ML24212A144

Integrated Inspection Report 05200025/2024002 and 05200026/2024002

ML24212A144
Person / Time
Site:	Vogtle
Issue date:	08/01/2024
From:	Bradley Davis NRC/RGN-II
To:	Coleman J Southern Nuclear Operating Co
References
IR 2024002
Download: ML24212A144 (23)

Text

Jamie M. Coleman Director, Regulatory Affairs Southern Nuclear Operating Co., Inc 3535 Colonnade Parkway Birmingham, AL 35243

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 - INTEGRATED INSPECTION REPORT 05200025/2024002 AND 05200026/2024002

Dear Jamie Coleman:

On June 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Vogtle Electric Generating Plant, Units 3 and 4. On July 24, 2024, the NRC inspectors discussed the results of this inspection with Ang Dong, Engineering Nuclear Director, 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 Vogtle Electric Generating Plant, Units 3 and 4.

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 Vogtle Electric Generating Plant, Units 3 and 4.August 1, 2024 J. Coleman 2 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, Bradley J. Davis, Chief Construction Inspection Branch 2 Division of Construction Oversight Docket Nos. 05200025 and 05200026 License Nos. NPF-91 and NPF-92

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV Signed by Davis, Bradley on 08/01/24

ML24212A144 X Non-Sensitive X Publicly Available X SUNSI Review Sensitive Non-Publicly Available

OFFICE RII/DRP RII/DCO RII/DCO

NAME A. Alen Arias J. Parent B. Davis DATE 07/30/24 08/01/24 08/01/24 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report

Docket Numbers: 05200025 and 05200026

License Numbers: NPF-91 and NPF-92

Report Numbers: 05200025/2024002 and 05200026/2024002

Licensee: Southern Nuclear Operating Company, Inc

Facility: Vogtle Electric Generating Plant, Units 3 and 4

Location: Waynesboro, GA

Inspection Dates: April 01, 2024 to June 30, 2024

Inspectors: J. Bell, Senior Health Physicist J. Diaz-Velez, Senior Health Physicist J. Eargle, Senior Resident Inspector S. Egli, Sr. Construction Inspector B. Griman, Resident Inspector M. Kennard, Sr. Operations Engineer D. Neal, Health Physicist J. Parent, Senior Resident Inspector J. Tornow, Physical Security Inspector B. Truss, Resident Inspector J. Walker, Sr Emergency Preparedness Inspector

Approved By: Bradley J. Davis, Chief Construction Inspection Branch 2 Division of Construction Oversight

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Vogtle Electric Generating Plant, Units 3 and 4, 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 perform adequate surveys to assess doses to members of the public from liquid effluent releases.

Cornerstone Significance Cross-Cutting Report Aspect Section Public Radiation Green [H.3] - Change 71124.06 Safety NCV 05200025,05200026/2024002-01 Management Open/Closed NRC inspectors identified a Green Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 20.1302, Compliance with dose limits for individual members of the public, for the licensee's failure to perform surveys of radiation levels in unrestricted and controlled areas to demonstrate compliance with the dose limits for individual members of the public.

Failure to perform adequate surveys to assess doses to members of the public from environmental direct radiation.

Cornerstone Significance Cross-Cutting Report Aspect Section Public Radiation Green [P.6] - Self-71124.07 Safety NCV 05200025,05200026/2024002-02 Assessment Open/Closed The NRC identified a Green NCV of 10 CFR 20.1302 for the licensee's failure to adequately control and account for transit dose on environmental dosimeters.

Additional Tracking Items

None.

2 PLANT STATUS

Unit 3 began the inspection period at rated thermal power (RTP). The unit remained at or near RTP for the remainder of the inspection period.

Unit 4 began the inspection period at 98 percent of RTP and in the process of conducting startup testing. On April 12, 2024, the loss of offsite power startup test was performed which placed the unit in mode 3 (Hot Standby). Following the test, the unit was placed in mode 5 (Cold Shutdown) and began a planned 10-day maintenance outage from April 12 through April 22, 2024. On April 22, 2024, the unit was restarted and recommenced startup testing on April 23, 2024. The unit completed all startup testing on April 25, 2024, and was returned to RTP on April 26, 2024. On April 29, 2024, Southern Nuclear Operating Company (SNC) declared that unit 4 entered commercial operation. On May 25, 2024, power was reduced to approximately 45 percent RTP to repair a steam leak on the 'A' moisture separator re-heater shell drain tank pump; the unit was returned to approximately RTP later that day. On June 5, 2024, the unit was manually tripped due to a temperature difference of greater than 10 degrees Fahrenheit (°F) between TAVE and TREF (NRC Event Notification 57164). The temperature difference resulted from the inability to control TAVE using control rods following a rapid power reduction and turbine runback due to a trip of the main feedwater pump C. On June 9, 2024, the unit was restarted and returned to RTP on June 11, 2024. The unit remained at or near RTP 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.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

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 that had the potential to create a tornado on April 3, 2024.

