ML25323A421
| ML25323A421 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 11/19/2025 |
| From: | Mark Franke NRC/RGN-II/DORS |
| To: | Carr E Dominion Energy |
| References | |
| EPID L-2025-LLD-0007 | |
| Download: ML25323A421 (1) | |
Text
EAF-RII-2025-0197 Eric S. Carr President, Nuclear Operations and Chief Nuclear Officer Dominion Energy Innsbrook Technical Center 5000 Dominion Blvd., Floor: IN-3SE Glen Allen, VA 23060-6711
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION (NOED) FOR VIRGIL C. SUMMER NUCLEAR PLANT, UNIT 1 (EPID: L-2025-LLD-0007)
Dear Eric S. Carr:
By letter dated November 18, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25322A212), Dominion Energy South Carolina (DESC) requested that the U.S. Nuclear Regulatory Commission (NRC) exercise discretion for compliance with the actions required in V.C. Summer Unit 1 Technical Specification (TS) 3.7.1.2, Emergency Feedwater System.
This letter documented information previously discussed with the NRC in a telephone conference on November 14, 2025, at 6:00 p.m. Eastern Standard Time (EST). DESC requested that a NOED be granted pursuant to the NRCs policy regarding exercise of discretion for an operating power reactor, set out in the NRC Enforcement Manual, Appendix F, Notices of Enforcement Discretion. DESC requested that the NOED be effective for 79 hours9.143519e-4 days <br />0.0219 hours <br />1.306217e-4 weeks <br />3.00595e-5 months <br /> beyond November 15, 2025, at 2:08 a.m., which is the time the TS would have required V.C.
Summer to begin transition to hot shutdown, absent discretion. The NRC verbally approved the NOED at 7:26 p.m. on November 14, 2025. The principal NRC staff members who participated in the telephone conference are listed in Enclosure 1. The staff determined that the information in the letter requesting the NOED was consistent with the oral request.
The NRC first became aware of the potential for the NOED request on November 13, 2025, at approximately 4:00 p.m., through communication with the V.C. Summer Senior Resident Inspector and Project Manager. The events leading up to the NOED request are described below.
On November 12, 2025, while performing STP-220.002, Turbine Driven Emergency Feedwater Pump and Valve Test, the Turbine Driven Emergency Feedwater Pump (TDEFP) tripped after startup. Prior to the test failure, at 2:08 a.m. on November 12, 2025, the November 19, 2025
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TDEFP was declared inoperable and the licensee entered TS Limiting Condition for Operation (LCO) 3.7.1.2, Action A, which has a 72-hour requirement to restore the required emergency feedwater pumps to operable status, or be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. DESC determined the overspeed trip was caused by binding and degraded responsiveness of the turbine speed control governor valve assembly due to wear discovered on valve components. The specific valve control linkage components exhibiting wear required replacement. The estimated time to perform repairs and complete post-maintenance testing would extend beyond the TS LCO 3.7.1.2, Action A, completion time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The letter requesting the NOED indicated that the incremental conditional core damage probability (ICCDP) for V.C. Summer associated with 79 additional hours of TDEFP unavailability was 2.61E-07. The incremental conditional large early release probability (ICLERP) for V.C. Summer was 7.64E-09. These values were less than the 5E-7 ICCDP and 5E-8 ICLERP guidance thresholds specified in the NRC Enforcement Manual, Appendix F, Notices of Enforcement Discretion.
During the requested period of enforcement discretion, DESC documented they would implement risk management actions (RMAs) for the period of enforcement discretion during repairs/testing of the TDEFP. The licensee proposed the following compensatory RMAs to reduce the likelihood of risk significant initiating events and protect risk significant equipment:
Shiftly Crew Brief on the actions of EOP-6.0, ECA 0.0 Loss of All ESF AC Power, and EOP-15.0, FR-H.1 Response to Loss of Secondary Heat Sink, including procedure progression given current plant configuration Prohibition on switchyard work in accordance with SAP-0703, Control of Switchyard/Transformer Yard Activities Protection of the following equipment in accordance with OP-VC-601, Protected Equipment, protection scheme for the TDEFP:
A/B emergency diesel generators and associated breakers
A/B motor driven emergency feedwater pumps and associated breakers
Ladder to intermediate building 424 area Shiftly flood watch in 412 intermediate building general area, in addition to alarmed level switches in the 412 intermediate building sump area Performance of RMAs in procedurally identified areas with fire vulnerability with the TDEFP out of service in accordance with OAP-100.5 "Guidelines for Configuration Control and Operation of Plant Equipment," Enclosure P. The identified areas include portions of the control and intermediate buildings, and the RMAs include but are not limited to:
Suspension of hot work
Removal of transient combustibles
One hour roving fire watch Verification that Parr Hydro can be staffed within one hour of a request from V.C.
