IR 05000395/2025002
| ML25213A008 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 08/06/2025 |
| From: | Matthew Fannon NRC/RGN-II/DORS/PB2 |
| To: | Carr E Dominion Energy |
| References | |
| IR 2025002 | |
| Download: ML25213A008 (1) | |
Text
SUBJECT:
VIRGIL C. SUMMER NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000395/2025002
Dear Eric S. Carr:
On June 30, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Virgil C. Summer Nuclear Plant. On July 29, 2025, the NRC inspectors discussed the results of this inspection with Doug Edwards, Director Nuclear Plant Support and other members of your staff. The results of this inspection are documented in the enclosed report.
Four findings of very low safety significance (Green) are documented in this report. Three 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 Nuclear Plant.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 Nuclear Plant.
August 6, 2025 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, Matthew S. Fannon, Chief Reactor Projects Branch 2 Division of Operating Reactor Safety Docket No. 05000395 License No. NPF-12
Enclosure:
As stated
Inspection Report
Docket Number:
05000395
License Number:
Report Number:
Enterprise Identifier:
I-2025-002-0025
Licensee:
Dominion Energy
Facility:
Virgil C. Summer Nuclear Plant
Location:
Jenkinsville, SC
Inspection Dates:
April 01, 2025, to June 30, 2025
Inspectors:
K. Dials, Project Engineer
M. Read, Senior Resident Inspector
A. Ruh, Senior Reactor Inspector
J. Tornow, Physical Security Inspector
J. Walker, Senior Emergency Preparedness Inspector
J. Zeiler, Senior Resident Inspector
Approved By:
Matthew S. Fannon, Chief
Reactor Projects Branch 2
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Virgil C. Summer Nuclear Plant, 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 Demonstrate Effective Control of a Maintenance Rule Scoped System Cornerstone Significance Cross-Cutting Aspect Report Section Public Radiation Safety Green NCV 05000395/2025002-01 Open/Closed
[H.3] - Change Management 71111.12 Inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR 50.65(a)(2), for the licensee's failure to demonstrate that the performance or condition of the main plant vent radiation monitor (RM-A13) was being effectively controlled through the performance of appropriate preventive maintenance, such that the component remained capable of performing its intended function. Specifically, the licensee failed to adequately track failures and follow procedures to perform evaluations of the effectiveness of maintenance such that RM-A13 failed seven times between January 2024 and March 2025.
Failure to Dedicate Commercial-Grade Items Prior to Installation into Safety-Related Fuel Oil Transfer Pumps Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000395/2025002-02 Open/Closed
[H.5] - Work Management 71111.15 Inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR 50,
Appendix B, Criterion III, "Design Control," when the licensee failed to follow procedures to identify and dedicate commercial-grade parts prior to use. Specifically, the licensee used non-safety related pump rebuild kits during maintenance activities on the four safety-related fuel oil transfer pumps.
Failure to Identify Fatigue-related Degradation on Electrohydraulic Control System Tubing Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000395/2025002-03 Open/Closed
[H.1] -
Resources 71152A A self-revealed finding (FIN) of very low significance (Green) was identified when periodic system engineering walkdowns failed to identify fatigue-related degradation on the turbine electrohydraulic control (EHC) system tubing, which failed and required a manual reactor trip.
Failure to Remove Rubber Shipping Grommet During Emergency Feedwater Pump Governor Installation Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000395/2025002-04 Open/Closed None (NPP)71152A A self-revealed Green finding and associated non-cited violation (NCV) of Technical Specification 6.8.1.a was identified when the licensee failed to provide an adequate maintenance procedure to check for and remove all vendor installed shipping plugs from the turbine-driven emergency feedwater (TDEFW) pump governor before installation in the plant, which eventually challenged the ability of the pump to maintain speed during testing.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000395/2025-001-00 LER 2025-001-00 for Virgil C. Summer Nuclear Station,
Unit 1 (VCSNS), Manual Reactor Trip due to Unisolable EHC Leak 71152A Closed
PLANT STATUS
The unit operated at or near rated thermal power for the entire 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
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)
'A' emergency diesel generator on April 29, 2025, prior to testing on the 'B' emergency diesel generator (2)
'A', 'B', and 'C' main steamline isolation and relief valves, on April 29, 2025
- (3) Electric-driven and alternate diesel-driven fire service pumps on May 27, 2025, while the diesel-driven fire service pump was under maintenance (4)125-volt safety-related battery XBA1A and XBA1B, battery charger XBC1B, and spare battery charger XBC1A-1B, completed on June 27, 2025, while the normal A train battery charger XBC1A was out of service due to an emergent failure
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) Service water pump house on May 27, 2025
- (2) Safety-related battery rooms in intermediate building elevation 412 feet on June 18, 2025
- (3) Chillers and chilled water pump rooms on June 18, 2025
- (4) Intermediate building elevation 412 feet on June 18, 2025
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated internal flooding mitigation protections in the auxiliary building west penetration room on elevation 412 feet, inspection completed on June 2, 2025.