3 71111.04 - Equipment Alignment

Partial Walkdown Sample [AP1000] (IP Section 03.01) (1 Sample)

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

(1) Unit 4 passive containment cooling system during the week of April 15, 2024.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample [AP1000] (IP Section 03.01) (2 Samples)

(1) 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 unit 3 fire areas on June 3, 2024:

• Fire Area 1230 AF 01: Division A and C corridor

• Fire Area 1230 AF 02: Non-class 1E equipment / penetration room

• Fire Area 1232 AF 01: Remote shutdown room (2) 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 unit 4 fire areas on June 28, 2024:

• Fire Area 1242 AF 01 (room 12401A): Unit 4 main control room

• Fire Area 1242 AF 01 (room 12401B): Shift manager's office / breakroom

• Fire Area 1242 AF 02 (room 12412): Division A electrical penetration room

• Fire Area 1243 AF 01 (room 12423): Reactor trip switchgear 1

• Fire Area 1243 AF 02 (room 12422): Reactor trip switchgear 2

Fire Brigade Drill Performance Sample [AP1000] (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill (Drill No. B-043) in the unit 3 decon room (room 40360), on May 8, 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 unit 4 main control room (MCR) during reactor start-ups to mode 2 and critical on April 8, 2024, and on June 9, 2024.

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

(1) The inspectors observed and evaluated Crew 2B performance in a simulator scenario consisting of a trip of the A service water system (SWS) pump, B SWS pump failure to automatically start in standby, core makeup tank (CMT) B outlet valve seat

4 leakage, loss of both component cooling water system (CCS) pumps, anticipated transient without scram (ATWS) that requires opening rod drive motor generator (RDMG) input breakers using plant control system (PLS), main generator breaker fails to open on reactor trip, cold leg loss of coolant accident (LOCA), and CMT outlet valves failing to open. The scenario resulted in an Alert emergency declaration and notification to the State of Georgia and surrounding counties, on June 24, 2024.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample [AP1000] (IP Section 03.01) (2 Samples)

(1) Unit 4 risk assessment for the unit 4 planned maintenance outage during the week of April 15, 2024.

(2) Unit 4 reactor trip risk analysis for the manual reactor trip on June 5, 2024.

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment [AP1000] (IP Section 03.01) (2 Samples)

(1) Condition report (CR) 11083772 on June 10, 2024. Indication of leak-by of unit 3 containment isolation valves 3-PSS-V010B and 3-PSS-V011B based on pressure instrument 3-PSS-PT034B.

(2) CR 11078091 on May 20, 2024. Unit 4 protection and safety monitoring system (PMS) division A computer mouse identified non-functional after work order to reset password.

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated unit 4 planned maintenance outage activities from April 13 to April 22, 2024.

71111.24 - Testing and Maintenance of Equipment Important to Risk

Post-Maintenance Testing (PMT) [AP1000] (IP Section 03.01) (5 Samples)

(1) 4-RCS-OTS-16-025, "Division D - Reactor Coolant Hot Leg Flow Calibration - RCS-FT101D, RCS-FT102D" for RCS-FT102D following indication of instrument inaccuracy, on April 16, 2024.

(2) NMP-MA-014-001, Post-Maintenance Testing Guidance, for a liquid penetrant dye test after replacement of CMT A fill check valve (4-PXS-V231A), on April 17, 2024.

(3) 4-MTS-OTS-10-001, "Main Turbine Inservice Valve Test," for stroke close testing of the moisture separator re-heater 'B' main steam supply air-operated valve (AOV)

(MSS-V015B) following maintenance, on April 22, 2024.

(4) 4-VES-OTS-17-001, "Main Control Room Emergency Habitability System Valve Position and Operability Check," for testing the MCR alternate supply path through the MCR alternate supply regulator (VES-V002B) and the MCR alternate supply isolation valve (4-VES-V001) following valve maintenance, on April 17, 2024.