Summer, in accordance with established procedures, to provide a dedicated alternative source of offsite power to the plant Based on the NRC staffs evaluation of the licensees request, we determined that granting this NOED was consistent with the NRCs Enforcement Policy and staff guidance. The NOED request met the criteria specified in NRCs Enforcement Manual, Appendix F, Notices of Enforcement Discretion, Sections 2.2 and 2.5. Specifically, the NRC determined that it was
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appropriate to exercise discretion for 79 hours9.143519e-4 days <br />0.0219 hours <br />1.306217e-4 weeks <br />3.00595e-5 months <br /> to avoid an unnecessary shutdown of a reactor without a corresponding benefit to public health and safety or the environment. Therefore, as communicated verbally to the licensee at approximately 7:26 p.m. EST on November 14, 2025, the NRC exercised discretion to not enforce compliance with TS LCO 3.7.1.2, Action A, for the 79-hour period from November 15, 2025, at 2:08 a.m., until November 18, 2025, at 9:08 a.m.
The NRC staff noted, after its verbal approval for enforcement discretion, that the condition causing the need for this NOED was corrected and V.C. Summer Unit 1 exited from TS LCO 3.7.1.2, Action A at approximately 5:47 p.m. on November 16, 2025. As a result, this NOED terminated at 5:47 p.m. on November 16, 2025, within the period of the enforcement discretion.
As stated during the conference call and in DESCs letter, a determination was made that a follow-up license amendment was not necessary. The NRC staff agrees with this determination.
As stated in the NRC Enforcement Policy, enforcement action may be taken to the extent that violations were involved for the root cause that led to the noncompliance for which this NOED was necessary.
This letter and its enclosure will be made available for public inspection and copying at ADAMS Public Documents l NRC.gov 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, Mark E. Franke, Director Division of Operating Reactor Safety Docket No. 05000395 License No. NPF-12
Enclosure:
List of Key NRC Personnel Signed by Franke, Mark on 11/19/25
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available OFFICE RII/DORS RII/DORS NRR/DORL NAME M. Fannon H. Gonzalez M. Franke DATE 11/19/2025 11/19/2025 11/19/2025
Enclosure LIST OF KEY NRC PERSONNEL PARTICIPANTS NRC REGION II Mark Franke, Director, Division of Operating Reactor Safety (DORS)
Matthew Fannon, Chief, Projects Branch 2 (PB2), DORS Mac Read, Senior Resident Inspector - V.C. Summer Nuclear Plant, PB2, DORS KD Dials, Resident Inspector - V.C. Summer Nuclear Plant, PB2, DORS Andy Rosebrook, Senior Reactor Analyst, DORS Shane Sandal, Senior Reactor Analyst, DORS Tom Stephen, Senior Reactor Analyst, DORS Adam Wilson, Senior Project Engineer, PB2, DORS OFFICE OF NUCLEAR REACTOR REGULATION Hipo Gonzalez, Acting Deputy Director, Division of Operating Reactor Licensing (DORL)
Rob Atienza, Reactor Systems Engineer, Containment and Plant Systems Branch, Division of Safety Systems (DSS)
Stewart Bailey, Chief, Mechanical Engineering and Inservice Testing Branch, Division of Engineering and External Hazards (DEX)
Nicholas Hansing, Mechanical Engineer, Mechanical Engineering and Inservice Testing Branch, DEX Brian Lee, Senior Safety and Plant Systems Engineer, Containment and Plant Systems Branch, DSS Ed Miller, Senior Project Manager, Plant Licensing Branch II-1, DORL David Nold, Safety and Plant Systems Engineer, Containment and Plant Systems Branch, DSS Qin Pan, Reliability and Risk Analyst, PRA Oversight Branch, Division of Risk Assessment (DRA)