IR 05000461/2025004

From kanterella
Jump to navigation Jump to search
Integrated Inspection Report 05000461/2025004
ML26040A159
Person / Time
Site: Clinton 
(NPF-062)
Issue date: 02/10/2026
From: Robert Ruiz
NRC/RGN-III/DORS/RPB1
To: Mudrick C
Constellation Energy Generation
References
IR 2025004
Download: ML26040A159 (0)


Text

SUBJECT:

CLINTON POWER STATION - INTEGRATED INSPECTION REPORT 05000461/2025004

Dear Christopher H. Mudrick:

On December 31, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Clinton Power Station. On January 23, 2026, the NRC inspectors discussed the results of this inspection with F. Payne, Site Vice President, 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. None of these findings involved a violation of NRC requirements.

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 III; and the NRC Resident Inspector at Clinton Power Station.

February 10, 2026 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, Robert Ruiz, Chief Reactor Projects Branch 1 Division of Operating Reactor Safety Docket No. 05000461 License No. NPF-62 Enclosure:

As stated cc w/ encl: Distribution via GovDelivery Signed by Ruiz, Robert on 02/10/26

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Clinton Power Station, 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 follow Preventive Maintenance Revision Process Leads to Servovalve Failure and Automatic Scram on High Water Level Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000461/2025004-01 Open/Closed

[H.14] -

Conservative Bias 71111.13 A Green finding of site procedure WC-AA-120, Preventive Maintenance (PM) Database Revision Requirements, and AD-AA-3000, Nuclear Risk Management, was self-revealed when the plant scrammed on high reactor water level. Equipment failure analysis revealed the failure mechanism to be metallic particulate silt accumulation in the Electro-Hydraulic Control (EHC)servovalve causing the valve to become stuck in the open position leading to the overfeeding event. Specifically, the servovalve failed due to the sites decision to extend the servovalve replacement frequency from every 3 refueling outages (O3) to every 4 refueling outages (O4), in 2024, without a technically robust risk assessment and screening per the sites preventive maintenance change processes.

Failure to Follow Parts Quality Process Leads to Turbine Electro-Hydraulic Control Oil Leak and Manual Scram Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000461/2025004-02 Open/Closed None (NPP)71111.13 A Green finding of SM-AC-3019, Parts Quality Process, was self-revealed when the operators inserted a manual scram due to low EHC oil level. Specifically, Clinton failed to properly screen the turbine control valve actuator into the Parts Quality Initiative (PQI) program, and therefore inadequately tested the actuator prior to accepting it into inventory. This resulted in the #3 Turbine Control Valve (TCV3) actuator being installed in 2018 and subsequently failing in the fall of 2025, causing an un-isolable EHC rupture in the heater bay resulting in a low EHC oil level (-24.5"), which led to a procedurally-required manual scram.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 began the inspection period in Mode 4, cold shutdown, due to the ongoing refueling outage, C1R22. The reactor achieved criticality on October 2, 2025. The generator was synchronized to the grid on October 4, 2025, ending refueling outage C1R22. Later, on October 4, 2025, the generator tripped on differential overcurrent, and the site entered forced outage C1F65. The reactor remained stable at 14 percent rated thermal power (RTP).

Following repair activities, the generator was synchronized to the grid following C1F65 on October 5, 2025.

On October 6, 2025, during reactor startup, Unit 1 automatically scrammed on high reactor water level when operating at 23 percent RTP. The unit subsequently entered Mode 3 and forced outage C1F66 due to the automatic scram. Following repair activities, the reactor achieved criticality on October 7, 2025, and synchronized to the grid on October 8, 2025.

The reactor achieved approximately 95 percent RTP on October 11, 2025. Reactor power was subsequently lowered to approximately 70 percent RTP for a planned rod pattern adjustment and then raised back to 95 percent RTP. On October 13, 2025, reactor power was lowered to approximately 70 percent RTP for a planned rod pattern adjustment. Reactor power was subsequently raised to approximately 100 percent RTP on October 14, 2025.

