IR 05000395/2024001

Integrated Inspection Report 05000395/2024001

ML24130A142
Person / Time
Site:
Issue date:	05/10/2024
From:	Renee Taylor NRC/RGN-II/DRP/RPB3
To:	Carr E Dominion Energy Co
References
IR 2024001
Download: ML24130A142 (19)

Text

SUBJECT:

VIRGIL C. SUMMER - INTEGRATED INSPECTION REPORT 05000395/2024001

Dear Eric S. Carr:

On March 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Virgil C. Summer. On April 18, 2024, the NRC inspectors discussed the results of this inspection with Mr. Robert Justice and other members of your staff. The results of this inspection are documented in the enclosed report.

Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Virgil C. Summer.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Virgil C. Summer.May 10, 2024 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Ryan C. Taylor, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket No. 05000395 License No. NPF-12

Enclosure:

As stated

Inspection Report

Docket Number: 05000395

License Number: NPF-12

Report Number: 05000395/2024001

Licensee: Dominion Energy

Facility: Virgil C. Summer

Location: Jenkinsville, SC

Inspection Dates: January 01, 2024 to March 31, 2024

Inspectors: S. Battenfield, Operations Engineer M. Read, Senior Resident Inspector S. Roberts, Project Engineer M. Schwieg, Senior Reactor Inspector J. Walker, Senior Emergency Preparedness Inspector J. Zeiler, Senior Resident Inspector

Approved By: Ryan C. Taylor, Chief Reactor Projects Branch 3 Division of Reactor Projects

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Virgil C. Summer, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Failure to Properly Evaluate Transient Materials for Combustibility Resulting in Missed Continuous Fire Watch Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.2] - Field 71111.05 NCV 05000395/2024001-01 Presence Open/Closed An NRC-identified Green finding and associated non-cited violation (NCV) was identified of Operating License Condition 2.C.(18), Fire Protection Program, for the licensee's failure to properly evaluate transient materials for combustibility, which resulted in exceeding storage limits in a fire zone without an adequate fire watch.

Failure to Establish a Continuous Fire Watch While Detection Capability was Reduced Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.4] - 71152A NCV 05000395/2024001-02 Teamwork Open/Closed A self-revealed Green finding and associated NCV was identified of Operating License Condition 2.C.(18), Fire Protection Program, for the licensee's failure to establish a continuous fire watch for transient combustibles while the fire detection system was unable to alarm.

Additional Tracking Items

None

PLANT STATUS

Unit 1 began the inspection period at rated thermal power. On March 11, 2024, the unit was down powered to 91 percent to perform quarterly turbine valve stroke testing. The unit was returned to rated thermal power on the same day and remained at or near rated thermal power for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures on January 17 and 18, 2024.

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk significant systems from impending severe weather on January 8, 2024.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Protected train walkdown of the 'A' and 'B' trains of the safety-related chilled water system while the 'C' chiller was out of service for replacement completed on January 2, 2024

(2) 'A' and 'B' motor-driven emergency feedwater pumps and flow paths on January 8, 2024, while the turbine-driven emergency feedwater pump was undergoing maintenance

(3) A and B component cooling water booster pumps while C component cooling water booster pump was out of service for ongoing preventive maintenance on January 30, 2024

(4) 'B' train residual heat removal system on February 12, 2024, after pump testing

(5) Reactor coolant pump seal injection piping and valves outside of containment and indications inside containment on March 13, 2024

(6) Reactor building cooling unit supply and return valves on February 5, 2024

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) HVAC chiller rooms in intermediate building elevation 412 feet on January 9, 2024

(2) Intermediate building elevation 412 feet on January 10, 2024

(3) Control building relay room (CB06) elevation 436 feet on February 14, 2024

(4) Turbine building lube oil storage room on March 13, 2024

71111.06 - Flood Protection Measures

Flooding Sample (IP Section 03.01) (1 Sample)

(1) Service water pump house on February 14, 2024

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during fire response on February 5, 2024, and steam generator flow control valve rack calibration on February 14, 2024

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) Inspectors observed licensed operator requalification simulator training identified by O-LOR-SIM-ST-052 on March 20, 2024. The details of the scenario were not included in this report because the scenario was controlled until all crews were tested.

