety significance which was identified by the licensee was reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and corrective actions are listed in Section 4OA7 of this report.
 
=REPORT DETAILS=
 
==REACTOR SAFETY==
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
{{a|1R05}}
 
==1R05 Fire Protection
 
====a. Inspection Scope====
==
The inspector reviewed the OI summary and transcripts of interviews conducted by OI investigators related to fire watches conducted by a laborer as well as license conditions, procedures and the UFSAR to determine if violations of regulatory requirements occurred.
 
====b. Findings====
=====Introduction:=====
The licensee identified a violation of 10 CFR 50.48: Fire Protection requirements when it was determined that a laborer failed to conduct a roving fire watch patrol.
 
=====Description:=====
Over the course of the night shift of May 4, 2010, the Operations Shift Manager became suspicious of one of the individuals who had been tasked to perform hourly firewatch walkdowns because the operations shift had delays in trying to contact him on several occasions and he had been observed in the break area frequently during the shift. At approximately 5:00 AM on May 4, 2010, the shift manager reviewed the security keycard report for the individual in question and found that he had not been in the firewatch locations from approximately 11:00 PM on May 4, 2010 to 4:00 AM on May 5, 2010. A Fire Watch Tour Documentation Sheet, Attachment 14 had been signed off by this individual for the time period in question.
 
The licensees investigation determined that the laborer knew he had not conducted the fire checks when he completed the documentation. Additionally, the licensees investigation found that the individual previously missed numerous other fire watches during the period August 1, 2009 to April 18, 2010. The laborer was subsequently terminated and the pertinent data was placed in Personnel Access Data System.
 
=====Analysis:=====
The failure to provide complete and accurate information regarding completion of the fire watches on the Fire Watch Tour Documentation Sheet (Attachment 14) was a performance deficiency. This issue was dispositioned using traditional enforcement due to the deliberate aspects of the performance deficiency. Furthermore, the failure to provide complete and accurate information has the potential to impact the NRCs ability to perform its regulatory function. This issue was considered more than minor due to the deliberate aspects of the performance deficiency. In accordance with the guidance in Supplement VII of the Enforcement Policy, this issue is considered a Severity Level IV violation because it involved information that the NRC required to be maintained by a licensee that was incomplete or inaccurate which was more than minor safety significance.
 
No cross-cutting aspect was identified because this performance deficiency was dispositioned using traditional enforcement.
 
=====Enforcement:=====
10 CFR 50.48: Fire Protection, requires that a licensee must have a fire protection plan that, in part, outlines the plans for fire protection, fire detection and suppression capability, and limitation of fire damage. Surry Power Station Renewed Facility Operating License, Condition 3.I Fire Protection, states in part that the licensee shall maintain in effect the provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report and as approved in the Safety Evaluation Report (SER) and subsequent supplements. The UFSAR requires, in part, that the fire protection program (FPP) meet Appendix A to Branch Technical Position (BTP) APCSB 9.5-1, Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1, 1976," dated August 23, 1976. Section C.2 of Appendix A to BTP APCSB 9.5-1 requires, in part, that inspections, tests, administrative controls, fire drills and training that govern the fire protection program should be prescribed by documented instructions, procedures or drawings and should be accomplished in accordance with these documents. Dominion Administrative procedure CM-AA-FPA-100, Revision 1, Fire Protection/Appendix R (Fire Safe Shutdown) Program, Attachment 2, North Anna Power Station and Surry Power Station Program Requirements, Section 3.6.2.g, states in part that, a fire watch shall document their rounds on the Fire Watch Tour Documentation Sheet (Attachment 14).
 
Contrary to the above, from approximately 2100 on May 4, 2010 to 0400 on May 5, 2010, an individual assigned as a fire watch deliberately documented the completion of fire watch rounds (Fire Watch Tour Documentation Sheet, Attachment 14) for locations in which he did not conduct the fire watches. The affected plant locations were in the Unit 1 Emergency Switchgear Room (ESGR), Unit 2 ESGR, Unit 1 Cable Vault/Tunnel and Unit 2 Cable Vault/Tunnel.
 