On October 22, 2025, Unit 1 reactor power was lowered from approximately 100 percent RTP to 86 percent RTP to support mitigation actions in combating an EHC fluid leak from the #3 turbine control valve positioner. The reactor was subsequently manually scrammed from approximately 86 percent RTP due to low level in the EHC reservoir. Unit 1 subsequently entered Mode 3 and forced outage C1F67. Unit 1 entered Mode 4, cold shutdown, on October 24, 2025. Following repair activities, the reactor achieved criticality on October 29, 2025. The reactor synchronized to the grid on October 30, 2025. The reactor achieved approximately 95 percent RTP on November 1, 2025. Power was lowered to approximately 70 percent RTP for a planned rod pattern adjustment and then restored to 95 percent RTP on the same day. Power was raised to approximately 100 percent RTP on November 2, 2025.

On November 14, 2025, Unit 1 had a complete loss of offsite power to vital busses due to the emergency reserve auxiliary transformer (ERAT) tripping during a planned maintenance outage window on the B reserve auxiliary transformer (RAT). This resulted in the sites required declaration of a Notice of Unusual Event (emergency action level MU.1). All three emergency diesel generators auto-started and reenergized the vital busses with no challenges. The site completed repairs and restoration on November 16, 2025, and exited the Unusual Event.

The unit was restored to a normal electrical lineup that same evening.

On November 19, 2025, Unit 1 power was reduced to approximately 75 percent RTP for a planned rod pattern adjustment. Power was restored to approximately 100 percent RTP on November 20, 2025, following successful completion of the rod pattern adjustment.

On December 7, 2025, Unit 1 power was reduced to approximately 70 percent RTP, for a planned rod pattern adjustment. Power was restored to approximately 100 percent RTP on December 8, 2025, following successful completion of the rod pattern adjustment.

The reactor remained at or near approximately 100 percent RTP until the end 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

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

(1) The inspectors evaluated readiness for seasonal extreme winter weather conditions prior to the onset of seasonal cold temperatures for the following systems:

diesel generators, emergency reserve auxiliary transformer (ERAT), reserve auxiliary transformer (RAT), and shutdown service water (SX) systems on December 5th, 2025

71111.04 - Equipment Alignment

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the reactor core isolation cooling (RCIC) system ending on October 29th, 2025.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 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)707 Auxiliary: RCIC pump room on December 1, 2025 (2)825 Control: control room HVAC on December 10, 2025 (3)777 Turbine: general access and mezzanine on December 22, 2025

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam and annual written exam administered between October 22, 2025, and December 5, 2025.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

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

(1) The inspectors observed and evaluated License Operator Requalification Examinations on October 28, 2025.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the system structures, systems, and components (SSCs) remain capable of performing their intended function:

(1)feedwater system with focus on valve maintenance practices completed on November 13, 2025 (2)fire protection systems completed on December 15, 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) The inspectors evaluated the thoroughness of work completion, work management, and risk associated to the containment fire protection header containment isolation valves (1FP050 and 1FP092) leakage repair and testing under Work Order (WO) 05725664 ending on October 27, 2025.
(2) The inspectors evaluated the thoroughness of work completion, work management, and risk associated with the reactor water cleanup (RT) drain line containment isolation valve to radwaste (1WX020) secondary containment repair under WO 05615967 ending on October 27, 2025.
(3) The inspectors evaluated the thoroughness of work completion, work management, and risk associated with the RPS level 8 scram and turbine driven reactor feed pump servo motor replacement under WO 05732014.
(4) The inspectors evaluated the thoroughness of work completion, work management, and risk associated with the #3 turbine control valve hydraulic oil rupture and manual scram under WO 05739914.