5 (5) 4-PXS-OTS-001, "Passive Core Cooling System Train A Valve Stroke Test," for stroke test of CMT A makeup AOV (4-PXS-V230A) following valve maintenance on April 19, 2024.

Surveillance Testing [AP1000] (IP Section 03.01) (2 Samples)

(1) 3-PCS-OTS-10-005, "PCS Valve Actuation and Exercise Test," on June 13, 2024.

(2) 4-PMS-OTS-18-001, "Engineered Safeguards Actuation System 24-Month Actuation Device Test," for unit 4 reactor coolant pump breakers trip signal actuation test, on April 15, 2024.

71114.01 - Exercise Evaluation

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

(1) (Partial)

The inspectors evaluated the biennial emergency plan exercise for Vogtle Units 1 and 2, during the week of May 20, 2024 (Agencywide Documents Access and Management System [ADAMS] Accession No. ML24205A003). The exercise allowed the onsite Emergency Response Organization (ERO), for units 1 and 2, to demonstrate the ability to mitigate the consequences of a radiological event in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix E.IV.F.2.b. In addition, the exercise allowed the Offsite Response Organizations to demonstrate their ability to implement emergency actions for units 1 - 4 (site-wide) in accordance with 10 CFR 50, Appendix E.IV.F.2.c.

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 May 20, 2024.

This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation

Additional Drill and/or Training Evolution (3 Samples)

The inspectors evaluated:

(1) The inspectors observed and evaluated a simulator scenario consisting of M-bank C control rods fully inserting, loss of all feedwater, passive residual heat removal heat exchanger failure to actuate, and containment isolation valves failure to automatically close. The scenario resulted in a Site Area Emergency declaration and notification to the State of Georgia and surrounding counties, on June 10, 2024.

(2) The inspectors observed and evaluated Crew 2B perform a simulator scenario consisting of a trip of the A SWS pump, B SWS pump failure to automatically start in standby, CMT B outlet valve seat leakage, loss of both CCS pumps, ATWS that requires opening RDMG input breakers using PLS, main generator breaker fails to open on reactor trip, cold leg LOCA, and CMT outlet valves failure to open. The

6 scenario resulted in an Alert emergency declaration and notification to the State of Georgia and surrounding counties, on June 24, 2024.

(3) The inspectors observed and evaluated Crew 4B perform a simulator scenario consisting of a trip of the A SWS pump, B SWS pump failure to automatically start in standby, CMT B outlet valve seat leakage, loss of both CCS pumps, ATWS that requires opening RDMG input breakers using PLS, main generator breaker fails to open on reactor trip, cold leg LOCA, and CMT outlet valves failure to open. The scenario resulted in an Alert emergency declaration and notification to the State of Georgia and surrounding counties, on June 3, 2024.

RADIATION SAFETY

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment

Walkdowns and Observations (IP Section 03.01) (4 Samples)

The inspectors evaluated the following radioactive effluent systems during walkdowns:

(1) Unit 3, room 50355, 3-WLS-JS-229 liquid radwaste radiation monitor (2) Unit 3, plant vent stack, 180-foot elevation (3) Unit 4, room 50355, 4-WLS-JS-229 liquid radwaste radiation monitor (4) Unit 4, plant vent stack, 180-foot elevation

Sampling and Analysis (IP Section 03.02) (4 Samples)

Inspectors evaluated the following effluent samples, sampling processes and compensatory samples:

(1) Unit 4, waste monitoring tank-C (compensatory sample) #12Jun24-004 (2) Unit 4, waste monitoring tank-C (compensatory sample) #12Jun24-012 (3) Unit 3, waste monitoring tank-A, sample #15821 (associated to release permit L-20240518-094-B)

(4) 2023 Annual Radioactive Effluent Release Report, regarding tritium total annual gaseous effluent

Dose Calculations (IP Section 03.03) (2 Samples)

The inspectors evaluated the following dose calculations:

(1) Liquid waste radiation permits L-20231230-127-B, L-20240518-094-B, L-20231225-123-B, L-20240505-086-B (2) Gaseous waste radiation permits G-20240530-161-B, G-20231229-236-B, G-20240528-158-B, G-20231227-223-C

71124.07 - Radiological Environmental Monitoring Program

Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples.

7 Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.

Groundwater Protection Initiative (GPI) Implementation (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees implementation of the GPI program to identify incomplete or discontinued program elements.