71111.12 - Maintenance Effectiveness

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) VC-23-00022, 'A' emergency diesel generator fuel oil piping modifications on February 22, 2024

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Elevated risk during complex lift of the 'C' chiller through the intermediate building hatch near safety-related cables on January 4, 2024

(2) Elevated risk during 'A' emergency diesel generator tagout for deep cleaning on January 23, 2024

(3) Elevated risk during 'A' control room emergency filtration system fan motor replacement on January 23 and 24, 2024

(4) Elevated risk during 'A' emergency diesel generator tagout for fuel oil piping replacement on February 17 through 23, 2024

(5) Elevated risk during maintenance activities on transformer XTF-5 and associated breakers and relays on March 18, 2024

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) CR1247018, 'A' emergency diesel generator output breaker failed to close during testing, review completed on January 3, 2024

(2) CR1249867 and CR1249868, A train service water pond reactor building cooling unit return isolation valve XVB03107A-SW open stroke time testing exceeded maximum allowed on January 31, 2024

(3) CR1427860, 'B' emergency diesel generator lube oil coupling angular deflection, review completed on February 9, 2024

(4) CR1248449, diesel-driven fire service pump hose clamp cutting into rubber coupling, review completed on March 21, 2024

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) VC-23-00022, emergency diesel generator fuel oil piping, review completed on March 22, 2024

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (PMT) (IP Section 03.01) (8 Samples)

(1) SOP-211, turbine-driven emergency feedwater pump testing, on January 8, 2024, following maintenance on the trip/throttle valve and pump

(2) ERMP-100.011A, combustion turbine generator XTG-200A testing, on January 10, 2024, following replacement of the fuel injectors

(3) SOP-301, 'B' emergency diesel generator testing, on January 11, 2024, following deep cleaning and minor maintenance of the engine

(4) SOP-501, 'A' chiller testing, on January 17, 2024, following replacement of the circuit 2 soft-starter power supply

(5) SOP-306, 'A' emergency diesel generator testing on January 23, 2024, following minor maintenance and deep cleaning

(6) SOP-118, C component cooling water booster pump testing, on January 30, 2024, following electrical maintenance on the pump motor and circuit breaker

(7) STP-223.002A, open stroke testing service water pond reactor building cooling unit return isolation valve XVB03107A testing on February 1, 2024, following adjustment of its open control air needle valve position

(8) SOP-118, 'B' component cooling water pump, on February 13, 2024, following motor and pump maintenance

Surveillance Testing (IP Section 03.01) (3 Samples)

(1) HPP-0904, gas and particulate sampling of the reactor building, on January 17, 2024, while radiation monitor RM-A2 was inoperable

(2) STP-223.004, air supply check valve testing for 'B' train reactor building to service water pond isolation, on January 19, 2024

(3) STP-125.002B, 'B' emergency diesel generator monthly testing, on February 7, 2024

Inservice Testing (IST) (IP Section 03.01) (1 Sample)

(1) STP-220.001A, 'A' motor-driven emergency feedwater pump and valve testing, on March 26, 2024

Reactor Coolant System Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) STP-114.002, Operational Leakrate Calculation, and condition reports CR1252229, CR1252271, CR1252370, and CR1252339, review completed on March 29, 2024

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.01-02.04) (1 Sample)

(1) The inspectors evaluated the maintenance and testing of the alert and notification system, the integrated public alert and warning system (IPAWS), during the week of March 4, 2024.

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.01-02.02) (1 Sample)

(1) The inspectors evaluated the readiness of the Emergency Preparedness Organization during the week of March 4, 2024

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated submitted Emergency Action Level, Emergency Plan, and Emergency Plan Implementing Procedure changes during the week of March 4, 2024. This evaluation does not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness

Inspection Review (IP Section 02.01 - 02.11) (1 Sample)

(1) The inspectors evaluated the maintenance of the emergency preparedness program during the week of March 4, 2024.

71114.06 - Drill Evaluation

Required Emergency Preparedness Drill (1 Sample)

(1) The inspectors evaluated a drill involving loss of offsite power, small break loss of coolant accident, and containment failure resulting in a general emergency on February 28,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12)===

(1) January 1, 2023, through December 31, 2023

EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)

(1) January 1, 2023, through December 31, 2023

EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)

(1) PI data was not available for ANS, the IPAWS is used for public alerting.