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 'B' emergency diesel generator testing on June 26, 2025.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated [scenario confidential] on June 11, 2025.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Radiation monitors on June 13, 2025
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 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) Chilled water system on April 22, 2025, during preventative maintenance on the 'B' chiller and the 'B' chilled water pump (2)
'B' emergency diesel generator during 'A' emergency diesel generator lubricating oil system maintenance on May 6, 2025
- (3) Increased risk during maintenance activities on the diesel-driven fire service water pump on May 27, 2025
- (4) Elevated risk during the emergent replacement of the 'B' service water booster pump motor on June 18, 2025
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) Condition report (CR)1286845, radiation monitor RM-A3 sample pump failure, review completed on April 7, 2025
- (2) CR1290146 and CR1290132, reactor coolant system letdown line pressure oscillations, review completed on April 29, 2025
- (3) CR1289935, intermediate building preaction sprinkler system failed operability testing, review completed on June 6, 2025
- (4) CR1291046, procurement engineering could not locate documentation justifying use of non-safety repair kits, review completed on June 30, 2025
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) (3 Samples)
- (1) SOP-503, testing of the 'B' train battery and charger room ventilation system, on April 7, 2025, following belt replacement for the supply fan and lubrication of the exhaust fan
- (2) PTP-113.002B, 'B' chiller performance testing, following preventative maintenance package, on April 24, 2025
- (3) SOP-301, 'A' emergency diesel generator testing, following lubricating oil system maintenance, on May 6, 2025
Surveillance Testing (IP Section 03.01) (3 Samples)
- (1) EMP-115.045, testing of the equipment building uninterruptable power supply, on April 2 and 3, 2025
- (2) STP-128.310, pre-action fire system testing for the diesel generator building, on May 12, 2025
- (3) STP-220.002, turbine-driven emergency feedwater pump and valve test, on June 9, 2025
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) STP-220.007, 'B' train emergency feedwater flow control valve air supply check valve testing, on April 8, 2025
Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)
- (1) FLEX steam generator feed pump and A/B booster/transfer pump surveillance testing, on June 23, 2025
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 12, 2025. This evaluation does not constitute NRC approval.
71114.06 - Drill Evaluation
Additional Drill and/or Training Evolution (1 Sample)
The inspectors evaluated:
- (1) Inspectors observed a hostile-action training drill which resulted in a general emergency on April 9, 2025
71114.07 - Exercise Evaluation - Hostile Action (HA) Event
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the biennial emergency plan exercise during the week of May 12, 2025. The scenario began with a simulated report from the field that a hostile action was occurring within the owner controlled area, thus meeting the criteria for declaration of an Alert. As the scenario progressed, hostile action in the protected area is reported by the security team leader and a Site Area Emergency is declared.
Around the time it is reported that all adversaries are neutralized a control rod ejection occurs and radiation monitor readings begin to increase. When effluent radiation levels reached a prescribed threshold, conditions for a General Emergency were met, and the Offsite Response Organizations were able to demonstrate their ability to implement emergency actions.
