ML111230053

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

ML111230053
Person / Time
Site:	Surry
Issue date:	05/02/2011
From:	Hartz L Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
11-194, 2-2010-029, EA-10-255, IR-11-012
Download: ML111230053 (4)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 May 2, 2011 United States Nuclear Regulatory Commission Serial No.11-194 Attention: Document Control Desk SPS:BAG Washington, D. C. 20555-0001 Docket Nos. 50-280 50-281 License Nos. 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,

~.~t1 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. 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. 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 VaultlTunnel and Unit 2 Cable VaultlTunnel.

This is a Severity Level IV violation (Supplement VII)."

REPLY TO A NOTICE OF VIOLATION; 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) 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 the Unit 1 Emergency Switchgear Room (ESGR), Unit 2 ESGR, Unit 1 Cable VaultlTunnel, and Unit 2 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.

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.

The company initiated an investigation to determine and document the extent of the laborer's misconduct. 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.

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 misconduct.

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.

4. The Date When Full Compliance Will be Achieved Full compliance has been achieved.