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (2 Samples)

(1) The inspectors evaluated refueling outage 1CR22 activities beginning on September 8, 2025, and ending on October 4, 2025.
(2) The inspectors evaluated forced outage 1CF67 beginning on October 22, 2025, and ending on October 29, 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) (1 Sample)

(1)reserve auxiliary transformer risk informed completion time system outage window and system restoration from November 10, 2025, to November 16, 2025

Surveillance Testing (IP Section 03.01) (2 Samples)

(1)division I diesel generator integrated testing under WO 05449881

(2) scram discharge volume vent valve stroke and flow scan on October 1, 2025

Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)

(1)main steam line containment isolation local leak rate testing completed on October 27, 2025, under WO 5161467

71114.04 - Emergency Action Level and Emergency Plan Changes

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

(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes.
  • EP-AA-1003 Addendum 3, Constellation Emergency Action Levels for Clinton Station, Revision 9 This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation

Additional Drill and/or Training Evolution (1 Sample)

The inspectors evaluated:

(1) frazil ICE scenario with DEP opportunity

OTHER ACTIVITIES - BASELINE

71152A - Annual Follow-up Problem Identification and Resolution

Annual Follow-up of Selected Issues (Section 03.03) (2 Samples)

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

(1)

  • RAT B mechanically switched capacitor EC, refueling outage MSC trips during condensate pump starts and load tap changer excessive tapping (2)

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 potential trends in configuration control events 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) Complete loss of offsite power and ERAT during RAT B System Outage Window from November 14, 2025, to November 16, 2025.

Personnel Performance (IP Section 03.03) (2 Samples)

(1) The inspectors evaluated the automatic reactor scram on high reactor water level due to turbine driven reactor feed pump overfeeding and licensees response on October 6, 2025.
(2) The inspectors evaluated the manual scram due to turbine controls EHC oil leak and licensees response on October 22, 2025.

INSPECTION RESULTS

Failure to follow Preventive Maintenance Revision Process Leads to Servovalve Failure and Automatic Scram on High Water Level Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000461/2025004-01 Open/Closed

[H.14] -

Conservative Bias 71111.13 A Green finding of site procedure WC-AA-120, Preventive Maintenance (PM) Database Revision Requirements, and AD-AA-3000, Nuclear Risk Management, was self-revealed when the plant scrammed on high reactor water level. Equipment failure analysis revealed the failure mechanism to be metallic particulate silt accumulation in the EHC servovalve causing the valve to become stuck in the open position leading to the overfeeding event.

Specifically, the servovalve failed due to the sites decision to extend the servovalve replacement frequency from every 3 refueling outages (O3) to every 4 refueling outages (O4),in 2024, without a technically robust risk assessment and screening per the sites preventive maintenance change processes.

Description:

On October 6, 2025, at 0321 Clinton Power Station, Unit 1, automatically scrammed on high reactor water level while placing the turbine driven reactor feed pump (TDRFP) A in service as a part of starting up the reactor after the most recent refueling outage, C1R22.

The reactor scram was uncomplicated and the operators in the control room performed their post-scram actions with no challenges.

The sites failure analysis concluded that the failure mechanism was metallic particulate/silt accumulation in the tight/narrow passages between the servo valve control swing plate and the valve body. This metallic silt accumulation led to increased frictional forces preventing the swing plate from restoring to the neutral/center position leading to hydraulic pressure shunting the TDRFP hydraulic operating cylinder to the full open position and leading to the overfeeding event. Furthermore, the failure analysis concluded that this failure mechanism aligned with an industry-known failure mode similar to spool-valve silting, in which small particles accumulate within tight hydraulic tolerances and restrict motion.

Additionally, when the servo valve that failed via the silt locking mechanism was calibrated in 2019 as a part of the post-maintenance testing of the servo position controller (SPC),the SPC was left with controller gain values that did not completely eliminate excess oscillations from the control scheme. These additional oscillations could have contributed to excessive wear of the servo valve due to increased motion and abrasion between the valve body and the swing plate leading to the silt lock mechanism that resulted in the high water level scram.