71114.08 - Exercise Evaluation - Scenario Review
Inspection Review (IP Section 02.01 - 02.04) (1 Sample)
- (1) The inspectors reviewed and evaluated in-office, the proposed scenario for the biennial emergency plan exercise at least 30 days prior to the day of the exercise.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===
- (1) Unit 1 (April 1, 2024, to March 31, 2025)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)
- (1) Unit 1 (April 1, 2024, to March 31, 2025)
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)
- (1) Unit 1 (April 1, 2024, to March 31, 2025)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)
- (1) Unit 1 (April 1, 2024, to March 31, 2025)
BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)
- (1) Unit 1 (April 1, 2024, to March 31, 2025)
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
- (1) January 1, 2024, through March 31, 2025 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
- (1) January 1, 2024, through March 31, 2025 EP04: Emergency Response Facility and Equipment Readiness (ERFER) (IP Section 02.14) (1 Partial)
(1)
(Partial)
This is a new NRC performance indicator, described in NEI 99-02, Revision 8 (ML24331A114). Licensees began collecting data for this performance indicator January 1, 2025. Therefore, at the time of inspection there was no quarterly data compiled and submitted to the NRC.
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) CR1284643, turbine-driven emergency feedwater pump surveillance test failure, review completed on June 5, 2025
- (2) CR1282758, manual reactor trip after electrohydraulic control system leak, review completed on June 30, 2025
71153 - Follow Up of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03)
- (1) LER 05000395/2025-001-00, Manual Reactor Trip Due to Unisolable EHC Leak (ADAMS Accession No. ML25097A291). The inspectors evaluated the manual reactor trip following an electrohydraulic control (EHC) system leak and the licensees performance on February 10, 2025. Inspectors did not identify any violations of regulatory requirements for the licensee's response to the EHC leak. Additional inspection conclusions associated with this LER are documented in this report under Inspection Results Section 71152A. This LER is Closed.
INSPECTION RESULTS
Failure to Demonstrate Effective Control of a Maintenance Rule Scoped System Cornerstone Significance Cross-Cutting Aspect Report Section Public Radiation Safety Green NCV 05000395/2025002-01 Open/Closed
[H.3] - Change Management 71111.12 Inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR 50.65(a)(2), for the licensee's failure to demonstrate that the performance or condition of the main plant vent radiation monitor (RM-A13) was being effectively controlled through the performance of appropriate preventive maintenance, such that the component remained capable of performing its intended function. Specifically, the licensee failed to adequately track failures and follow procedures to perform evaluations of the effectiveness of maintenance such that RM-A13 failed seven times between January 2024 and March 2025.
Description:
Inspectors reviewed fleet maintenance rule program changes and the licensee's implementation of the procedures to evaluate repetitive failures of RM-A13. Inspectors noted failures on January 21, 2024 (CR1248854), December 4, 2024 (CR1277875), December 6, 2024 (CR1278128), December 22, 2024 (CR1279309), January 7, 2025 (CR1279997), and March 24, 2025 (CR1286732) due to an "Error Code 7" displayed. Inspectors also noted a failure on April 18, 2024 (CR1256952) due to a ratemeter failure.
The main plant vent radiation monitor is part of the radiation monitoring system described in final safety analysis report (FSAR) section 11.4, "Process and Effluent Radiological Monitoring Systems," and provides extended range radiation monitoring for the main plant vent described in Section 9.4.2, Auxiliary and Radwaste Area Ventilation System, of the FSAR. The licensee declared RM-A13 inoperable following each failure and implemented a preplanned alternate method of monitoring in accordance with the requirements of action 30 of technical specifications (TS) Table 3.3-6.
Paragraph 50.65(a)(2) of 10 CFR specifies, Monitoring as specified in paragraph (a)(1) of this section is not required where it has been demonstrated that the performance or condition of a structure, system, or component is being effectively controlled through the performance of appropriate preventive maintenance, such that the structure, system, or component remains capable of performing its intended function. Inspectors determined that the repetitive failures of RM-A13 are contrary to 10 CFR 50.65(a)(2) and do not demonstrate that the performance or condition of the component was being effectively controlled through the performance of appropriate preventive maintenance, such that the component remained capable of performing its intended function. Inspectors noted to the licensee that CR1258854 was the only one of the seven failures that was properly screened and evaluated in the maintenance rule tracking software at the time of the inspection. That screening determined that the Error Code 7 failure on January 21, 2024, was a functional failure.