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

EP01: Drill/Exercise Performance (DEP) Sample [AP1000] (IP Section 02.12) (1 Sample)

(1) April 1, 2023, through March 31, 2024.

EP02: ERO Drill Participation [AP1000] (IP Section 02.13) (1 Sample)

(1) April 1, 2023, through March 31, 2024.

EP03: Alert And Notification System (ANS) Reliability Sample [AP1000] (IP Section 02.14) (1 Sample)

(1) April 1, 2023, through March 31, 2024.

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample

[AP1000] (IP Section 02.16) (1 Sample)

(1) October 14, 2022 to June 14, 2024

71152S - Semiannual Trend Problem Identification and Resolution

Semiannual Trend Review (Section 03.02) (1 Sample)

(1) The inspectors reviewed the licensees corrective action program to identify and evaluate potential trends regarding the implementation of severe weather preparations procedures 3/4-AOP-901, "Acts of Nature," and NMP-OS-017, "Severe Weather," that might be indicative of a more significant safety issue.

71153 - Follow Up of Events and Notices of Enforcement Discretion

Event Follow up (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated the unit 4 manual reactor trip due to a temperature difference greater than 10°F between T AVE and TREF; and the licensees response on June 5, 2024. (NRC Event Notification 57164)

8 INSPECTION RESULTS

Failure to perform adequate surveys to assess doses to members of the public from liquid effluent releases.

Cornerstone Significance Cross-Cutting Report Aspect Section Public Radiation Green [H.3] - Change 71124.06 Safety NCV 05200025,05200026/2024002-01 Management Open/Closed NRC inspectors identified a Green Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 20.1302, Compliance with dose limits for individual members of the public, for the licensee's failure to perform surveys of radiation levels in unrestricted and controlled areas to demonstrate compliance with the dose limits for individual members of the public.

Description:

While reviewing licensee dose calculations from effluents, the inspectors identified that dose assessment surveys associated with liquid waste release permits failed to properly determine doses to members of the public. Specifically, surveys were inadequate because the licensee failed to include doses from drinking water and shoreline exposure pathways at the site boundary for 2023 (Calendar Year) and 2024 (Year-to-Date; until June 12, 2024). The licensee determined that after installation and commissioning of the software used for the calculations, parameters affecting the calculations for drinking water and shoreline exposure pathways were zeroed out and not accounted for in the surveys. The change in the software parameters went unnoticed until inquiries from the inspection and as a result, liquid waste release permits processed contained errors in the calculations and doses assessed were underestimated.

For example, in permit #L-20231230-127B, the licensee's dose calculations to the theoretically maximum exposed individual at the site boundary incorrectly determined unit 3 annual organ dose to be 1.077E-10 mRem to the child age group and identified the organ as the thyroid. However, after the licensee performed the necessary dose corrections (addition of the drinking water and shoreline exposure pathways doses), the dose to the theoretically maximum exposed individual at the site boundary for unit 3 annual organ dose was determined to be 1.153E-02 mRem (milli roentgen equivalent man) to the child age group and identified the organ as the GI-LLI (gastrointestinal tract: lower large intestine). The dose calculations from unit 3 to the total body of the theoretically maximum exposed individual at the site boundary tracked identical in magnitude and age groups identified, with the error in dose calculations and after the dose corrections.

Corrective Actions: The licensee reviewed the dose calculations with the assistance of the contractor that supports the software used for the calculations. The licensee determined that the reason manual calculations following the site Offsite Dose Calculation Manual (ODCM) did not agree with the surveys performed by the software used was because parameters used for the calculations had changed resulting in failure to add doses from all necessary pathways regarding the liquid waste release permits calculations. From this corrective action, the licensee restored parameters to be used to correct values and recalculated all release permits (surveys) for CY2023 and YTD 2024. The licensee provided the inspectors with corrected liquid waste permits and the inspectors verified that calculations were trending with the methodology described in the ODCM.

9 Corrective Action

References:

CR 11084522 - OpenEMS Liquid calculations found to be incorrect CAR 706788 - OpenEMS Liquid and Gaseous calculations found to be incorrect TE 1157228 - OpenEMS Liquid calculations found to be incorrect Performance Assessment:

Performance Deficiency: The inspectors determined that the licensee's failure to perform adequate liquid waste release permits dose calculations (radiation surveys) concerning doses to members of the public was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program and Process attribute of the Public Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. Specifically, the licensee failed to monitor doses from two exposure pathways that contained radioactivity.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix D, Public Radiation Safety SDP. The inspectors determined the finding to be of very low safety significance (Green) because the dose impact to a member of the public from the radiological releases after re-calculations of doses did not exceed the dose values in Appendix I to 10 CFR Part 50 and/or 10 CFR 20.1301(e).

Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.

The apparent cause of this finding is related to the cross-cutting area of Change Management, Aspect H.3 because the licensee did not ensure that configuration controls were placed over the software used to perform dose calculations to prevent important parameters being changed to ensure dose calculations to members of the public were assessed properly.

Enforcement:

Violation: Title 10 CFR 20.1302(a) requires in part, that a licensee make or cause to be made, as appropriate, surveys of radiation levels in unrestricted and controlled areas and radioactive materials in effluents released to unrestricted and controlled areas to demonstrate compliance with the dose limits for individual members of the public in 10 CFR 20.1301, Dose limits for individual members of the public. ODCM, Attachment 13, Section 2.0, requires that the liquid pathway surveys (considering the absence of an irrigated garden) include doses from the drinking water, fish ingestion, and shoreline exposure pathways. Title 10CFR 20.1003, Definitions, defines a survey as an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation.

Contrary to the above, as of June 12, 2024, licensee radiation surveys concerning doses to individual members of the public from radioactive materials due to liquid effluents released to unrestricted areas contained errors in the dose calculations. Specifically, surveys assessing doses to members of the public from liquid effluent releases failed to consider doses from the drinking water (the most contributing pathway) and shoreline exposure pathways.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

10 Failure to perform adequate surveys to assess doses to members of the public from environmental direct radiation.

Cornerstone Significance Cross-Cutting Report Aspect Section Public Radiation Green [P.6] - Self-71124.07 Safety NCV 05200025,05200026/2024002-02 Assessment Open/Closed The NRC identified a Green NCV of 10 CFR 20.1302 for the licensee's failure to adequately control and account for transit dose on environmental dosimeters.

==

Description:==

The inspectors performed reviews of the 2023 Annual Radiological Environmental Operating Report (AREOR) report (ADAMS Accession No. ML24131A140) during the week of June 10, 2024. During this review inspectors observed lower than expected results of direct radiation environmental measurements for dosimeters meant to provide estimates of direct radiation in the environment surrounding the plant.

The inspectors identified that inadequate control of transit correction dosimeters resulted in lower than expected environmental dose measurements reported in the AREOR. Specifically, the licensees process included shipping the transit correction dosimeters to the site and back twice whereas the field dosimeters were in transit once, effectively doubling transit dose. In addition, the transit correction dosimeters spent several weeks outside of lead shielding on either end of the quarter, waiting to be shipped, while the field dosimeters were in the field. In total, it was determined that the transit correction dosimeters spent up to 60 days per quarter improperly accumulating extraneous background and transit dose, which was then incorrectly subtracted from field dosimeter readings. This results in reported doses in the AREOR that do not adequately represent direct radiation in the environment surrounding the plant. At most locations, the reported environmental radiation levels are substantially lower (10 - 15 mRem) than normal background radiation levels. At some locations, the reported quarterly level is zero (e.g., the background radiation levels at locations V06A, V35B, V08B, etc., whereas normal background radiation levels in the USA ranges from approximately 12 - 25 mRem/quarter.) These discrepancies in Attachment 4 of the AREOR indicate that the process for measuring environmental radiation is not being adequately controlled.

Corrective Actions: The licensee captured this issue in their corrective action program and plans to evaluate the process for handling environmental dosimetry and implement necessary changes to produce representative direct radiation measurements in the environment due to plant operations.

Corrective Action

References:

CR 11084942 Performance Assessment:

Performance Deficiency: The inspectors determined that the licensee's failure to adequately control and account for transit dose on environmental dosimeters was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program and Process attribute of the Public Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. Specifically, not adequately controlling and accounting for transit dose on environmental dosimeters per the

11 Radiological Environmental Monitoring Program (REMP) program degrades the ability to confirm that plant releases are not having an unexpected impact on the environment.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix D, Public Radiation Safety SDP. The inspectors determined the finding was of very low safety significance (Green) because it was associated with the REMP and no unexpected radiological conditions in the environment were identified.

Cross-Cutting Aspect: P.6 - Self-Assessment: The organization routinely conducts self-critical and objective assessments of its programs and practices. Specifically, during a recent self-assessment, the licensee did not identify that it was not adequately controlling the dose to environmental control radiation dosimeters during transit and storage to ensure the field dose measurements are adequately analyzed and reported.

