ML25218A269
| ML25218A269 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 08/07/2025 |
| From: | Nestor Feliz-Adorno NRC/RGN-III/DORS/ERPB |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2025011 | |
| Download: ML25218A269 (1) | |
Text
David Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer (CNO)
Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
CLINTON POWER STATION - LICENSE RENEWAL PRE-APPROVAL INSPECTION IP 71002 REPORT 05000461/2025011
Dear David Rhoades:
On June 27, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Clinton Power Station and discussed the results of this inspection with Norha Plumey, 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. Two 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 III; the Director, Office of Enforcement; and the NRC Resident Inspector at Clinton Power Station.
If you disagree with a cross-cutting aspect assignment 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.
August 7, 2025
D. Rhoades 2
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, Néstor Féliz Adorno, Chief Engineering and Reactor Projects Branch Division of Operating Reactor Safety Docket No. 05000461 License No. NPF-62
Enclosure:
As stated cc w/ encl: Distribution via LISTSERV Signed by Feliz-Adorno, Nestor on 08/07/25
D. Rhoades 3
Letter to David Rhoades from Néstor Féliz Adorno dated August 7, 2025.
SUBJECT:
CLINTON POWER STATION - LICENSE RENEWAL PRE-APPROVAL INSPECTION IP 71002 REPORT 05000461/2025011 DISTRIBUTION:
Tim Steadham RidsNrrDorlLpl3 RidsNrrPMClinton Resource RidsNrrDroIrib Resource Jack Giessner Mohammed Shuaibi Diana Betancourt-Roldan John Pelchat Jared Heck Jennifer Dalzell R3-DORS ADAMS Accession Number: ML25218A269
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available OFFICE RIII RIII NAME KFay for MDomke:anm NFélizAdorno DATE 08/07/2025 08/07/2025 OFFICIAL RECORD COPY
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
05000461 License Number:
NPF-62 Report Number:
05000461/2025011 Enterprise Identifier:
I-2025-011-0028 Licensee:
Constellation Nuclear Facility:
Clinton Power Station Location:
Clinton, IL Inspection Dates:
June 09, 2025, to June 27, 2025 Inspectors:
M. Domke, Senior Reactor Inspector K. Fay, Senior Reactor Inspector J. Park, Reactor Inspector D. Ray, Materials Engineer M. Siddiqui, Reactor Inspector Approved By:
Néstor Féliz Adorno, Chief Engineering and Reactor Projects Branch Division of Operating Reactor Safety
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a License Renewal Pre-Approval Inspection IP 71002 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 Timely Drain Cable Vaults with Submerged Safety-Related Cables Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000461/2025011-01 Open/Closed
[H.8] -
Procedure Adherence 71002 The NRC identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the applicant failed to accomplish activities affecting quality in accordance with documented instructions, procedures or drawings. Specifically, the applicant failed to drain a cable vault within 3 weeks of safety-related (SR) cable submergence as required by their procedures.
Failure to Maintain Safety-Related Cable Vault Water Level Monitoring Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000461/2025011-02 Open/Closed
[H.9] - Training 71002 The NRC identified a Green finding and associated NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the applicant failed to accomplish activities affecting quality in accordance with documented instructions, procedures or drawings. Specifically, the applicant did not perform the actions required by procedure CPS 3221.02, Operating Cable Vault Pumping Stations, Revision 6c, related to the (SR) outdoor cable vault water level monitoring. These included failing to initiate an incident report (IR) for water level monitoring low battery alarms, failing to open the vaults to determine actual water levels when the ultrasonic level monitoring system was inoperable or the battery was dead, and failing to plug in the level controller during restoration from a secured vault condition.
Additional Tracking Items None.
3 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 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.
OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 71002 - License Renewal Inspection The inspectors reviewed the applicants scoping and screening of non-safety-related structures, systems, and components (SSCs), as required by 10 CFR 54.4(a)(2). The inspectors assessed whether the proposed aging management programs (AMPs) would effectively manage identified aging effects.
To evaluate scoping, inspectors selected several license renewal SSCs observed during plant walkdowns to verify that the applicants methodology adequately addressed non-safety-related SSCs that support safety functions.