Inspectors reviewed program and procedure changes to the licensees maintenance rule program which went into effect on June 13, 2024. Procedure ER-AA-MRL-100, "Implementing Maintenance Rule," Revision 16, Step 3.3 required trending of non-risk significant failure evaluations, known as "Trending Evaluation." In-scope radiation monitors such as RM-A13 are considered non-risk significant. Attachment 10, Step 3.3.3 states, "If the event is a trending event, then select a trending group in the MRule Software and, using subsections 3.5 and 3.6, evaluate whether there is a potential unfavorable trend due to ineffective maintenance of the SSC." Step 3.3.4 states, "For all potential unfavorable trends, ensure that a cause evaluation is assigned in accordance with PI-AA-200 to document the trend evaluation and determination of apparent cause." Step 3.3.5 states, "If an unfavorable trend is identified by the cause evaluation, then identify that an (a)(1) evaluation is required and ensure an assignment is created in PAMS to track performance of the (a)(1) evaluation."
Inspectors determined that contrary to the revised procedure, the licensee failed to perform trending evaluations after each failure and therefore did not identify the unfavorable trend, perform cause evaluations, or perform a 10 CFR 50.65(a)(1) evaluation.
Corrective Actions: The licensee documented a degraded performance trend for RM-A13 in CR1287141. After each Error Code 7 failure, RM-A13 was reset after outside temperatures increased and functioned until the next failure. The licensee replaced the ratemeter in April 2024 and the detector in January 2025.
Corrective Action References: CR1287141, CR1286732
Performance Assessment:
Performance Deficiency: The failure of the licensee to demonstrate that the performance or condition of RM-A13 was being effectively controlled through the performance of appropriate preventive maintenance, such that the component remained capable of performing its intended function, is a performance deficiency reasonably within the licensee's ability to foresee and prevent.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Plant Facilities/Equipment and Instrumentation 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, considering the number of functional failures without adequate trending or evaluation, performance indicated that the SSC was not being effectively controlled through appropriate preventive maintenance, and the SSC was evaluated for designation under 10 CFR 50.65(a)(1). This is similar to IMC 0612 Appendix E, "Examples of Minor Issues,"
Example 8.g.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix D, Public Radiation Safety SDP. The finding was determined to be of very low safety significance (Green) since it did not result in a substantial failure to implement the effluent monitoring program, and did not involve any effluent releases that exceeded 10 CFR 50 Appendix I or 10 CFR 20.1301(e) limits.
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.
Specifically, the changes to the Maintenance Rule program and procedures were not effectively managed such that system performance issues were not screened and trended in a timely manner.
Enforcement:
Violation: 10 CFR 50.65(a)(1) requires, in part, each holder of an operating license for a nuclear power plant under this part shall monitor the performance or condition of SSCs, against licensee-established goals, in a manner sufficient to provide reasonable assurance that these SSCs, as defined by 10 CFR 50.65(b), are capable of fulfilling their intended functions.
10 CFR 50.65(a)(2) requires, in part, that monitoring, as specified in 10 CFR 50.65(a)(1), is not required where it has been demonstrated that the performance or condition of an SSC is being effectively controlled through the performance of appropriate preventive maintenance, such that the SSC remains capable of performing its intended function.
Contrary to the above, following failures of RM-A13 on December 4, 2024, December 6, 2024, December 22, 2024, April 8, 2024, January 7, 2025, and March 24, 2025, the licensee failed to follow implementing procedures to perform trending, perform evaluations, and perform a 10 CFR 50.65(a)(1) evaluation, and the failures demonstrated that the performance or condition of the radiation monitor was not being effectively controlled through the performance of appropriate preventive maintenance.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Dedicate Commercial-Grade Items Prior to Installation into Safety-Related Fuel Oil Transfer Pumps Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000395/2025002-02 Open/Closed
[H.5] - Work Management 71111.15 Inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion III, "Design Control," when the licensee failed to follow procedures to identify and dedicate commercial-grade parts prior to use. Specifically, the licensee used non-safety related pump rebuild kits during maintenance activities on the four safety-related fuel oil transfer pumps.
Description:
Inspectors identified that the licensee installed non-safety related (NS) parts on six occasions during maintenance impacting four safety-related (SR) fuel oil transfer pumps.
The fuel oil transfer pumps have a safety function to transfer fuel from underground storage tanks to the emergency diesel generator day tanks.