The violation is being cited because of the willful aspects, and because of the repetitive nature of the employees missed fire watches, in accordance with Section VI.A.1 of the NRCs Enforcement Policy in effect at the time of the violation: VIO 05000280/2011012-01, 05000281/2011012-01 Inaccurate Fire Watch Records.
 
{{a|4OA6}}
 
==4OA6 Meetings, Including Exit==
===Exit Meeting Summary===
On March 30, 2011, the results of this inspection were presented to Mr. Bischof, Site Vice-President, and other members of the licensee staff, who acknowledged the findings. No proprietary information was provided or examined during the inspection.
 
{{a|4OA7}}
 
==4OA7 Licensee-Identified Violation==
The following finding of very low significance was identified by the licensee and is a violation of NRC requirements which meet the criteria of Section 2.3.2 of the NRC Enforcement Policy, for characterization as a Green Non-Cited Violation (NCV).
* 10 CFR 50.48: Fire Protection, requires in part that a licensee must have a fire protection plan that outlines the plans for fire protection, fire detection and suppression capability, and limitation of fire damage. Contrary to this, the licensee identified that from approximately 2100 on May 4, 2010 to 0400 on May 5, 2010, an individual assigned as a fire watch deliberately documented the completion of fire watch rounds (Fire Watch Tour Documentation Sheet, 14) for locations in which he did not conduct the fire watches. The affected plant locations were in the Unit 1 Emergency Switchgear Room (ESGR),
Unit 2 ESGR, Unit 1 Cable Vault/Tunnel and Unit 2 Cable Vault/Tunnel. The deliberate aspect of this finding makes it greater than minor. This issue is in the licensees CAP as CR 379888.
 
=SUPPLEMENTAL INFORMATION=
 
KEY POINTS OF CONTACT
 
Licensee
: [[contact::G. Bischof]], Site Vice President
: [[contact::B. Garber]], S upervisor, Licensing
NRC
: [[contact::G. McCoy]], Chief, Division of Reactor Projects (DRP), Reactor Projects Branch 5 (RPB5)
: [[contact::D. Arnett]], Project Engineer, DRP, RPB5
 
LIST OF ITEMS OPENED, CLOSED, AND REVIEWED
Opened and Closed
05000280, 281/2011012-01
VIO
Inaccurate Fire Watch Records
 
NOT FOR PUBLIC DISCLOSURE WITHOUT APPROVAL OF
FIELD OFFICE DIRECTOR, OFFICE OF INVESTIGATIONS, REGION II
 
Official Use Only - OI Investigation Information
Case No. 2-2010-029
 
Official Use Only - OI Investigation Information
 
SYNOPSIS
 
This investigation was initiated on May 12, 2010, by the U.S. Nuclear Regulatory Commission
(NRC), Office of Investigations (OI), Region II (RII), to determine whether a former laborer
employed by Dominion Virginia Power (DVP), and working at the Surry Power Station (SPS),
deliberately failed to conduct firewatches and falsified fire watch logs.
Based on the documentation and testimony developed during this investigation OI:RII
substantiated the allegation that a former laborer employed by DVP, and working at SPS,
deliberately failed to conduct firewatches and deliberately falsified fire watch logs.
}}
}}

Latest revision as of 07:25, 13 January 2025

IR 05000280-11-012 & 05000281-11-012, and Notice of Violation, on 01/28/11 - 02/16/11, Surry Power Station, Units 1 & 2
ML110900445
Person / Time
Site: Surry  Dominion icon.png
Issue date: 03/31/2011
From: Gerald Mccoy
NRC/RGN-II/DRP/RPB5
To: Heacock D
Virginia Electric & Power Co (VEPCO)
References
EA-10-255 2-2010-029, IR-11-012
Download: ML110900445 (14)
v • d • e