Inspectors reviewed 39 of the 44 AMPs to assess the adequacy of the applicants guidance, implementation activities, and documentation. The review focused on whether the applicant could manage aging effects and maintain the intended functions of license renewal SSCs during the period of extended operation.
The inspectors also evaluated the applicants use of internal and external operating experience in identifying aging effects and enhancing AMP effectiveness.
To support these evaluations, inspectors conducted plant walkdowns of accessible areas, reviewed AMP documentation, and interviewed program engineers. Walkdowns focused on identifying observable signs of aging in selected SSCs within the scope of license renewal.
License Renewal Inspection (39 Samples)
(1)
Fatigue Monitoring, X.M1 (2)
Inservice Inspection, XI.M1 (3)
Water Chemistry, XI.M2 (4)
Reactor Head Closure Stud Bolting, XI.M3 (5)
BWR Vessel ID Attachment Welds, XI.M4 (6)
BWR Feedwater Nozzle, XI.M5 (7)
BWR Control Rod Drive Return Line Nozzle, XI.M6 (8)
BWR Stress Corrosion Cracking, XI.M7 (9)
BWR Penetrations, XI.M8 (10)
BWR Vessel Internals, XI.M9 (11)
Flow Accelerated Corrosion, XI.M17 (12)
Bolting Integrity, XI.M18
4 (13)
Open-Cycle Cooling Water System, XI.M20 (14)
Closed Treated Water Systems, XI.M21A (15)
Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, XI.M23 (16)
Compressed Air Monitoring, XI.M24 (17)
Fire Protection, XI.M26 (18)
Fire Water System, XI.M27 (19)
Aboveground Metallic Tanks, XI.M29 (20)
Fuel Oil Chemistry, XI.M30 (21)
Reactor Vessel Surveillance, XI.M31 (22)
One-Time Inspection, XI.M32 (23)
Selective Leaching, XI.M33 (24)
External Surfaces Monitoring of Mechanical Components, XI.M36 (25)
Inspection of Internals Surface in Miscellaneous Piping and Ducting Components, XI.M38 (26)
Lubricating Oil Analysis, XI.M39 (27)
Non-Boraflex Neutron-Absorbing Material, XI.40 (28)
Buried Underground Piping and Tanks, XI.M41 (29)
ASME Section XI, Subsection IWE, XI.S1 (30)
ASME Section XI, Subsection IWL, XI.S2 (31)
ASME Section XI, Subsection IWF, X1.S3 (32) 10 CFR Part 50, Appendix J, XI.S4 (33)
Masonry Walls, XI.S5 (34)
Structures Monitoring, XI.S6 (35)
Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, XI.E1 (36)
Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits, XI.E2 (37)
Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, XI.E3 (38)
Metal Enclosed Bus, XI.E4 (39)
Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, XI.E6
5 INSPECTION RESULTS Failure to Timely Drain Cable Vaults with Submerged Safety-Related Cables Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000461/2025011-01 Open/Closed
[H.8] -
Procedure Adherence 71002 The NRC identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the applicant failed to accomplish activities affecting quality in accordance with documented instructions, procedures or drawings. Specifically, the applicant failed to drain a cable vault within 3 weeks of safety-related (SR) cable submergence as required by their procedures.
==
Description:==
On June 26, 2025, inspectors identified that SR cables in vault 0SHA1D were submerged for a period that exceeded the duration allowed by procedure, based on water level monitoring data. The water level first exceeded the lowest cable elevation (e.g., 11 inches above the vault floor) on February 27, 2025, and remained above that level until the applicant pumped down the vault on May 14, 2025. At that time, the water level monitoring system recorded a peak water level of 26.6 inches. The applicant was unable to identify information explaining what prompted the draining of the vault on May 14, 2025. The vault contained medium-voltage cables for the SR essential service water (SX) system, which were not designed to remain continuously submerged.
The inspectors determined the applicant failed to follow procedure CPS 3221.02, Operating Cable Vault Pumping Stations, Revision 6c. Specifically, the applicant did not comply with Step 8.1.4.3, sub-step (2.3), which required initiating an IR when a high-water level advisory or alarm existed. This failure was also contrary to procedure ER-AA-300-150, Attachment 1, Pumping Criteria and Long-Term Wetting Definition, Revision 9. According to Table Q1-1 of Attachment 1, if cables have no previous test results and were wet occasionally during life, the vault must be drained within 3 weeks. Trend data confirmed that the SR cables in 0SHA1D vault exceeded the allowable submergence duration. These cables had not been tested. Step 4.6.4 of ER-AA-300-150 stated that the test options for critical medium-voltage cables were very low frequency (VLF) tan delta, VLF withstand, or offline partial discharge methods. Both procedures are credited by the applicants AMP for inaccessible power cables not subject to 10 CFR 50.49 environmental qualification requirements.