NS pump rebuilt kits were installed in 2013 (XPP-4A and XPP-141A), 2014 (XPP-4B and XPP-141B), and 2024 (XPP-4A and XPP-141A) under licensee procedure MMP-180.006, "Emergency Diesel Generator Engine Fuel Oil System Maintenance," Revision 11. Although material restraints were listed on the work order due to the NS kits on a SR work order, the kits were installed without a technical evaluation.
Licensee procedures allow extension of quality requirements when parts cannot be procured as SR from a qualified supplier or commercial grade dedication of parts. Licensee procedure MS-AA-PTE-401-1004, "Commercial Grade Dedication," Revision 12, Step 3.3.1 defined commercial grade as satisfying each of three criteria: not subject to design or specification requirements that are unique to nuclear facilities or activities; used in applications other than nuclear facilities or activities; ordered from the manufacturer/supplier on the basis of specifications set forth in manufacturer's published product description. Licensee procedure MS-AA-PTE-401, "Procurement Technical Evaluation Determination," Revision 24, Step 3.4.3 stated, in part, that when the criteria for commercial dedication are met, "then procure as a commercial grade item for dedication under Dominion Energy's quality assurance program."
Furthermore, Step 3.4.5 stated, in part, when "an item intended for use in a safety related application does not meet the definition of a commercial grade item" and "a replacement is needed and the OEM no longer provides the item under an approved quality assurance program," then "procure the item as a basic component under Dominion Energy's quality assurance program by extending via source verification."
Commercial-grade dedication is a process by which a commercial-grade item (CGI) is designated for use as a basic component. This acceptance process is undertaken to provide reasonable assurance that a CGI to be used as a basic component will perform its intended safety function and, in this respect, is deemed equivalent to an item designed and manufactured under a 10 CFR Part 50, Appendix B, quality assurance program. This assurance is achieved by identifying the critical characteristics of the item and verifying their acceptability by inspections, tests, or analyses by the purchaser or third-party dedicating entity.
Inspectors determined that the installation of NS parts kits into the SR fuel oil transfer pumps bypassed the quality assurance processes in procurement or dedication and affected the reliability and qualification of the system. Inspectors noted that pumps XPP-4B and XPP-141B were rebuilt with SR repair kits in 2025 and were at that time fully qualified. Inspectors determined that pumps XPP-4A and XPP-141A have NS parts and are not fully qualified.
Additionally, 10 CFR Part 21, Section 21.31 requires that each individual, corporation, partnership, dedicating entity, or other entity subject to the regulations in this part shall ensure that each procurement document for a facility, or a basic component issued by him, her or it on or after January 6, 1978, specifies, when applicable, that the provisions of 10 CFR Part 21 apply. This is to ensure that the SR supplier or dedicating entity is responsible for identifying and evaluating deviations, reporting defects and failures to comply for the dedicated item, and maintaining auditable records of the dedication process. By bypassing the dedication process, 10 CFR Part 21 requirements were not invoked.
Corrective Actions: The licensee reviewed pumps XPP-4A and XPP-141A for operability and determined that the pumps maintained reasonable assurance that they could perform their safety function until a future rebuild. XPP-4B and XPP-141B are not affected since this issue was discovered after they had been rebuilt with an appropriate kit.
Corrective Action References: CR1291046
Performance Assessment:
Performance Deficiency: The licensee's use of NS parts to rebuild SR pumps without proper procurement or dedication of those parts was a performance deficiency within their ability to foresee and correct.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the installation of NS parts kits into the SR fuel oil transfer pumps bypassed the quality assurance processes in procurement or dedication and affected the reliability and qualification of the system. This is similar to Example 5.c of Inspection Manual Chapter 0612, Appendix E, "Examples of Minor Issues."
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Specifically, the inspectors determined the finding was of very low safety significance (Green)because the operability of the fuel oil transfer pumps was maintained. Furthermore, inspectors noted that the lower quality classification of the parts was mitigated by the procurement of the kits from the pump original equipment manufacturer and by the licensee performing pump performance testing and trending on a quarterly basis.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Inspectors determined that several opportunities in the work management process allowed the installation of NS parts into SR pumps in 2013, 2014, and 2024. These included procurement documentation, communications between MAXIMO and SAP programs for materials management, work planning and reserving of nonconforming materials, material issuance from the warehouse with open restraints, and maintenance installation with an open work order restraint.