On July 9, 2024, the site approved preventive maintenance modification request (PMMR),

Preventive Maintenance Change (PMC)-24-149999, to permanently change the frequency of the TDRFP servovalve replacement from every 3 refueling outages (6 year frequency) to every 4 refueling outages (8 year frequency) contrary to original equipment manufacturer (OEM) guidance and Exelon EHC High Impact Team (HIT) guidance. This moved the planned replacement from the most recent refueling outage, C1R22 to C1R23. If replaced in C1R22, the servovalve would have reasonably not failed due to silt lock and would have prevented the high level scram from occurring. The basis for the decision to move out the servo valve replacement was based on a technical review, and risk assessment performed as part of the PMMR process.

The technical review required per station procedure WC-AA-120, Preventive Maintenance Database Revision Requirements, Section 6.2.4.c, used the fact that the as-found condition of the servovalves was always satisfactory over the last 20 years as basis to extend the PM frequency. However, the as-found condition review only included visual cleanliness inspections of the servovalve, and did not include, nor require, a detailed inspection of the hydraulic or electrical components of the servovalve. Contrary to, PMMR E-Strategy Tool, WC-AA-120-F-02, Step 46, which states, in part, ensure planned PM Modification is technically sound, utilizing the as-found visual cleanliness review as a basis for extending frequency was not technically sound because visual cleanliness is not sufficient to be a predicative/leading metric/indicator for the applicable potential failure mechanismsspecifically, the silting mechanism that led to the high water level scram.

Additionally, the site performed a risk assessment per, AD-AA-3000, Nuclear Risk Management Process, as a part of PMC-24-149999, which was prompted by WC-AA-120, Section 6.4.4, which states, in part, Risk assessments may be requested for potential high consequence issues per AD-AA-3000. The risk assessment from PMC-24-149999, completed in July 2024, concluded that the risk from the servovalve was LOW due to the likelihood of an event being low per AD-AA-3000. However, the safety culture assessment, performed as a part of the causal evaluation in response to the high water level scram, concluded the servo PM was changed from O3 to O4 without robust risk assessment. The basis for this conclusion was the fact that AD-AA-3000 requires both likelihood and consequences to be considered in the risk assessment via a likelihood-consequence significance matrix.

The consequence analysis was accurate in determining a potential significance 2 event (i.e., scram/transient), but the likelihood analysis resulted in a LOW result without consideration of potential unknown factors. The risk assessment and ultimate likelihood conclusion lacked robustness because only one electrical failure mechanism was considered in PMC-24-149999 when multiple failure modes were possible, and plausible, both mechanically and electrically. The lack of control with potential failure mechanisms suggests this issue was more complex. Additionally, the unknown factors in relation to the potential failure modes as discussed in AD-AA-3000, Attachment 1, Risk Assessment and Ranking Process, states in part, The more known about conditions that influence the risk item and resulting consequences, the higher the certainty or predictability of that probability and the lower the likelihood would have resulted in a higher likelihood result than LOW. Failure mechanisms, like the silting mechanism that led to the scram, were not considered, and even if considered, would have a lack of predictability due to the nature of the failure mechanism.

These additional possible failure mechanisms with lack of predictability would have driven the risk matrix likelihood result higher than LOW leading to a different conclusion from the risk assessment in PMC 24-149999 and could have reasonably prevented the servo valve replacement frequency change from O3 to O4.

Ultimately, the site failed to follow the requirements of WC-AA-120 by performing a cursory risk assessment in support of the PMMR, and a lack of robust technical review with respect to technical basis and work history. This resulted in the PM frequency being extended from O3 to O4, which ultimately led to the scram on high water level event on October 6, 2025.

Corrective Actions:

In response to the high water level scram, the site replaced the servo valve on both the A and B TDRFPs. Additionally, the site completed a root cause evaluation to gain further insights and mitigate recurrence.