Enforcement:

Violation: Title 10 CFR 20.1302(a) requires the licensee make or cause to be made, as appropriate, surveys of radiation levels in unrestricted and controlled areas and radioactive materials in effluents released to unrestricted and controlled areas to demonstrate compliance with the dose limits for individual members of the public in 10 CFR 20.1301, Dose limits for individual members of the public.

Contrary to these requirements, the Vogtle Unit 3 did not adequately analyze data from environmental dosimeters. Specifically, the licensee subtracted incorrectly estimated transit dose from the dose received by environmental field dosimeters resulting in inadequate estimates of environmental radiation doses surrounding the plant to ensure compliance with the dose limits for individual members of the public in 10 CFR 20.1301.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

Minor Performance Deficiency 71152S Severe weather procedure implementation deficiencies

Minor Performance Deficiency: The inspectors identified two instances where the licensee failed to adequately implement procedure NMP-OS-017, Severe Weather, Version 3.1, in preparation for the effects of severe weather. One instance on April 3, 2024, and a second instance on May 9, 2024. These where performance deficiencies.

The licensee captured these issues in their corrective action program as CRs 11075391 and 11075397.

Screening: The inspectors determined the performance deficiency was minor. The inspectors screened the performance deficiencies in accordance with NRC Inspection Manual Chapter (IMC) 0612 Appendix B, "Issue Screening Directions," and determined that the materials left unsecured in the areas surrounding units 3 and 4, due to their quantity and size, would not have been a precursor to a significant event, did not have the potential to lead to a more significant safety concern, nor adversely affected any cornerstone objectives.

12 EXIT MEETINGS AND DEBRIEFS

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

• On July 24, 2024, the inspectors presented the integrated inspection results to Ang Dong, Engineering Nuclear Director, and other members of the licensee staff.

• On July 24, 2024, the inspectors presented the radiation safety inspection results to Ang Dong, Engineering Nuclear Director, and other members of the licensee staff.

• On May 23, 2024, the inspectors presented the emergency preparedness and biennial exercise inspection results to J. Weissinger, Vogtle Units 1 and 2 Site Vice President, and other members of the licensee staff.

13 DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 71111.01 Procedures 3-AOP-901 Acts of Nature Version 1.1 71111.01 Procedures 4-AOP-901 Acts of Nature Version 1.1 71111.01 Procedures NMP-OS-017 Severe Weather Version 3.1 71111.04 Procedures 4-PXS-SOP-001 Passive Core Cooling System Version 6.0 71111.05 Fire Plans B-PFP-ENG-001-Pre-Fire Plan - Auxiliary Building Non-RCA El 100'-0" Version 3.0 F3113 71111.05 Fire Plans B-PFP-ENG-001-Pre-Fire Plan - Annex Building El 100' - RP Area Version 2.0 F3402 71111.05 Fire Plans B-PFP-ENG-001-Pre-Fire Plan - Auxiliary Building Non-RCA El 117'-6" Version 1.0 F4114 71111.05 Miscellaneous NMP-TR-425-F01 Fire Drill Scenario Development and Approval Sheet Version 6.0 71111.05 Miscellaneous NMP-TR-425-F14 Fire Drill Package Version 5.0 71111.05 Procedures B-FPS-MMM-004 Portable Fire Extinguishers and Fire Hose Stations Visual Version. 7.0 Inspection 71111.05 Procedures NMP-ES-035-017 Fleet Fire Doors Functional Inspection Governance and Version 2.0 Acceptance Criteria 71111.05 Procedures NMP-HP-108-001 Instruction for Issuing and Activating Dosimetry and Version 2.3 Updating Doc Records in HIS-20 71111.11Q Calculations NMP-RE-019 Beacon 7 Estimated Critical Condition Calculations Version 5.0 71111.11Q Corrective Action CR 11082481 U4 Manual Reactor Trip 06/05/2024 Documents 71111.11Q Miscellaneous AP-LT-C-SE-24-5X LOCT 24-5 As-Found Rev. 1.0 71111.11Q Procedures 3-AOP-201 Uncontrolled Cooldown Version 1.0 71111.11Q Procedures 3-AOP-702 Loss of Component Cooling Water Version 1.0 71111.11Q Procedures 3-AOP-704 Loss of Service Water Version 1.1 71111.11Q Procedures 3-EOP-E-0 Reactor Trip or Safeguards Actuation Version 1.1 71111.11Q Procedures 3-EOP-E-1 Loss of Reactor or Secondary Coolant Version 2.0 71111.11Q Procedures 3-EOP-F-0 Critical Safety Function Status Trees Version 1.1 71111.11Q Procedures 4-GOP-301-002 Mode 2 Change Checklists Version 1.2 71111.11Q Procedures 4-GOP-302 Reactor Startup Mode 3 To Mode 2 Version 2.0 71111.11Q Procedures 4-GOP-306 Plant Startup Mode 2 to 25% Power Version 4.0

