ML25195A306

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Notice of Violation, NRC Inspection Report No. 05000254/2024403, NRC Investigation Report 3-2023-013 and Exercise of Enforcement Discretion
ML25195A306
Person / Time
Site: Quad Cities 
Issue date: 07/30/2025
From: Jack Giessner
NRC/RGN-III
To: Case J
- No Known Affiliation
References
EAI-RIII-2025-0083, OI-RIII-2023-0013, IR 2024403
Download: ML25195A306 (1)


See also: IR 05000254/2024403

Text

EAI-RIII-2025-0083

Jerome Case

[HOME ADDRESS DELETED

UNDER 10 CFR 2.390(a)]

SUBJECT: NOTICE OF VIOLATION, NRC INSPECTION REPORT NO. 05000254/2024403,

NRC INVESTIGATION REPORT 3-2023-013 AND EXERCISE OF ENFORCEMENT

DISCRETION

Dear Jerome Case:

This letter refers to an inspection that was performed by the U.S. Nuclear Regulatory

Commission (NRC) Region III office at the Quad Cities Nuclear Power Station, which

concluded on April 16, 2025. The purpose of the inspection was to review activities surrounding

a Unit 1 reactor pressure vessel (RPV) drain down event due to the mispositioning of

approximately 177 safety-related hydraulic control units (HCU) accumulator drain valves that

occurred on March 28, 2023. This letter also refers to an investigation that was conducted by

the NRCs Office of Investigations (OI). The purpose of the investigation was to determine

whether personnel at the Quad Cities Nuclear Station (Quad Cities) who had knowledge of a

human performance error that occurred on March 28, 2023, deliberately took action to cover up

the event. The investigation was completed on September 11, 2024. A factual summary of

Investigation 3-2023-013, which substantiated willful behaviors by you, is provided as Enclosure

1. NRC Inspection Report No. 05000254/2024403 can be found in the NRCs Agencywide

Documents Access and Management System (ADAMS) at ML25114A211.

On June 10, 2025, a predecisional enforcement conference was conducted in the Region III

Office with you to discuss the apparent violations, their significance, their root causes, and your

corrective actions.

Based on the information developed during the investigation and inspection and the information

that you provided during the conference, the NRC has determined that a deliberate violation

of NRC requirements occurred. The violation is cited in the enclosed Notice of Violation (NOV)

(Enclosure 2). On March 28, 2023, as a Senior Reactor Operator (SRO) overseeing the Unit 1

outage work activities, you became aware of an RPV drain down event due to the

mispositioning of the safety-related HCU accumulator drain valves. Despite this knowledge, for

10 days, you inaccurately attributed the event to broken hoses and submitted an inaccurate

Corrective Action Program document based on this false claim on April 6, 2023. You did not

rectify this inaccurate information until April 7, 2023. This information was material to the NRC,

as it left inspectors unaware of the drain down event and the performance issues causing it

within a timeframe necessary to assess appropriate event response and follow-up inspection

activities. Your deliberate actions placed Quad Cities in violation of 10 CFR 50.9 and placed you

in violation of 10 CFR 50.5, Deliberate Misconduct.

July 30, 2025

J. Case

- 2 -

This violation is normally categorized in accordance with the NRC Enforcement Policy at

Severity Level II (see example 6.9.b.1); however, after consultation with the Director, Office of

Enforcement, I have been authorized to exercise discretion to reduce the significance of this

violation to Severity Level III, consistent with Section 3.5, Violations Involving Special

Circumstances, of the Enforcement Policy. Discretion is being exercised due to relevant

circumstances which include: (1) you withdrawing the inaccurate work group evaluation (WGE)

from the corrective action program within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the initial submittal; (2) you then revised

the WGE and informed your supervisor of the actual cause of the event; (3) your NRC license

was terminated effective June 7, 2023; and, (4) you admitted wrongdoing and accepted

responsibility while attending the conference.

The NRC has concluded that information regarding: (1) the cause of the violation, and (2) the

corrective actions to address the violation were adequately addressed by actions taken by you

and Quad Cities. Therefore, you are not required to respond to this letter. However, should you

choose to respond, your response should be sent to the U.S. Nuclear Regulatory Commission,

ATTN: Director, Division of Operating Reactor Safety, 2056 Westings Avenue, Suite 400,

Naperville IL, 60563-2657, include EAI number, EAI-RIII-2025-0083, and marked Open by

Addressee Only, within 30 days of the date of this letter. You may contact Diana Betancourt-

Roldan, Enforcement/Investigations Officer, if you have any questions at 630-810-4373.