Corrective Action References: AR 04903283

Performance Assessment:

Performance Deficiency:

The licensees failure to follow WC-AA-120, Preventive Maintenance Database Revision Requirements, with respect to performance of an adequate risk assessment ranking in accordance with AD-AA-3000 Attachment 1, Risk Assessment and Ranking Process, and robust technical review in accordance with WC-AA-120-F-02, step 45 and 46, PMMR E-Strategy PMMR Tool, was a performance deficiency.

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 performance deficiency resulted in the failure of the A TDRFP control system to adequately perform its function resulting in overfeeding the reactor vessel and an automatic scram on high water level. Examples 4.b and 5.b in IMC 0612 Appendix E Examples of Minor Issues supports the more-than-minor determination.

Significance:

The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.

Specifically, all the questions in IMC 0609 Appendix A, The Significance Determination Process (SDP) For Findings At-Power, Exhibit 1, Initiating Events Screening Questions were answered No.

Cross-Cutting Aspect:

H.14 - Conservative Bias: Individuals use decision-making practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, the driver behind the failure to follow WC-AA-120 with respect to changing PM frequency, technical rigor, and risk assessment, points toward decision-making that prioritized protection of outage schedule and scope over ensuring plant equipment reliability.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

Failure to Follow Parts Quality Process Leads to Turbine Electro-Hydraulic Control Oil Leak and Manual Scram Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000461/2025004-02 Open/Closed None (NPP)71111.13 A Green finding of SM-AC-3019, Parts Quality Process, was self-revealed when the operators inserted a manual scram due to low Electro-Hydraulic Control (EHC) oil level. Specifically, the licensee failed to properly screen the turbine control valve actuator into the Parts Quality Initiative (PQI) program, and therefore inadequately tested the actuator prior to accepting it into inventory. This resulted in the #3 Turbine Control Valve (TCV3) actuator being installed in 2018 and subsequently failing in the fall of 2025, causing an un-isolable EHC rupture in the heater bay resulting in a low EHC oil level (-24.5"), which led to a procedurally-required manual scram.

Description:

On October 22, 2025, Clinton Power Station manually scrammed from low EHC oil level while operating at approximately 86 percent rated thermal power. The reactor scram was uncomplicated and the operators in the control room performed their post-scram actions with no challenges.

The site concluded that the failure was the #3 Turbine Control Valve (TCV3) actuator, including a dislodged backing plate, four of the eight tie rods sheared, and two of the remaining tie rods were under-torqued, resulting in an un-isolable EHC rupture. The sites extent of condition included resonance testing on tie rods and identifying multiple under-torqued (<500 ft-lbs) tie rods on both currently installed and spare actuators. The failure analysis identified the under-torquing of tie rods increased cyclic stress on the actuator to the point of shearing. The sheared tie rods allowed leakage of pressurized EHC fluid to spray out, leading to failure of the TCV3 actuator and coating the heater bay and below levels of the Turbine Building in EHC fluid.

On March 12, 2009, the site incorrectly screened the turbine control valve actuator in accordance with procedure SM-AC-3019, Parts Quality Process, documenting on their inventory control program, in part...used on a Risk Significant System (TG [turbine generator]). However, the actuator itself does not require any additional PQI testing.

The Parts Quality Process Section 7.1.1 identifies the Catalog Identification (CatID) should be verified for PQI applicability when in receipt of a new potential PQI item. Parts Quality Process Attachment 2, PQI Component Inclusion List provides a recommended list of PQI components including Valve Positioners. Clintons evaluation of the manual scram event noted the breakdown was a Parts/Vendor Quality Issue. The inspectors determined the licensee did not follow their procedure Parts Quality Process Section 7.1.1 step 2 to properly screen the actuator (valve positioner) as PQI which directs the site to assess in part if in-house testing, [...], or enhanced receipt inspection are necessary to verify quality of the part. Specifically, if screened correctly the site would have had the opportunity to perform additional non-invasive testing, like resonance frequency testing of the bolted tie rods or torque checks, as part of the PQI process. Not performing the testing produced a vulnerability which caused a mechanical failure resulting in a manual reactor scram.

