ML25195A314
| ML25195A314 | |
| Person / Time | |
|---|---|
| Issue date: | 07/30/2025 |
| From: | Jack Giessner NRC/RGN-III |
| To: | Meyers J - No Known Affiliation |
| References | |
| EAF-R3-2025-0074, EAI-RIII-2025-0085, IR 2024403 | |
| Download: ML25195A314 (1) | |
See also: IR 05000254/2024403
Text
EAI-RIII-2025-0085
Jeff Meyers
[HOME ADDRESS DELETED
UNDER 10 CFR 2.390(a)]
SUBJECT: NOTICE OF VIOLATION AND NRC INSPECTION REPORT NO.
Dear Jeff Meyers:
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 (Quad Cities),
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 unit (HCU) accumulator drain valves that
occurred on March 28, 2023.
In the letter transmitting the inspection report, we provided you with the opportunity to address
the apparent violation identified in the report by either attending a predecisional enforcement
conference or by providing a written response before we made our final enforcement decision.
On May 22, 2025, you contacted the NRC Region III office to inform the regional staff of your
decision to decline further participation in this case.
Based on the information developed during the inspection, the NRC determined that on
March 28, 2023, as a Reactor Operator (RO) overseeing Units 1 outage work activities, you
directed equipment operators to not complete Attachment B of QCOP-0500-04. Specifically,
your decision resulted in the opening of the HCU accumulator drain valves without the human
performance tools in Attachment B (i.e., concurrent or independent verification), thereby
creating multiple penetration flow paths below top of active fuel susceptible to a common mode
failure. This ultimately led to the loss of 5-6 inches of RPV inventory and required operator
action to stop the drain down. Reactor Operator License Number OP-31534-2 issued to you on
July 7, 2023, 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. Technical Specification 5.4.1, Procedures, requires, in part, that written procedures
shall be established, implemented, and maintained as covered in Regulatory Guide 1.33.
Contrary to the above, on March 28, 2023, you failed to implement written procedures covered
in Regulatory Guide 1.33. Your actions caused Quad Cities to be in violation of Technical
Specification 5.4.1 and you in violation of Technical Specification 5.4.1. Given the significance
of the underlying issue, this violation has been categorized in accordance with the NRC
Enforcement Policy at Severity Level III. The violation is cited in the enclosed Notice of Violation
(Notice). NRC Inspection Report No. 05000254/2024403 can be found in the NRCs
Agencywide Documents Access and Management System (ADAMS) at ML25114A211.
July 30, 2025
J. Meyers
- 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. 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 IA number, EAI-RIII-2025-0085, 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 Agency Rules of Practice and Procedure,
enforcement actions are made available electronically for public inspection in the NRC Public
ADAMS. A copy of this letter and the enclosed NOV with your address removed will be made
available to the public unless you provide a sufficient basis to withdraw this violation. 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. The NRC-3 system notice,
which provides detailed information about this system of records, can be accessed from the
NRC Web site at https://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
Enclosure: Notice of Violation
Signed by Giessner, Jack
on 07/30/25
J. Meyers
- 3 -
Letter to J. Meyers from J. Giessner dated July 30, 2025.
SUBJECT: NOTICE OF VIOLATION AND NRC INSPECTION REPORT NO.
DISTRIBUTION:
Eric Brothman
Jeremy Francis
Nestor Feliz Adorno
Chris Hunt
RidsOemailCenter Resource
ADAMS Accession Number: ML25195A314
Publicly Available
Non-Publicly Available
Sensitive
Non-Sensitive
OFFICE
RIII-EICS
RIII-DORS
RIII-DORS
NAME
GEdwards:bw
NFeliz Adorno
JKozal
DBradley for
JPeralta
DATE
7/15/2025
7/15/2025
7/15/2025
7/22/2025
OFFICE
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
Jeff Meyers
[HOME ADDRESS DELETED
UNDER 10 CFR 2.390]
EAI-RIII-2025-0085
During the performance of the Inspection Procedure 71152, Problem Identification and
Resolution, at the Quad Cities Nuclear Station (Quad Cities), on April 16, 2025, the U.S Nuclear
Regulatory Commission (NRC) identified a violation of NRC requirements concerning a licensed
operator. In accordance with the NRC Enforcement Policy, the violation is listed below:
Reactor Operator License Number OP-31534-2 issued to Jeff Meyers on July 7, 2023,
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.
TS 5.4.1, Procedures, requires, in part, that written procedures shall be established,
implemented, and maintained as covered in Regulatory Guide 1.33, Revision 2,
Appendix A, February 1978. Regulatory Guide 1.33, Section 1, Administrative
Procedures, covers procedures for procedure adherence as well as authorities and
responsibilities for safe operation and shutdown. Section 4, Procedure for Startup,
Operation, and Shutdown of Safety-Related BWR Systems, cover procedures for
energizing, filling, venting, draining, startup, shutdown, and changing modes of operation
for the Control Rod Drive (CRD) system.
The facility established procedure QCOP 0500-04, "Inserting Manual Scrams,"
Revision 14, as a continuous use procedure of the CRD system to provide instructions
for inserting a full manual scram when the reactor is shutdown. Step D.5 states, in part,
that Inserting a scram with the CRD drain valves open will result in a drain path from the
vessel. Step F.2.b(3) requires, in part, closing all 177 safety-related HCU accumulator
drain valves per Attachment B, which requires either a concurrent or independent
verification that each valve is closed.
Contrary to the above, on March 28, 2023, you failed to implement written procedures
covered in Regulatory Guide 1.33, as evidenced by the following examples:
You directed equipment operators to not complete Attachment B of QCOP 0500-
04, which was contrary to step F.2.b(3) of the procedure. Specifically, attachment
B included steps for closing the safety-related HCU accumulator drain valves as
well as human performance tools designed to prevent errors (i.e., either a
concurrent or independent verification of each valve closure). As a result of the
decision not to complete Attachment B, the equipment operators neither
performed nor confirmed the closure of the valves.
You signed off step F.2.b(3) of QCOP 0500-04 as complete and proceeded with
the next steps without ensuring Attachment B was complete and that all
appropriate steps were performed. Specifically, you relied on verbal confirmation
from the equipment operators that their assigned tasks were complete.
Ultimately, this led to inadvertently establishing a drain path from the reactor
vessel resulting in the Unit 1 reactor vessel water level dropping between 5-6
inches.
2
Your decision not to complete the attachment caused the licensee to place Unit 1 in a
condition prohibited by TS 3.5.2, which requires, in part, that RPV drain time to the TAF
be 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> in Modes 4 and 5, with immediate actions required if drain time falls below
8 or 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Since the decision to informally plan the implementation of QCOP-0500-04
resulted in a drain time of 15 minutes, it also led to a red shutdown safety level, which is
not permitted by procedure OU-AA-103, revision 23.
This is a Severity Level III violation (Enforcement Policy Section 6.4).
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-2025-0085, 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.