Text

March 31, 2011

SUBJECT:

SURRY POWER STATION - NRC INSPECTION REPORT 05000280/2011012, 05000281/2011012, NRC OFFICE OF INVESTIGATIONS REPORT 2-2010-029 AND NOTICE OF VIOLATION

Dear Mr. Heacock:

On December 8, 2010, the Nuclear Regulatory Commissions (NRC) Office of Investigations completed an investigation and in-office review at Surry Power Station to determine, in part, whether a former laborer failed to conduct a roving fire watch patrol and deliberately falsified subsequent documentation. Based on the results of the investigation, the NRC concluded that the individual deliberately failed to follow station procedure CM-AA-FPA-100, Revision 1, Fire Protection/Appendix R (Fire Safe Shutdown) Program, Attachment 2. The results of the investigation were discussed on March 30, 2011, with Mr. Bischof and other members of your staff. The enclosed inspection report presents the findings resulting from this investigation.

During this inspection, the NRC staff examined activities conducted under your license as they relate to public health and safety and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel.

Based on the staffs review of the facts and circumstances in this case, the NRC has determined that a Severity Level IV violation of NRC requirements occurred. The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site at (http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html).

The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in the enclosed inspection report. The violation is being cited because of the willful aspects, and because of the repetitive nature of the employees missed fire watches, in accordance with Section VI.A.1 of the NRCs Enforcement Policy in effect at the time of the violation. The NRC also notes that Surrys internal investigation identified numerous additional examples of missed fire watches and related falsified documentation involving this employee.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.

VEPCO

Additionally, as discussed above, Surrys internal investigation of this matter identified numerous additional examples of missed fire watches and related falsified documentation, occurring over several months. In light of the above, the NRC requests that your response address corrective actions that have or will be implemented to permit or allow for early identification of similar non-compliances, should they occur in the future.

Based on the results of this inspection, no findings of significance were identified. However, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. NRC is treating this violation as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy because of the very low safety significance of the violation and because it is entered into your corrective action program. If you contest this non-cited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Surry Power Station.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Gerald J. McCoy, Chief

Reactor Projects Branch 5

Division of Reactor Projects Docket Nos.: 50-280, 50-281 License Nos.: DPR-32, DPR-37

cc w/Encls: (See Page 3)

Enclosures:

1. Notice of Violation

2. Inspection Report 05000280/2011012, 05000281/2011012

w/Attachment: Supplemental Information

3. OI Synopsis, Investigation 2-2010-029

_ ML110900445_________________

X SUNSI REVIEW COMPLETE OFFICE RII:DRP RII:DRP RII:EICS

SIGNATURE

/RA/

/RA/

/RA/

NAME DArnett GMcCoy CEvans

DATE 3/29/11 3/29/11 3/30/11

E-MAIL COPY?

YES NO YES NO YES NO YES NO YES NO YES NO YES NO

VEPCO

REGION II==

Docket Nos.:

50-280, 50-281

License Nos.:

DPR-32, DPR-37

Report No:

05000280/2011012, 05000281/2011012

Licensee:

Virginia Electric and Power Company (VEPCO)

Facility:

Surry Power Station, Units 1 and 2

Location:

5850 Hog Island Road

Surry, VA 23883

Dates:

January 28, 2011 through February 16, 2011

Inspectors:

D. Arnett, RII Project Engineer

Approved by:

Gerald J. McCoy, Chief

Reactor Projects Branch 5

Division of Reactor Projects

Enclosure 2

SUMMARY OF FINDINGS

IR 05000280/2011012, 05000281/2011012; 1/28/2011 - 2/16/2011; Surry Power Station; Fire

Protection

The report covered an in-office review of NRC Office of Investigations (OI) Report No. 2-2010-029 by a project engineer. One Severity Level IV violation was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609,

Significance Determination Process. Findings for which the Significance Determination Process does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 4, dated December 2006.