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) CR1243818 and CR1243853, multiple broken welds on piping supports on emergency diesel generators (EDGs). Inspectors identified multiple piping supports that were cracked at the weld joint between the support and the base metal. The supports were provided as a part of the skid mounted EDGs. The licensee replaced the supports on both EDGs in February and March 2024. Upon removal of the cracked supports, it was evident that the original construction techniques resulted in inadequate penetration of the base metal, likely as a result of not using a groove between the base metal and the 1/4-inch plate used for the support. The piping vibrations due to the operation of the EDGs resulted in weld failure. Inspectors were unable to identify how long the conditions existed, but the cracked welds did not affect the operability of the EDGs. Inspectors did not identify a violation of regulatory requirements during the review.

(2) CR1250201, fire in intermediate building elevation 412 feet due to hot work, review completed on March 26, 2024

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in related to valve stroke time testing failures that might be indicative of a more significant safety issue. The review was completed on March 14, 2024. The inspectors did not identify any violations of regulatory requirements.

INSPECTION RESULTS

Failure to Properly Evaluate Transient Materials for Combustibility Resulting in Missed Continuous Fire Watch Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.2] - Field 71111.05 NCV 05000395/2024001-01 Presence Open/Closed An NRC-identified Green finding and associated non-cited violation (NCV) was identified of Operating License Condition 2.C.(18), Fire Protection Program, for the licensee's failure to properly evaluate transient materials for combustibility, which resulted in exceeding storage limits in a fire zone without an adequate fire watch.

Description:

On January 3 and 4, 2024, as a part of the 'C' chiller replacement project, the licensee staged two of three chiller sections in the intermediate building, elevation 412 feet.

On January 9, inspectors observed closed-cell foam insulation on the components and piping on both sections of the chiller. The licensee reviewed the procurement documentation and recognized that the insulation should have been evaluated as transient combustibles. The licensee immediately established a continuous fire watch for the area.

The intermediate building, elevation 412 feet, contains NFPA 805 spatial separation sub zones, where the controls over transient combustible materials are more restrictive than other areas of the site. Combustible materials taken within 10 feet on either side of a fire subzone boundary for the restricted areas are evaluated using licensee procedures SAP-142, "Station Housekeeping Program," Revision 17, and FPP-020, "Program Administration", Revision 7.

Licensee procedure FPP-022, "Fire Prevention," Section 3.3.4.C, states "All quantities of combustible materials to be used in a restricted area defined in Step 3.3.3.D of this procedure shall have a FP permit and be in continuous line-of-sight of a qualified Fire Watch, unless excluded in Attachment III, IV, or evaluated by a Fire Protection Engineer." Step 3.3.3.D notes that Enclosure 6.1 lists plant rooms that are considered restricted. Enclosure 6.1 lists the intermediate building fire subzones IB25.01.02, IB25.01.05, and IB25.01.03 as restricted storage areas. The chillers were stored within 10 feet of all three of the subzone boundaries.

Corrective Actions: The licensee immediately established a continuous fire watch as required by procedure FPP-022.

Corrective Action References: CR1247887

Performance Assessment:

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the transient combustible additional fire loading was not allowed within 10 feet of the fire subzones. This issue is similar to IMC 0612, Appendix E, Examples of Minor Issue, Example 4.j, because the fire loading was not within the fire hazard analysis limits.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The finding screened to very low safety significance (Green) at Step 1.4, "Qualitative Screening Questions for Individual Fire Finding Categories," question 1.4.1-B, "Does the fire finding adversely affect an area with adequate automatic detection and suppression" answered, "Yes."

Cross-Cutting Aspect: H.2 - Field Presence: Leaders are commonly seen in the work areas of the plant observing, coaching, and reinforcing standards and expectations. Deviations from standards and expectations are corrected promptly. Senior managers ensure supervisory and management oversight of work activities, including contractors and supplemental personnel.

Specifically, inspectors identified several deficiencies related to station housekeeping and fire protection in the intermediate building that revealed lower standards that could have been previously identified and corrected by leaders.

Enforcement:

Violation: The V.C. Summer Nuclear Station, Renewed Facility Operating License Number NPF-12, Condition 2.C.(18) states, in part, that Dominion Energy South Carolina, Inc.

(Licensee), shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request (LAR) dated 11/15/11 (and supplements dated 1/26/12, 10/10/12, 2/1/13, 4/1/13, 10/14/13, 11/26/13, 1/9/14, 2/25/14, 5/2/14, 5/11/14, 8/14/14, 10/9/14, and 12/11/14) and as approved in the safety evaluation report dated 02/11/15 and 3/6/2020.