In accordance with 10 CFR 2.390 of the NRC's Rules of Practice, a copy of this letter, its

enclosure(s), and your response, if you choose to provide one, will be made available

electronically for public inspection in the NRC Public Document Room or from ADAMS,

accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent

possible, your response should not include any personal privacy, proprietary, or safeguards

information so that it can be made available to the Public without redaction. The NRC also

includes significant enforcement actions on its Web site at

(http://www.nrc.gov/reading-rm/doc-collections/enforcement/actions/).

In addition, this letter will be maintained by the Office of Enforcement in an NRC Privacy Act

system of records, NRC-3, Enforcement Actions Against Individuals. This system, which is not

publicly accessible, includes all records pertaining to individuals who are being or have been

considered for enforcement action, whether such action was taken or not. The NRC-3 system

notice, which provides detailed information about this system of records, can be accessed from

the NRC Web site at http://www.nrc.gov/reading-rm/foia/privacy-systems.html. Finally, a copy of

this letter will be placed in your 10 CFR Part 55 docket file.

Please feel free to contact Nestor J. Feliz Adorno of my staff at 630-829-9739 if you have any

questions.

Sincerely,

John B. Giessner

Regional Administrator

Enclosures: 1. Factual Summary

2. Notice of Violation

Signed by Giessner, Jack

on 07/30/25

J. Case

- 3 -

Letter to J. Case from J. Giessner dated July 30, 2025.

SUBJECT: NOTICE OF VIOLATION, NRC INSPECTION REPORT NO. 05000254/2024403,

NRC INVESTIGATION REPORT 3-2023-013 AND EXERCISE OF ENFORCEMENT

DISCRETION

DISTRIBUTION:

Juan Peralta

Dan Bradley

Thomas Ashley

Jeremy Francis

Phillip McKenna

Jack Giessner

Mohammed Shuaibi

Diana Betancourt-Roldan

Jason Kozal

Billy Dickson

Nestor Feliz Adorno

Paul Zurawski

Robert Ruiz

Chris Hunt

Shannon Rogers

Sara Kirkwood

Shelbie Lewman

Eric Brothman

Geoffrey Edwards

Jason Draper

Sarah Bakhsh

Michelle Garza

RidsOemailCenter Resource

ADAMS Accession Number: ML25195A306

Publicly Available

Non-Publicly Available

Sensitive

Non-Sensitive

OFFICE

RIII-EICS

RIII-DORS

RIII-DORS

OE

NAME

GEdwards:bw

NFeliz Adorno

JKozal

DBraqdley for

JPeralta

DATE

7/15/2025

7/15/2025

7/15/2025

7/22/2025

OFFICE

OGC for NLO

RIII-EICS

RIII-ORA

NAME

SRogers for

SKirkwood

GEdwards for

DBetancourt-

Roldan

JGiessner

DATE

7/24/2025

7/28/2025

7/30/2025

OFFICIAL RECORD COPY

Enclosure 1

Factual Summary of NRC Office of Investigations Cases No. 3-2023-013

On August 18, 2023, the U.S. Nuclear Regulatory Commission (NRC), Office of Investigations

(OI), Region III, initiated investigation No. 3-2023-0013 to determine whether personnel at the

Quad Cities Nuclear Station (Quad Cities or licensee) who had knowledge of a human

performance error that occurred on March 28, 2023, deliberately took action to cover up the

event. The investigation was completed on September 11, 2024.

Title 10 CFR § 50.9(a), Completeness and Accuracy of Information, requires, in part, that

information required by statute or by the Commission's regulations, orders, or license conditions

to be maintained by the applicant or the licensee shall be complete and accurate in all material

respects. The investigation showed that on March 28, 2023, Jerome Case, at the time a Senior

Reactor Operator (SRO) overseeing the Unit 1 outage work activities, became aware of a

reactor pressure vessel (RPV) drain down event due to the mispositioning of 177 safety-related

hydraulic control units (HCU) accumulator drain valves. Despite this knowledge, for 10 days, he

inaccurately attributed the event to broken hoses and submitted an inaccurate Corrective Action

Program document (Work Group Evaluation (WGE)) that contained inaccurate information. He

did not rectify this inaccurate information until April 7, 2023. Through his sworn testimony and

admission, he was aware of the facts of what happened on March 28, 2023, and admitted to

investigators that he submitted an incomplete and inaccurate WGE to the licensee. He also

stated in his testimony that he knew the WGE he submitted was false and that he was aware it

was false at the time he sent it. He stated that fear of a particular senior managers anger kept

him from providing complete and accurate information.