NRC Identified and Self Revealing Findings

Cornerstone: Mitigating Systems

C Severity Level IV: The licensee identified a violation of 10 CFR 50.48 Fire Protection requirements when it was determined that a laborer failed to conduct a roving fire watch patrol. The licensee took substantial disciplinary actions and entered the deficiency into the corrective action program for resolution as CR 379888.

This issue was dispositioned using traditional enforcement due to the deliberate aspects of the performance deficiency. Furthermore, the failure to provide complete and accurate information has the potential to impact the NRCs ability to perform its regulatory function.

An individual assigned as a fire watch deliberately documented the completion of fire watch rounds (Fire Watch Tour Documentation Sheet, Attachment 14) for locations in which he did not conduct the fire watches. This issue was considered more than minor due to the deliberate aspects of the performance deficiency. In accordance with the guidance in Supplement VII of the Enforcement Policy, this issue is considered a Severity Level IV violation because it involved information that the NRC required to be maintained by a licensee that was incomplete or inaccurate and of more than minor safety significance. No cross-cutting aspect was identified because this performance deficiency was dispositioned using traditional enforcement.

Licensee Identified Violations

A violation of very low safety significance which was identified by the licensee was reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and corrective actions are listed in Section 4OA7 of this report.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

==1R05 Fire Protection

a. Inspection Scope

==

The inspector reviewed the OI summary and transcripts of interviews conducted by OI investigators related to fire watches conducted by a laborer as well as license conditions, procedures and the UFSAR to determine if violations of regulatory requirements occurred.

b. Findings

Introduction:

The licensee identified a violation of 10 CFR 50.48: Fire Protection requirements when it was determined that a laborer failed to conduct a roving fire watch patrol.

Description:

Over the course of the night shift of May 4, 2010, the Operations Shift Manager became suspicious of one of the individuals who had been tasked to perform hourly firewatch walkdowns because the operations shift had delays in trying to contact him on several occasions and he had been observed in the break area frequently during the shift. At approximately 5:00 AM on May 4, 2010, the shift manager reviewed the security keycard report for the individual in question and found that he had not been in the firewatch locations from approximately 11:00 PM on May 4, 2010 to 4:00 AM on May 5, 2010. A Fire Watch Tour Documentation Sheet, Attachment 14 had been signed off by this individual for the time period in question.

The licensees investigation determined that the laborer knew he had not conducted the fire checks when he completed the documentation. Additionally, the licensees investigation found that the individual previously missed numerous other fire watches during the period August 1, 2009 to April 18, 2010. The laborer was subsequently terminated and the pertinent data was placed in Personnel Access Data System.

Analysis:

The failure to provide complete and accurate information regarding completion of the fire watches on the Fire Watch Tour Documentation Sheet (Attachment 14) was a performance deficiency. This issue was dispositioned using traditional enforcement due to the deliberate aspects of the performance deficiency. Furthermore, the failure to provide complete and accurate information has the potential to impact the NRCs ability to perform its regulatory function. This issue was considered more than minor due to the deliberate aspects of the performance deficiency. In accordance with the guidance in Supplement VII of the Enforcement Policy, this issue is considered a Severity Level IV violation because it involved information that the NRC required to be maintained by a licensee that was incomplete or inaccurate which was more than minor safety significance.

No cross-cutting aspect was identified because this performance deficiency was dispositioned using traditional enforcement.