14 Inspection Type Designation Description or Title Revision or Procedure Date 71111.13 Miscellaneous B-ADM-OPS-011 Outage Risk Assessment Monitoring Version 1.0 71111.13 Miscellaneous NMP-OM-002 V4 Pre-COD PMO Shutdown Safety Assessment Final Appendix A:

Summary Report Meeting 71111.13 Miscellaneous NMP-OM-002 V42024A Shutdown Safety Assessment 06/07/2024 Appendix A:

Summary Report Meeting 71111.13 Miscellaneous SV0-PRA-GSC-AP1000 Plant PRA, Shutdown Defense-In-Depth Risk Rev. A 383 Monitor Model Notebook 71111.15 Corrective Action CR 11078091 Unit 4 - Mouse for QDSP Division A not functional 05/20/2024 Documents 71111.15 Corrective Action CR 11083772 PSS Train B pressurized with RCS pressure following 06/10/2024 Documents restoration of PSS Train A 71111.15 Engineering TE 1155039 U4 trackball (mouse) for QDSP DIV A not functional 05/28/2024 Evaluations 71111.15 Engineering TE 1155924 PSS Train B pressurized with RCS pressure following 06/10/2024 Evaluations restoration of PSS Train A 71111.15 Miscellaneous NMP-AD-002-F04 Troubleshooting Log Version 2.1 71111.15 Miscellaneous NMP-AD-012-F01 Operability Determination Support Basis Version 4.1 71111.15 Miscellaneous NMP-DP-001 Operation Risk Awareness Version 25.0 71111.20 Miscellaneous B-GEN-ENG-032 Containment Cleanliness and Sampling Program Version 1.0 71111.20 Miscellaneous Permit Number # Erect and remove scaffold for WO # SNC 1732621 - Erect 03/21/2024 SNC1747033 scaffold to access Upper Equipment Hatch bolts 71111.20 Miscellaneous Permit Number # Erect and remove scaffold for WO # SNC 1732621 - Erect 03/21/2024 SNC1747040 scaffold to access Upper Equipment Hatch Hoist 71111.20 Procedures 4-CNS-SOP-001 Containment System Version 2.0 71111.20 Procedures 4-GOP-302 Reactor Startup Mode 3 To Mode 2 Version 2.0 71111.20 Procedures NMP-OS-001 Reactivity Management Program Version 23.2 71111.20 Procedures NMP-RE-008-F01 Detailed Reactivity Management Plan Version 2.1 71111.20 Procedures NMP-RE-019 Beacon 7 Estimated Critical Condition Calculations Version 4.2 71111.24 Corrective Action CR 11070032 Stroke time for 4-MSS-V015B passed Ovation time but 04/22/2024 Documents failed stopwatch time