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that the measures shall also be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components.
Contrary to the above, the licensee failed to maintain design control for the SR fuel oil transfer pumps when NS parts were used to rebuild the pumps in 2013, 2014, and 2024.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Identify Fatigue-related Degradation on Electrohydraulic Control System Tubing Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000395/2025002-03 Open/Closed
[H.1] -
Resources 71152A A self-revealed finding (FIN) of very low significance (Green) was identified when periodic system engineering walkdowns failed to identify fatigue-related degradation on the turbine electrohydraulic control (EHC) system tubing, which failed and required a manual reactor trip.
Description:
On February 10, 2025, during the performance of licensee procedure PTP-102.001, "Main Turbine Test," an unisolable leak on the EHC system skid developed. The licensee had started both EHC pumps in accordance with the procedure and stroked the first control valve. After the performance of this step, the local operator identified the smell of EHC in the air, went to the EHC skid, and noticed a leak coming from 1/4-inch tubing on the top of the skid. The licensee was unable to isolate the leak, and the EHC fluid reservoir continued to lower. The main turbine load was lowered; however, the EHC leak rate was too high and required the licensee to manually trip the reactor.
During the investigation, the licensee identified fretting and wall thinning of 1/4-inch tubing at a clamp location just above the EHC skid top plate. The tubing clamp at the location of the leak had loosened over time. Normal vibration from the EHC skid pumps created relative movement between the tube and clamp causing wear and loss of material on the tube wall which thinned to the point of failure.
The EHC system operates at approximately 1650 psig. During the test with both EHC pumps running, the EHC header pressure increased to approximately 1714 psig. The failed tubing was aircraft hydraulic quality chromium-nickel steel seamless tubing (AISI type 304), 1/4-inch outer diameter with nominal 0.045-inch wall thickness, which was rated at 3000 psig.
The inspectors determined that periodic system engineering walkdowns performed in accordance with ER-AA-101, "System Engineering Walkdowns," Revision 10, could have identified the degraded condition. Several bullets in Attachment 2 were applicable to the conditions of the EHC skid prior to the failure:
1. "#17: Lines/pipes loose or unbracketed" - The tubing was loose in the clamp.
2. "#26: Skids, foundations, supports, hangers, and fasteners are not loose, corroded,
stressed, seized, or rusted" - The clamp was a double-tubing clamp with the attachment screw on one side, which is susceptible to loosening or relaxing due to the design and was not identified as loose.
3. "#29: No foreign material such as paint, adhesive, or markings on stainless steel
piping" - The tubing clamp and stainless steel tubing and were painted, which masked the condition of the tubing.
4. "#50: Tubing (particularly copper tubing and tubing on skid-mounted equipment) that
potentially could fail due to cyclic fatigue, thermal fatigue, or the frequency of disassembly. Inspect tubing and fittings for excess vibration and external damage." -
The tubing on the EHC skid was subject to continuous vibration due to the EHC pump operation, had visible degradation to the paint on the tubing near the clamp, and eventually failed due to fretting.
The designated frequency for engineering walkdowns of the main turbine and accessories system group, including the EHC system, was quarterly. Inspectors did not identify any detailed discussions of the EHC skid or deficiencies during reviews of system health and system walkdown reports. Inspectors noted that operational risk considerations may have challenged access to the top of the EHC skid while the unit was online, but ER-AA-101 Step 3.1.9 required, "perform a walkdown on portions of the system inaccessible during power operation during refueling outages or forced outages."
Corrective Actions: The licensee replaced the affected portions of the EHC system with new 1/4-inch stainless steel tubing and fittings. During the extent of condition walkdown, two valves on the EHC skid were found to have degraded mounts. Additionally, tubing clamps on the EHC skid were physically inspected and tightened as needed. The licensee also established a recurring preventative maintenance schedule to physically inspect tubing, clamps, and supports on the EHC skid for degradation and looseness during each refueling outage.
Corrective Action References: CR1282758
Performance Assessment:
Performance Deficiency: The licensees failure to identify degraded conditions on EHC tubing during periodic system walkdowns was a performance deficiency that was within their ability to foresee and correct.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance 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 fatigue-related degradation continued until the tubing failed, which required a manual reactor trip.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding screened to Green when the question, "Did the finding cause a reactor trip AND the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition (e.g., loss of condenser, loss of feedwater)?" was answered "No."