Corrective Actions:

In response to the manual scram, the site resonance frequency tested the three remaining Turbine Control Valves, all four Main Turbine Stop Valves and Intermediate Valves, and all six Main Turbine Bypass Valves to assess tie rod torquing. Additionally, the site will implement periodic resonance frequency testing on actuators and require a Certificate of Conformance from the vendor for torque specifications on tie rods. The licensee completed a Corrective Action Program Evaluation (CAPE) following the event. Constellation corporate engineering is also determining a long-term strategy for tie rods evaluations.

Corrective Action References: AR 04908061

Performance Assessment:

Performance Deficiency:

In March 2009, the licensees failure to follow SM-AC-3019, Parts Quality Process, procedure to screen and test the turbine control valve actuators as Parts Quality Initiative components correctly was a performance deficiency.

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 performance deficiency resulted in the failure of the

  1. 3 Turbine Control Valve actuator which prompted the Electro-Hydraulic Control low oil level manual scram. Examples 4.b and 5.b in IMC 0612 Appendix E Examples of Minor Issues supports the more-than-minor determination.
Significance:

The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.

Specifically, all the questions in IMC 0609 Appendix A, The Significance Determination Process (SDP) For Findings At-Power, Exhibit 1, Initiating Events Screening Questions were answered No.

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, the performance deficiency occurred on March 12, 2009, and does not reflect present licensee performance.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

EXIT MEETINGS AND DEBRIEFS

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

  • On January 23, 2026, the inspectors presented the integrated inspection results to F. Payne, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

AR 04904441

Winter Readiness-Heater 1SH05AC Not Working

10/10/2025

AR 04912239

Winter Readiness: RWT Chemical Feed Tray

11/05/2025

Corrective Action

Documents

AR 04913227

Degraded Winter Readiness of MPW Trailer

11/09/2025

71111.01

Miscellaneous

Clean Power

Station Winter

Readiness

Certification

Clean Power Station Winter Readiness Certification

10/31/2025

Corrective Action

Documents

AR 04902994

1E51C003 Further Degradation into Action Range

10/04/2025

71111.04

Procedures

3310.01

Reactor Core Isolation Cooling

034

1893.04M103

707' Auxiliary: RCIC Pump Room Prefire Plan

5a

1893.04M370

25' Control Building Control Room HVAC

Fire Area / Fire Zone: CB-1i

7b

71111.05

Fire Plans

1893.04M730

777', 781' & 783' Turbine Building General Access &

Mezzanine

Fire Area / Fire Zone: T-1(h, k)

5d

71111.11A

Miscellaneous

TQ-AA-150-F25

LORT Annual Exam Status Report

2/05/2025

71111.11Q Miscellaneous

LOR Exam

Licensed Operator Requalification Exams

AR 04903283

RFP A Over Feed Level 8 Scram

10/06/2025

AR 04903442

RFP A Ovation Points Not Indicating Correctly

10/06/2025

AR 04903499

RFP B Ovation Points Not Indicating Correctly

10/07/2025

Corrective Action

Documents

AR 0911040

Multiple Issues Placing RFP B In Service

10/31/2025

ISSUE-2021-7256

1FP50J Troubleshoot 11-20 Turbine Generator Bearing and

Underskirt

05/21/2021

ISSUE-2023-

13094

1FP092 CNMT FP Outboard Isolation LLRT Results

07/21/2023

71111.12

Miscellaneous

ISSUE-2023-

1FP050 Has A Packing Leak

09/24/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

18097

ISSUE-2024-0814

FP B Low Room Temperature

01/14/2024

ISSUE-2024-

18575

Fire Pump B 0FP01PB Degrading Oil Pressure Trend

11/26/2024

9071.03

Fire Protection Water System Valve Cycling-Testable Valves

9071.03C001

Fire Protection Water System Valve Cycling

Checklist-Testable Valves

CL-PRA-021.02

Clinton Power Station Fire PRA Equipment Selection

Notebook

Procedures

CPS 3213.02

Plant Fire Detection System

WO 04954031

Install New Model LVDT on RFP A per EC 629096

11/02/2022

WO 04968764

Issues Identified During RFP A SPC 2 Calibration

03/29/2022

Work Orders

WO 04996991

Replace Servo Valve on FW Reg Valve (1FW01KA)