15 Inspection Type Designation Description or Title Revision or Procedure Date 71111.24 Procedures 4-MTS-OTS-10-001 Main Turbine Inservice Valve Test Version 2.1 71111.24 Procedures 4-PMS-OTS-18-001 Engineered Safeguards Actuation System 24-Month Version 2.0 Actuation Device Test 71111.24 Procedures 4-PXS-OTS-001 Passive Core Cooling System Train A Valve Stroke Test Version 2.0 71111.24 Procedures 4-RCS-OTS Division D - Reactor Coolant Hot Leg Flow Calibration - 3.0 025 RCS-FT101D, RCS-FT102D 71111.24 Procedures 4-VES-OTS Main Control Room Emergency Habitability System Valve Version 2.0 001 Position and Operability Check 71111.24 Work Orders SNC1534213 ESFAS Actuation Device Test - RCP Breakers Rev. 0 71111.24 Work Orders SNC1708579 4-VES-V002B - MCR Alt Supply Regulator Rev. 1 71111.24 Work Orders SNC1733394 Disassembly / Inspect / Replace Internals / Reassemble 4-Rev. 0 PXS-V230A 71111.24 Work Orders SNC1736011 Disassembly / Inspect / Rework / Reassemble / Diagnostic Rev. 0 Testing 4-MSS-V015B 71111.24 Work Orders SNC1746439 Contingency to replace HL 2 Flow D Transmitter 4-RCS-FT102D 71111.24 Work Orders SNC1764644 Replace Valve 4-PXS-V231A 4/17/2024 71114.06 Miscellaneous AP-LT-C-SE-24-5X LOCT 24-5 As-Found Rev 1.0 71114.06 Miscellaneous AP-LT-C-SE-24-5Y LOCT 24-5 As-Found Rev 1.0 71114.06 Procedures 3-AOP-201 Uncontrolled Cooldown Version 1.0 71114.06 Procedures 3-AOP-704 Loss of Service Water Version 1.1 71114.06 Procedures 3-EOP-E-0 Reactor Trip or Safeguards Actuation Version 1.1 71114.06 Procedures 3-EOP-F-0 Critical Safety Function Status Trees Version 1.1 71124.06 Corrective Action Condition Report U4 WLS weekly composite biased due to cross 10/23/2023 Documents (CR) 11017783 contamination 71124.06 Corrective Action CR 11061498 Investigate out of trend plant vent tritium value 03/22/2024 Documents 71124.06 Corrective Action CAR 706788 OpenEMS Liquid and Gaseous calculations found to be 06/12/2024 Documents incorrect Resulting from Inspection 71124.06 Corrective Action CR 11084339 Unit 4-WLS-V230C (Unit 4 Waste Monitoring Tank-C) valve 06/12/2024 Documents difficult to operate Resulting from

16 Inspection Type Designation Description or Title Revision or Procedure Date Inspection 71124.06 Corrective Action CR 11084522 OpenEMS Liquid permits calculations found to be incorrect 06/12/2024 Documents Resulting from Inspection 71124.06 Corrective Action CR 11087735 OpenEMS Gaseous calculations found to not match 06/24/2024 Documents manual calculations Resulting from Inspection 71124.06 Corrective Action CR 11092652 2023 Annual Dose Report Requires Correction 07/12/2024 Documents Resulting from Inspection 71124.06 Miscellaneous TE 1157228 Technical Evaluations Quality Record - OpenEMS Liquid 07/09/2024 calculations found to be incorrect 71124.06 Self-Assessments Technical Check-in Self-Assessment (CISA) - Pre-NRC Inspection of 05/28/2024 Evaluation (TE) the Radioactive Gaseous and Liquid Effluent Treatment 1154423 and the Radiological Environmental Monitoring Program 71152S Corrective Action CAR 680019 Document resolution - NRC identified potential missile 05/09/2024 Documents hazards during tornado watch Resulting from Inspection 71152S Corrective Action CR 11075391 NRC identified potential missile hazards during tornado 05/09/2024 Documents watch Resulting from Inspection 71152S Corrective Action CR 11075397 NRC identified: construction equipment identified as 05/09/2024 Documents hazards by NRC and SNC walkdowns Resulting from Inspection 71152S Corrective Action TE 1154317 Fleet procedure revision - NRC identified potential missile 05/16/2024 Documents hazards during tornado watch Resulting from Inspection

17 Inspection Type Designation Description or Title Revision or Procedure Date 71152S Engineering TE 1157719 Evaluated proposed change - 3/4-AOP-901, Acts of Nature, 07/03/2024 Evaluations revision 71152S Procedures 3-AOP-901 Acts of Nature Version 1.1 71152S Procedures 4-AOP-901 Acts of Nature Version 1.1 71152S Procedures NMP-OS-017 Severe Weather Version 3.1 71153 Calculations NMP-RE-019 Beacon 7 Estimated Critical Condition Calculations Version 5.0 71153 Corrective Action CR 11082481 Unit 4 Manual Reactor Trip 06/05/2024 Documents 71153 Miscellaneous NMP-GM-020- Event Recovery Report 06/17/2024 F03 71153 Procedures 4-AOP-207 Loss of Turbine Load Version 5.0 71153 Procedures 4-GOP-301-002 Mode 2 Change Checklists Version 1.2 71153 Procedures 4-GOP-302 Reactor Startup Mode 3 to Mode 2 Version 2.0 71153 Procedures 4-GOP-306 Plant Startup Mode 2 to 25% Power Version 4.0 71153 Procedures B-ADM-OPS-020 Reactor Trip Review Version 4.0

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