Enclosure 2

NOTICE OF VIOLATION

Jerome Case

[HOME ADDRESS DELETED

UNDER 10 CFR 2.390]

EAI-RIII-2025-0083

During the performance of the Inspection Procedure 71152, Problem Identification and

Resolution, at the Quad Cities Nuclear Generating Station (Quad Cities), on April 16, 2025, and

NRC Investigation Report 3-2023-013 which was completed on September 11, 2024, the NRC

identified a violation of U.S. Nuclear Regulatory Commission (NRC) requirements concerning a

licensed operator. In accordance with the NRC Enforcement Policy, the violation is listed below:

Senior Reactor Operator License Number SOP-500475-1 issued to Jerome Case on

May 17, 2022, states, in part, While performing licensed duties you shall observe the

operating procedures and other conditions specified in the facility licensee authorizing

operation of the facility.

Title 10 CFR 50.5(a)(2) requires, in part, that any employee of a licensee may not

deliberately submit to a licensee information that the person submitting the information

knows to be incomplete or inaccurate in some respect material to the NRC.

Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings,

states Activities affecting quality to be prescribed by documented instructions,

procedures, or drawings, of a type appropriate to the circumstances and shall be

accomplished in accordance with these instructions, procedures, or drawings.

The licensee established procedure OP-AA-106-101-1001, Event Response

Guidelines, Revision 32, provides instructions for responding to significant plant issues

and events. Step 4.4.1, states, Ensure an IR is written for the event. Step 4.4.2, states,

Review the event to determine if the event is significant and if a prompt investigation is

necessary. Significant equipment failures and human performance events require equal

consideration for prompt investigations. Step 4.4.2 clarifies that examples of a

significant event include a level 1, 2, or 3 configuration control event.

Contrary to the above, from March 28, 2023, through April 7, 2023, Jerome Case, at the

time a licensed Senior Reactor Operator (SRO) at Quad Cities, deliberately submitted to

the licensee information that he knew at the time to be incomplete and/or inaccurate and

material to the NRC. Specifically, on March 28, 2023, as an SRO overseeing Unit 1s

outage work activities, you became aware of an RPV drain down event due to the

mispositioning of the safety-related HCU accumulator drain valves. Despite this

knowledge, you deliberately failed to accurately evaluate or report the event for a period

of 10 days. Instead, you knowingly misattributed the water spill to broken hoses and

willfully submitted an inaccurate WGE on April 6, 2023, based on that false explanation.

You did not correct the record until April 7, 2023.

This information was material to the NRC, as it left inspectors unaware of the drain down

event and the performance issues causing it within a timeframe necessary to assess

appropriate event response and follow-up inspection activities.

This is a Severity Level III violation (Enforcement Policy Section 6.9).

2

The NRC has concluded that information regarding: (1) the cause of the violation, and (2) the

corrective actions to address the violation were adequately addressed by actions taken by you

and Quad Cities. However, you are required to submit a written statement or explanation

pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective

actions or your position. In that case, or if you choose to respond, clearly mark your response as

a Reply to a Notice of Violation; EAI-RIII-2025-0083 and send it to the U.S. Nuclear Regulatory

Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the

Regional Administrator, Region III, 2056 Westings Avenue, Suite 400, Naperville, IL, 60563-

2657, and a copy to the NRC Resident Inspector at the Quad Cities Nuclear Power Plant within

30 days of the date of the letter transmitting this Notice of Violation (Notice).

If you contest this enforcement action, you should also provide a copy of your response, with

the basis for your denial, to the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001.

If you choose to respond, your response will be made available electronically for public

inspection in the NRC Public Document Room or from the NRCs document system (ADAMS),

accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. Therefore, to

the extent possible, the response should not include any personal privacy, proprietary, or

safeguards information so that it can be made available to the Public without redaction.

This letter will be maintained by the Office of Enforcement in an NRC Privacy Act system of

records, NRC-3, Enforcement Actions Against Individuals. This system, which is not publicly

accessible, includes all records pertaining to individuals who are being or have been considered

for enforcement action, whether such action was taken or not. The NRC-3 system notice, which

provides detailed information about this system of records, can be accessed from the NRC Web

site at http://www.nrc.gov/reading-rm/foia/privacy-systems.html.

Dated this 30th day of July 2025.