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.
Specifically, inspectors determined that the most likely cause of the missed identification was due to the thoroughness of the walkdowns, which can be related to the resources and staffing assigned to perform the work.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
Failure to Remove Rubber Shipping Grommet During Emergency Feedwater Pump Governor Installation Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000395/2025002-04 Open/Closed None (NPP)71152A A self-revealed Green finding and associated non-cited violation (NCV) of Technical Specification 6.8.1.a was identified when the licensee failed to provide an adequate maintenance procedure to check for and remove all vendor installed shipping plugs from the turbine-driven emergency feedwater (TDEFW) pump governor before installation in the plant, which eventually challenged the ability of the pump to maintain speed during testing.
Description:
On March 4, 2025, the licensee declared the TDEFW pump inoperable due to a condition identified during a surveillance test. The pump drifted to slower speeds as the pump was running without any operator input. During troubleshooting activities, the licensee identified a vendor-installed rubber grommet inside the fitting on the pneumatic speed control tubing connection on the governor. The grommet had likely been installed during refurbishment activities in 2012, and the governor had been installed in the plant since 2017.
The port was vented during the troubleshooting run and the pump speed began to increase, demonstrating the port blockage was causing the drifting.
The licensee proactively replaced the governor and returned the TDEFW pump to operable on March 6, 2025.
With the grommet installed in the TDEFW governor, air was trapped inside a bellows that was originally used for pneumatic speed control. The licensee has not used the pneumatic speed control feature since 1998, opting instead for the manual speed setting knob for speed setpoint control. This setup requires that the bellows for pneumatic speed control is vented to prevent pressurization, so the manual speed control knob is the only speed adjustment. With the bellows plugged during testing, the temperature of the trapped air in the bellows rose, which increased air pressure. This caused the bellows to depress the speed setting plunger, which reduced oil flow to the speed setting piston. This, in turn, changed the spring tension and set a new operating point for the spinning flyweight. Essentially, due to the air port being blocked, the maximum speed was lowered proportional to the increase in governor temperature.
The inspectors reviewed licensee procedure MMP-300.015, Turbine Maintenance, Emergency Feedwater Pump TPP0008, revision 19. The inspectors determined that there was no step in the procedure to ensure the control port was vented during governor installation.
The licensee evaluated the condition, performed additional testing through a vendor, and determined that the pump remained operable. Despite the lowering speed and inability to meet the testing acceptance criteria, during the worst-case accident conditions that were reliant on the TDEFW pump, the licensee's analysis concluded that the pump would have been able to maintain steam generator levels. Inspectors reviewed the analysis and concluded that there was reasonable assurance that the degraded condition would not have prevented fulfillment of the safety function based on the as-found testing results.
Corrective Actions: The licensee removed the grommet from the governor bellows to demonstrate that it was causing the speed drift. The licensee proactively replaced the governor and ensured the new governor control air port was vented.
Corrective Action References: CR1284643
Performance Assessment:
Performance Deficiency: The failure to provide adequate procedures for maintenance on safety-related equipment was a performance deficiency. Specifically, the licensee failed to provide an adequate maintenance procedure to ensure the control air port was vented when installing the TDEFW pump governor.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the grommet installed on the TDEFW governor put the safety-related pump into a degraded condition which lowered the speed of the pump and slowly decreased during testing to below the surveillance test acceptance criteria. Although the licensee reasonably demonstrated through analysis that the pump would have been able to perform its safety function, the margin of safety was degraded.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Inspectors used Exhibit 2, "Mitigating Systems Screening Questions," and determined that the violation screened to Green by answering question A.1, "If the finding is a deficiency affecting the design or qualification of a mitigating SSC, does the SSC maintain its operability or PRA functionality?" as "Yes." Specifically, the licensee performed a detailed analysis of the pump performance degradation compared to minimum flow rates required for worst-case accident sequences. Although margin was degraded, inspectors agreed that there was reasonable assurance that the as-found condition would have performed its safety function.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. Specifically, although the installation procedure was inadequate during the most recent governor installation in 2017 and was inadequate during the failure in 2025, the procedure revision should have occurred in 1998 during the design change process to remove the remote control feature.