Additionally, inspectors noted that similar elevated water levels occurred in other SR cable vaults, in some cases exceeding high-level alarms. Due to a failure of the water level monitoring system, the applicant could not confirm whether other SR cables had also remained submerged beyond acceptable timeframes. The applicants performance associated with the maintenance of the monitoring system is discussed in the other NCV included in this inspection report.
Corrective Actions: The applicants corrective actions include reinforcing expectations for monitoring water level and draining during operator rounds. Also, the applicant plans to perform training needs analysis for both licensed and non-licensed operators to assess the need for vault draining. Lastly, the applicant plans to conduct corporate benchmarking to
6 identify best practices and review station procedures to ensure alignment with fleet vault draining timeframes.
Corrective Action References: AR 04886837 Performance Assessment:
Performance Deficiency: The applicants failure to drain SR cable vault 0SHA-1D within 3 weeks of cable submergence was contrary to Table Q1-1 of procedure ER-AA-300-150,, and was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the failure to drain cable vault 0SHA1D within 3 weeks of cable submergence does not assure that the SR cables will remain functional throughout the period of extended operation. The vault contained medium-voltage cables for the SX system, which were not designed to remain continuously submerged. Prolonged submergence can compromise cable insulation integrity and affect long-term reliability.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Using Exhibit 2, Mitigating Systems Screening Questions, the Team was able to answer yes to question A.1 and determined the finding to be of very low safety significance (Green). Specifically, the cable submergence did not represent a loss of operability or PRA system function.
Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Specifically, individuals did not initiate IRs upon receiving high-water level alarms for SR cable vault 0SHA1D, as required by procedure CPS 3221.02. As a result, SX cables remained submergence beyond the allowable duration.
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and be accomplished in accordance with these procedures.
The applicant established procedure ER-AA-300-150, Cable Condition Monitoring Program, Revision 9, as the implementing procedure for testing and evaluating all critical, medium-voltage cables in adverse environments. Attachment 1, Table Q1-1 described the condition prior to pumping and the corresponding required action. For cables with No previous test results available and that were Wet Occasionally During Life, the required action was to Drain within 3 weeks. Step 4.6.4 specified the applicable cable test options.
Contrary to the above, from February 27, 2025, through May 14, 2025, the applicant failed to accomplish activities affecting quality in accordance with procedure ER-AA-300-150.
Specifically, the SR SX cables in vault 0SHA1D became submerged on February 27, 2025.
Because the cables were not tested in accordance with any option specified in Step 4.6.4, the cable vault was required to be drained within 3 weeks per procedure ER-AA-300-150,, Table Q1-1. However, the cables remained submerged beyond the three-week period until the vault was drained on May 14, 2025.
7 Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Maintain Safety-Related Cable Vault Water Level Monitoring Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000461/2025011-02 Open/Closed
[H.9] - Training 71002 The NRC identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the applicant failed to accomplish activities affecting quality in accordance with documented instructions, procedures or drawings. Specifically, the applicant did not perform the actions required by procedure CPS 3221.02, Operating Cable Vault Pumping Stations, Revision 6c, related to the safety-related (SR) outdoor cable vault water level monitoring. These included failing to initiate an incident report (IR) for water level monitoring low battery alarms, failing to open the vaults to determine actual water levels when the ultrasonic level monitoring system was inoperable or the battery was dead, and failing to plug in the level controller during restoration from a secured vault condition.
==
Description:==
As part of its license renewal application, Clinton Nuclear Power Station requested an exception to the recommended surveillance frequency of annually monitoring water accumulation in SR cable vaults, proposing instead to inspect once every 5 years.