10 CFR 50.48(c) specifies the use of NFPA 805, 2001 Edition, of which, Section 3.2.3, Procedures, states in part that procedures shall be established to accomplish inspection of features credited by the fire protection program.

Licensee procedure SAP-0131, "Fire Protection Program," Section 6.2.1.B, states "The requirements of FPP-020 shall be considered and, as required, implemented when any of the following activities occur: 1. compensatory actions must be implemented. 4. transient combustibles are to be taken into or transferred from place to place within the Protected Area."

Licensee procedure FPP-022, "Fire Prevention," Section 3.3.4.C, states "All quantities of combustible materials to be used in a restricted area defined in Step 3.3.3.D of this procedure shall have a FP permit and be in continuous line-of-sight of a qualified Fire Watch, unless excluded in Attachment III, IV, or evaluated by a Fire Protection Engineer."

Contrary to the above, from January 3 to January 9, 2024, the licensee failed to follow FPP-022 by failing to properly evaluate transient materials for combustibility, which resulted in exceeding storage limits in a fire zone without establishing a continuous fire watch.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Establish a Continuous Fire Watch While Detection Capability was Reduced Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.4] - 71152A NCV 05000395/2024001-02 Teamwork Open/Closed A self-revealed Green finding and associated NCV was identified of Operating License Condition 2.C.(18), Fire Protection Program, for the licensee's failure to establish a continuous fire watch for transient combustibles while the fire detection system was unable to alarm.

Description:

On January 9, 2024, during a project to replace the 'C' chiller, inspectors identified foam insulation attached to two sections of the chiller which were staged in the intermediate building elevation 412 feet. The licensee immediately established a continuous fire watch as required by licensee procedure FPP-022, "Fire Prevention," Revision 6. On February 1, 2024, the licensee completed an engineering evaluation to downgrade the continuous fire watch to a shiftly roving fire watch as long as eight conditions were met, including "Simplex Panel XPN0130 and IB412 Smoke Detector Zones Operable: AA and BB."

On February 2, 2024, during hotwork activities associated with the replacement project, four detectors in the southwest corner of the intermediate building elevation 412 feet alarmed on the Simplex fire panel in the main control room. Operators acknowledged the alarms, which deactivated subsequent alarms for those detectors. During hotwork activities, a fire watch had been established as required by procedure. On February 2, 2024, at the conclusion of hotwork activities and securing the hotwork fire watch, operators failed to reset the alarms on the fire panel to meet the requirements of the engineering evaluation.

On February 5, 2024, a small fire occurred because of hotwork activities which was quickly extinguished by the hotwork fire watch. During the investigation, the licensee identified that the main control room did not receive any fire alarms, and the "acknowledged" condition of the nearby detectors was recognized. The licensee reset the alarms to restore functionality before returning to a shiftly fire watch.

Corrective Actions: The licensee reset the fire panel alarms on February 5, 2024, which satisfied the evaluation criteria for downgrading the continuous fire watch to a shiftly fire watch in the intermediate building elevation 412 feet.

Corrective Action References: CR1250201 and CR1250206

Performance Assessment:

Performance Deficiency: The licensee's failure to establish a continuous fire watch for transient combustibles while the fire detection system was unable to alarm was a performance deficiency that was within the licensee's ability to foresee and correct.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the transient combustible additional fire loading was not allowed within 10 feet of the fire subzones without a continuous fire watch or engineering evaluation. The engineering evaluation required functional detection and suppression capabilities, but detection was not fully functional when in an "acknowledged" state. This issue is similar to IMC 0612, Appendix E, Examples of Minor Issue, Example 4.j, because the fire loading was not within the fire hazard analysis limits.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors assessed the significance of the finding using Inspection Manual Chapter (IMC) 0609, Attachment 04, Initial Characterization of Findings, and determined the finding was associated with the Mitigating Systems cornerstone and required additional evaluation using IMC 0609, Appendix F, Fire Protection Significance Determination Process. The finding was associated with fixed fire protection systems and was assigned a high degradation rating. The inspectors concluded that additional evaluation by a Senior Reactor Analyst (SRA) was necessary to assess the significance of the finding.

The SRA observed that the licensee had a fire probabilistic risk assessment (PRA) model capable of adequately assessing the fire risk associated with the finding and reviewed the licensees PRA evaluation of the nonfunctional detectors. The analyst noted that the evaluations treatment of condition exposure period, transient influencing factors, and adjacent functional detectors were conservative and appropriate to the circumstances associated with the finding. The dominant sequences involved fire events in the affected fire area that were more significant due to the modeled non-functionality of the fire detectors which were associated with a plant transient and challenges to reactor coolant pump seal cooling. The evaluation yielded an estimated change in core damage frequency (delta-CDF)of 4.84E-09/year and change in large early release frequency (delta-LERF) of 6.21E-11/year.