Enforcement:

10 CFR 50.48: Fire Protection, requires that a licensee must have a fire protection plan that, in part, outlines the plans for fire protection, fire detection and suppression capability, and limitation of fire damage. Surry Power Station Renewed Facility Operating License, Condition 3.I Fire Protection, states in part that the licensee shall maintain in effect the provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report and as approved in the Safety Evaluation Report (SER) and subsequent supplements. The UFSAR requires, in part, that the fire protection program (FPP) meet Appendix A to Branch Technical Position (BTP) APCSB 9.5-1, Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1, 1976," dated August 23, 1976. Section C.2 of Appendix A to BTP APCSB 9.5-1 requires, in part, that inspections, tests, administrative controls, fire drills and training that govern the fire protection program should be prescribed by documented instructions, procedures or drawings and should be accomplished in accordance with these documents. Dominion Administrative procedure CM-AA-FPA-100, Revision 1, Fire Protection/Appendix R (Fire Safe Shutdown) Program, Attachment 2, North Anna Power Station and Surry Power Station Program Requirements, Section 3.6.2.g, states in part that, a fire watch shall document their rounds on the Fire Watch Tour Documentation Sheet (Attachment 14).

Contrary to the above, from approximately 2100 on May 4, 2010 to 0400 on May 5, 2010, an individual assigned as a fire watch deliberately documented the completion of fire watch rounds (Fire Watch Tour Documentation Sheet, Attachment 14) for locations in which he did not conduct the fire watches. The affected plant locations were in the Unit 1 Emergency Switchgear Room (ESGR), Unit 2 ESGR, Unit 1 Cable Vault/Tunnel and Unit 2 Cable Vault/Tunnel.

The violation is being cited because of the willful aspects, and because of the repetitive nature of the employees missed fire watches, in accordance with Section VI.A.1 of the NRCs Enforcement Policy in effect at the time of the violation: VIO 05000280/2011012-01, 05000281/2011012-01 Inaccurate Fire Watch Records.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On March 30, 2011, the results of this inspection were presented to Mr. Bischof, Site Vice-President, and other members of the licensee staff, who acknowledged the findings. No proprietary information was provided or examined during the inspection.

4OA7 Licensee-Identified Violation

The following finding of very low significance was identified by the licensee and is a violation of NRC requirements which meet the criteria of Section 2.3.2 of the NRC Enforcement Policy, for characterization as a Green Non-Cited Violation (NCV).

  • 10 CFR 50.48: Fire Protection, requires in part that a licensee must have a fire protection plan that outlines the plans for fire protection, fire detection and suppression capability, and limitation of fire damage. Contrary to this, the licensee identified that from approximately 2100 on May 4, 2010 to 0400 on May 5, 2010, an individual assigned as a fire watch deliberately documented the completion of fire watch rounds (Fire Watch Tour Documentation Sheet, 14) for locations in which he did not conduct the fire watches. The affected plant locations were in the Unit 1 Emergency Switchgear Room (ESGR),

Unit 2 ESGR, Unit 1 Cable Vault/Tunnel and Unit 2 Cable Vault/Tunnel. The deliberate aspect of this finding makes it greater than minor. This issue is in the licensees CAP as CR 379888.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

G. Bischof, Site Vice President
B. Garber, S upervisor, Licensing

NRC

G. McCoy, Chief, Division of Reactor Projects (DRP), Reactor Projects Branch 5 (RPB5)
D. Arnett, Project Engineer, DRP, RPB5

LIST OF ITEMS OPENED, CLOSED, AND REVIEWED

Opened and Closed

05000280, 281/2011012-01

VIO

Inaccurate Fire Watch Records

NOT FOR PUBLIC DISCLOSURE WITHOUT APPROVAL OF

FIELD OFFICE DIRECTOR, OFFICE OF INVESTIGATIONS, REGION II

Official Use Only - OI Investigation Information

Case No. 2-2010-029

Official Use Only - OI Investigation Information

SYNOPSIS

This investigation was initiated on May 12, 2010, by the U.S. Nuclear Regulatory Commission

(NRC), Office of Investigations (OI), Region II (RII), to determine whether a former laborer

employed by Dominion Virginia Power (DVP), and working at the Surry Power Station (SPS),

deliberately failed to conduct firewatches and falsified fire watch logs.

Based on the documentation and testimony developed during this investigation OI:RII

substantiated the allegation that a former laborer employed by DVP, and working at SPS,

deliberately failed to conduct firewatches and deliberately falsified fire watch logs.

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