This exception was based on NRC guidance SLR-ISG-2021-04-ELECTRICAL, which stated, in part: Inspection of manholes equipped with water level monitoring and alarms that result in consistent and subsequent pump out of accumulated water prior to wetting or submergence of cables can be performed at least once every five years if supported by plant operating experience. However, the inspectors noted the plant operating experience and recent performance undermined their justification for this exception.
The station has ten SR cable vaults located outdoors, below grade, and susceptible to water accumulation. Each vault is equipped with a submersible pump, local water level indication, and remote level monitoring to prevent cables from becoming submerged. In 2018, the applicant installed SmartCovers, which are equipped with ultrasonic devices designed to monitor vault water levels. To ensure proper operation and maintenance of this equipment, the applicant established procedure CPS 3221.02, "Operating Cable Vault Pumping Stations," Revision 6c.
On June 9, 2025, during a walkdown, inspectors heard an alarm originating from cable vault 0SHA1B. The applicant determined the alarm was caused by tripped submersible pump #1 on high current. Additionally, the inspectors reviewed trend data associated with the SmartCover of vault 0SHA1B from January 1, 2024, to June 27, 2025, and discovered over 500 alerts since the beginning of that data. During the time the pump was tripped and the SmartCover was out of service, local water level indication was available. However, the applicant did not locally monitor the water level. The inspectors determined the applicant failed to follow procedure CPS 3221.02. Specifically, the applicant did not comply with Step 8.1.4.3, sub-step (3), which required initiating IRs if a SmartCover low battery alert was present. Additionally, the applicant did not implement the compensatory measures in, Cable Vault Failure Modes & Actions, which required operators to locally
8 determine water level by opening the cable vault cover whenever the ultrasonic level monitoring system failed or the battery was dead.
On June 23, 2025, the inspectors performed a second walk down of the cable vaults and discovered a level controller was left unplugged for SR cable vault 0SHB1D-LC.
The unplugged level controller caused the pump and the local and remote level indication to be inoperable. This was contrary to Step 8.1.4.2.5 of CPS 3221.02, which required plugging the level controller cord into a 120V receptacle when restoring from a secured cable vault.
These procedural failures, along with broader plant operating history, undermined the justification for the license renewal applications proposed 5-year surveillance interval for SR cable vault inspections.
Cable vault issues at Clinton have been documented in prior NRC inspections. In 2007, the NRC issued NCV 05000461/2007008-01 for failure to ensure the adequacy of the power and control cables that are submerged on a continuous basis. In 2009, Clinton installed solar-powered dewatering systems under Work Order 1254898-06, as documented in NRC inspection report 05000461/2015001. In 2014, the NRC found SR cables submerged for 22 years in 6 SR vaults and issued NCV 05000461/2015001-02 for unqualified safety-related cables used in a submerged environment. In 2016, the NRC issued NCV 05000461/2016002-02 for failure to identify submerged cables and a separate finding (FIN 05000451/2016002-03) for improper installation of dewatering equipment.
Corrective Actions: The applicant investigated and created a work order to correct the degraded conditions. The applicant generated training request TR 250605-001 to provide operators with further training on SmartCovers and created a work order to perform visual inspection of SR cable vaults.
Corrective Action References: AR 04871793, AR 04876197, AR 04876103, AR 04875921, and AR 04872644 Performance Assessment:
Performance Deficiency: The applicants failure to initiate IRs for SmartCover low battery alerts; to open cable vaults to determine water levels when the ultrasonic level monitoring system had failed or the battery was dead; and to plug in the level controller during restoration from a secured vault condition was contrary to procedure CPS 3221.02 and was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the performance deficiency would allow potential submergence of SR cables to go unnoticed, which does not ensure the cables will remain functional throughout the period of extended operation.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Using Exhibit 2, Mitigating Systems Screening Questions, the inspectors answered yes to question A.1 and determined the finding to be of very low safety significance (Green). Specifically, the performance deficiency did not involve a loss of operability or PRA system function.
9 Cross-Cutting Aspect: H.9 - Training: The organization provides training and ensures knowledge transfer to maintain a knowledgeable, technically competent workforce and instill nuclear safety values. Specifically, inspectors observed that operators lacked familiarity with monitoring SR cable vault water levels, including the physical locations of the vaults, associated remote panels, and the applicable procedures. The inspectors confirmed that the applicant was not providing training on these tasks or associated procedural requirements.