The risk of the finding was mitigated by the relatively short 3-day exposure period. The analyst concluded that the finding was characterized as very low safety significance (Green).

Cross-Cutting Aspect: H.4 - Teamwork: Individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, during shift turnovers over three days, operators did not communicate or recognize that four detectors were in an "acknowledged" state and unable to alarm, which was contrary to the engineering evaluation which downgraded the continuous fire watch to a shiftly fire watch.

Enforcement:

Violation: The V.C. Summer Nuclear Station, Renewed Facility Operating License Number NPF-12, Condition 2.C.(18) states, in part, that Dominion Energy South Carolina, Inc.

(Licensee), shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the LAR dated 11/15/11 (and supplements dated 1/26/12, 10/10/12, 2/1/13, 4/1/13, 10/14/13, 11/26/13, 1/9/14, 2/25/14, 5/2/14, 5/11/14, 8/14/14, 10/9/14, and 12/11/14) and as approved in the safety evaluation report dated 02/11/15 and 3/6/2020.

10 CFR 50.48(c) specifies the use of NFPA 805, 2001 Edition, of which, Section 3.2.3, Procedures, states in part that procedures shall be established to accomplish inspection of features credited by the fire protection program.

Licensee procedure SAP-0131, "Fire Protection Program," section 6.2.1.B, states "The requirements of FPP-020 shall be considered and, as required, implemented when any of the following activities occur: 1. compensatory actions must be implemented. 4. transient combustibles are to be taken into or transferred from place to place within the Protected Area."

Licensee procedure FPP-022, "Fire Prevention," section 3.3.4.C, states "All quantities of combustible materials to be used in a restricted area defined in Step 3.3.3.D of this procedure shall have a FP permit and be in continuous line-of-sight of a qualified Fire Watch, unless excluded in Attachment III, IV, or evaluated by a Fire Protection Engineer."

Contrary to the above, from February 2 to February 5, 2024, the licensee failed to follow FPP-022 by failing to establish a continuous fire watch as required by the fire protection permit and the engineering evaluation. Specifically, engineering assessment ETE-VC-24-0003 allowed the licensee to downgrade the continuous fire watch required due to storage of combustible materials to a shiftly roving fire watch with eight conditions being met. One condition, "Simplex Panel XPN0130 and IB412 Smoke Detector Zones Operable: AA and BB", was not met when fire alarms from four detectors were acknowledged but not reset on February 2, 2024. This condition did not alert operators to a small fire which occurred on February 5, 2024.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On April 18, 2024, the inspectors presented the integrated inspection results to Mr.

Robert Justice and other members of the licensee staff.

• On March 7, 2024, the inspectors presented the Emergency preparedness program inspection exit meeting. inspection results to Mr. Robert Justice and other members of the licensee staff.

THIRD PARTY REVIEWS

Inspectors reviewed Institute on Nuclear Power Operations and Dominion Management Safety Review Committee reports that were issued during the previous two inspection periods.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71114.02 Miscellaneous V.C. Summer Alert and Notification System Evaluation Rev 3

Report

71114.04 Miscellaneous 10 CFR 50.54 (q) Screen and Evaluation for VCS-EPP- 09/26/2022

0001.2, Revision 2

CFR 50.54 (q) Screen and Evaluation for EP-AA-105, 01/20/2023

"Emergency Preparedness Department Staff Training,"

Revision 5

CFR 50.54 (q) Screen and Evaluation for EP-AA-0601, 05/01/2023

"Emergency Press Releases," Revision 5

Procedures EP-100 Radiation Emergency Plan Rev. 74

EP-AA-601 Emergency Press Releases Rev. 5

VCS-EPP-0001 Classification of Emergencies Rev. 1

VCS-EPP-0001.1 Unusual Event Rev. 2

VCS-EPP-0001.2 Alert Rev. 1

VCS-EPP-0001.3 Site Area Emergency Rev. 4

VCS-EPP-0001.4 General Emergency Rev. 4

VCS-EPP-0002 Communication and Notification Rev. 4

VCS-EPP-0005 Offsite Dose Calculation Rev. 2

14