Enforcement:
Violation: Technical Specification 6.8.1, Procedures and Programs, requires, in part, that written procedures be implemented covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, Section 9.a, maintenance that can affect the performance of safety-related equipment should be properly pre-planned. The licensee established procedure MMP-300.015, Turbine Maintenance, Emergency Feedwater Pump TPP0008, Revision 18, to meet the Regulatory Guide 1.33 requirement.
Contrary to the above, during the April 2017 TDEFW governor replacement, the licensee failed to provide adequate instructions in MMP-300.015 to ensure that the control air port was vented.
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 July 29, 2025, the inspectors presented the integrated inspection results to Doug Edwards, Director Nuclear Plant Support, and other members of the licensee staff.
- On May 15, 2025, the inspectors presented the emergency preparedness exercise inspection results to Beth Jenkins, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
SOP-311
25 VDC System
Revision 13
SOP-509
Fire Suppression System
Revision
21C
Procedures
STP-501.001A
Battery XBA1A Weekly Test
Revision 4
Drawings
FP1IB-412,
Intermediate
Building
Revision 6
Calculations
Calculation
DC03290-006
"Evaluation for Auxiliary Building Pipe Rupture / Flooding
Effects"
Revision 0
CR1286329
CR1286340
Corrective Action
Documents
CR1286344
Revision 0
D-109-014
Intermediate Building
Revision 6
Drawings
D-109-019
Intermediate Building Miscellaneous Details
Revision 1
Procedures
STP-125.002B
Diesel Generator B Operability Test
Revision 4
Corrective Action
Documents
CR1282598
CR1289667
Corrective Action
Documents
CR1289710
CR1289935
CR1290684
Corrective Action
Documents
CR1290761
GTP-702
Surveillance Activity Tracking and Triggering
Revision 19E
HPP-0904
Use of the Radiation Monitoring System (RMS)
Revision 14A
MMP-180.006
Emergency Diesel Generator Engine Fuel Oil System
Maintenance
Revision 11A
MS-AA-PTE-401
Procurement Technical Evaluation Determination
Revision 24
Procedures
MS-AA-PTE-401-
1004
Revision 12
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
MS-AA-WHI-801
Issues and Returns
Revision 7
Offsite Dose
Calculation
Manuel (ODCM)
Revision 32
Revision 18
Fire Protection Program Surveillances and Compensatory
Measures
Revision 6
Work Management
Revision 40
Work Order Planning
Revision 22
Work Orders
EMP-115.045
IUQ79200/IUQ79201 Ametek 3DPP UPS Maintenance
Revision 1B
MMP-460.022
Inspection, Cleaning and Lubrication of Fan Coil Units
Revision
16G
VCS-ERP-0140
FX Steam Generator Feed Pump Operation
Revision 1
Procedures
VCS-ERP-0144
FX Booster Transfer Pump Operation
Revision 0
DSEM
PIR1231616
03/24/2025
Radiation Emergency Plan
Rev. 76
Conduct of Drills and Exercises
Rev. 500
EP-AA-DAM-101
Core Damage Estimation
Rev. 0
VCS-EPP-0001
Classification of Emergencies
Rev. 2
VCS-EPP-0012
Onsite Personnel Accountability and Evacuation
Rev. 3
VCS-EPP-0027
Hostile Action
Rev. 4
Procedures
VCS-EPP-0123
Emergency NRC Notifications
Rev. 0
Procedures
VCS-EPP-0108
Emergency Action Level Technical Basis
Rev. 5
21359
PI Adverse Trend Roll-up CR
03/09/2023
239533
10/02/2023
281140
01/21/2025
Corrective Action
Documents
DSEM
PIR1238993
03/24/2025
71151
Miscellaneous
NRC/INPO/WANO Performance Indicator and MOR
Reporting
Revision 4
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Emergency Preparedness Performance Indicators
Rev. 12
Engineering
Changes
ECR 50157B
deletion of the speed controller for TDEFWP
June 22,
2000
Engineering
Evaluations
ETE-VC-2025-
0030
Turbine Driven Emergency Feedwater Pump Functionality
Evaluation
Work Orders
98-0823