07/30/2020

04897507

1FP050 and 1FP092 LLRT Results per 9861.02D045

09/12/2025

04897584

1WX020 As-Found Leakage Outside Admin Limit

09/13/2025

04899315

9861.02D045, FP to CNMT, 1FP092 Above Evaluation Limit

09/20/2025

04908072

1TGCV3 Actuator Cylinder Blown Seal and Indicator Damage

10/22/2025

04910320

Residual EHC Fluid Identified at Turbine Control Valve 1

10/30/2025

04910325

Leak Identified at Turbine Control Valve 3

10/30/2025

04954031

Install New Model LVDT on TDRFP-A Per EC 629096

09/21/2019

Corrective Action

Documents

AR 04286814

Observations of TDRFP B Tuning/Calibration on SPBSPC2

10/10/2019

Drawings

M05-1089

Radwaste Sludge Process (WX)

Miscellaneous

PMC-24-149999

Revise PMID 00158129-10 Replace Servo Valve (SVA2) on

1FW01KB from an O3 to O4 Frequency

07/16/2024

3103.01

Feedwater

3103.02

Digital Feedwater (Ovation) System Operations

ER-AA-200

Preventive Maintenance Program

71111.13

Procedures

ER-AA-200-1002

Preventive Maintenance Oversight Committee

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

ER-AA-200-1003

Maintenance Strategy Analysis

ER-AA-200-1004

PCM Templates

Issue Identification

and Screening

Process

PI-AA-120

Nuclear Risk

Management

Process

AD-AA-3000

SM-AA-3019

Parts Quality Initiative (PQI)

WC-AA-120

Preventive Maintenance Database Revision Requirements

Self-Assessments 04908061-26

CAPE - Manual Scram Due to Main EHC Leak

10/22/2025

01149908

Replace Servo Valve (SVA2) on 1FW01KA

01/12/2010

01685570

Replace Servo Valve (SVA2) on 1FW01KA

05/04/2015

04667653

1TGCV3 Replace

01/19/2018

04968764

Issues Identified During TDRFP-A SPC 2 Calibration

10/13/2019

04996991

Replace Servo Valve (SVA2) on 1FW01KA

07/30/2020

226078

1FW01KA Replace Filter Element in Hydraulic System

09/18/2023

Work Orders

05615967

1WX020 Failed To Open - BWRT Overflowing to RF

04900136

MSIV Stem Assemblies Need Rebuilt Prior to C1R23

09/23/2025

04900157

Secondary Containment Bypass Leakage Above TS Limit

09/24/2025

04900293

C1R22 LL: Suppression Pool Level Suspect Readings

09/24/2025

04900403

C1R22 1E51F076 Overthrust

09/24/2025

Corrective Action

Documents

04900454

Leak in Drywell from 1B21F051D

09/25/2025

Miscellaneous

C1R22 SSMP

C1R22 Shutdown Safety Management Program

CPS 3005.01F001

Unit Power Changes Power Increase Flowchart

CPS 3005.01F002

Unit Power Changes Power Decrease Flowchart

CPS 3005.01F003

Secondary Thermal Power Validation

0b

71111.20

Procedures

CPS 3006.01

Unit Shutdown

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CPS 3006.01F001

Unit Shutdown Flowchart

0a

04009845

PSU: C1R17 MSIV LLRT Tech Spec 3.6.1.3 Limit Exceeded

05/12/2017

04896157

MSIV LLRT 9861.04 Acceptance Criteria not Met

09/09/2025

04897000

MSIV LLRT Leakage Determination

09/12/2025

04900160

9861.04 MSIV LLRT Final Results

09/24/2025

AR 04902183

1C11F010 Failed to Indicate Full Closed

10/01/2025

Corrective Action

Documents

AR 4900853

1C11F010 Internal Mechanical Binding

09/26/2025

Drawings

E02-1AP03

Electrical Loading Diagram Clinton Power Station Unit

AD

OP-AA-108-118

RAT B RICT Calculation

11/09/2025

Miscellaneous

Risk Assessment:

CPS-1-2025-0329

Simple Issue Risk Assessment: C1R22 MSIV Decision and

Impact

9012.01 Rev 032

Scram Discharge Volume Vent and Drain Valve

Operability Test

04/15/2025

9012.01 Rev 032

Scram Discharge Volume Vent and Drain Valve

Operability Test

07/18/2025

Procedures

9080.21

Diesel Generator 1A - ECCS Integrated

04874764, Blank

RAT B Inspections Work Instructions

71111.24

Work Orders

05449881

9080.21R20 OP *DG 1A Integrated Test

09/25/2025

3C10-1082-002

EOP/SAG Guidelines for CPS

2b

EP-AA-120-1001

Evaluation No.: 24-

§50.54(q) Program Evaluation Assessment Review for

Standardized Radiological Emergency Plan Revision 34

2/28/2025

Calculations

EP-AA-120-1001

Evaluation No.: 25-

§50.54(q) Program Evaluation Assessment Review for Clinton

Minimum Steam Cooling RPV Level EAL

09/18/2025

Miscellaneous

EPID L-2018-LLA-

0045

Issuance of Amendments to Revise the Emergency Response

Organization Staffing Requirements

03/21/2019

71114.04

Procedures

EP-AA-1000

Exelon Nuclear Standardized Radiological Emergency Plan

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

EP-AA-1000

Standardized Radiological Emergency Plan

EP-AA-1003

Addendum 3

Constellation Emergency Action Levels for Clinton Station

EPA-400/R-17/001 PAG Manual: Protective Action Guides and Planning

Guidance for Radiological Incidents

01/2017

71114.06

Procedures

EP-AA-1003

Addendum 3

Emergency Action Levels for Clinton Station

AR 04888282

Breaker Tripped and Wont Reset for RAT MSC Yard Lighting

08/04/2025

AR 04890824

Received 5008-5L due to ERAT LTC Tapping

08/15/2025

AR 04899430

RCIC Level Switch Wiring

09/21/2025

AR 04899521

RCIC Turb Trip As-Found Wiring Incorrect

09/21/2025

AR 04900403

C1R22 1E51F076 Overthrust

09/25/2025

AR 04901289

Unexpected RAT MSC Trip

09/28/2025

AR 04902350

RAT MSC Tripped Again During CB Pump Start

10/02/2025

AR 04906348

RAT MSC Breaker 52-2 SF6 Pressure Was Below the

Fill Spec

10/16/2025

AR 04908314

RAT B LTC Excessive Tapping

10/23/2025

Corrective Action

Documents

EC 627131

RAT B SVC Long Term Abandonment

03/12/2024

71152A

Work Orders

WO 01496512

RCIC Steam Supply LLRT Higher than Admin Limit

09/28/2025

AR 04884336

FP Program Health Yellow Cornerstone/White Overall 2025P1 07/22/2025

Corrective Action

Documents

AR 04884594

Results of Clinton 2025 Biennial Fleet Safety Culture SA

07/23/2025

07/25/2025

1H2025 Station Trending HURB Documentation Review

07/25/2025

AR 04881155

CPS Is One Component Failure Away from Required

Shutdown

07/13/2025

AR 04882715

MOVs Improperly Descoped from C1R22

07/16/2025

AR 04883589

Multiple FP Device Troubles Received after 22-01

07/20/2025

71152S

Fire Plans

AR 04899405

C1R22 FAC Component 1B21-F010B Low Wall Thickness

09/20/2025