Enforcement:
Violation: Violation: 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and be accomplished in accordance with these procedures.
The applicant established continuous use operating procedure CPS 3221.02, Operating Cable Vault Pumping Stations, Revision 6c, as the implementing procedure for operating equipment associated with the SR cable vaults, an activity affecting quality. Procedure Step 8.1.4.2.5 required that if the panel door was opened [for restoration from a secured cable vault] then plug applicable cord in to 120V receptacle. Procedure Step 8.1.4.3, SmartCover Use, sub-step (3) required an IR if low battery alert exists. Attachment 3, Cable Vault Failure Modes & Actions, required, as a compensatory measure for an ultrasonic level monitoring system failure or dead battery that operators determine level only by opening cable vault.
Contrary to the above, since at least January 1, 2024, through June 27, 2025, the applicant failed to accomplish activities affecting quality in accordance with procedure CPS 3221.02.
Specifically, the applicant did not initiate IRs for SmartCover low battery alerts as required by Step 8.1.4.3(3). The applicant also failed to open cable vaults to determine water level when the ultrasonic level monitoring system failed or the battery was dead, contrary to the compensatory actions required by Attachment 3. In addition, the applicant did not plug a level controller cord into the 120V receptacle when restoring from a secured cable vault, as required by Step 8.1.4.2.5.
Enforcement Action: This violation is being treated as an NCV consistent with Section 2.3.2 of the Enforcement Policy.
Minor Violation 71002 Minor Violation: Title 10 of the Code of Federal Regulations (10 CFR) Part 50.71(e), states in part, each person licensed to operator a nuclear power reactor [] shall update periodically, as provided in paragraphs (e)(3) and (4) of this section, the final safety analysis report originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed.
Contrary to the above, as of June 27, 2025, the applicant failed to update the final safety analysis originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed. Specifically, Updated Final Safety Analysis Report (UFSAR) Section 9.3.1.4, Tests and Inspections, stated, The air for the Instrument Air System will be tested, at least annually, at the system filter discharge for a dew point of -40F and a particulate content in excess of 3 microns.
However, the applicant had revised its performance standards to align with ANSI/ISA-7.0.01, which allows for a dew point of +39°F downstream. Quarterly dew point testing, conducted
10 under Preventive Maintenance (PM) 00158471-47, used acceptance criteria consistent with this ANSI standard. Despite implementing this change, the applicant had not updated UFSAR Section 9.3.1.4 and had no plans to do so.
Screening: The inspectors determined that this issue constituted a minor violation.
Specifically, the outdated UFSAR content had no material impact on safety or licensed activities. The revised acceptance criteria were consistent with NRC guidance in NUREG-1801, Revision 2, Generic Aging Lessons Learned (GALL),Section XI.M24, which states, in part, Acceptance criteria for air quality moisture limits are established based on accepted industry standards, such as ANSI/ISA-S7.0.01-1996. This determination was made in accordance with the NRCs Enforcement Policy.
Enforcement: This failure to comply with 10 CFR 50.71(e) constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
Observation: Unclear Structures Monitoring of 345kV Switchyard 71002 The CPS Structures Monitoring AMP includes switchyard structures within the scope of license renewal. This scope covers both the 345kV and 138kV switchyards. While CPS is responsible for the operation and maintenance of the 138kV switchyard, the 345kV switchyard falls under the jurisdiction of Ameren Illinois Company (Ameren), in accordance with the Nuclear Plant Operating Agreement (NPOA) established in 2006.
During the review of 2019 and 2024 structures monitoring inspection records for outdoor structures, inspectors noted that CPS had not performed inspections of the 345kV switchyard structures. The applicant stated that these inspections are conducted by Ameren under the terms of the NPOA. However, the applicant could not confirm whether such inspections had actually been performed. Additionally, there was no documentation demonstrating that CPS was informed of the general structural condition of the 345kV switchyard structures, or whether any such inspections, if performed, were conducted by qualified personnel.
In response, the applicant-initiated Action Tracking Item 4548088-35-14 to establish a new PM activity. This PM will define a strategy to meet the license renewal commitment by ensuring that structures monitoring inspections and evaluations of the 345kV switchyard are performed by the responsible entity during the period of extended operation. It will also establish a process to verify that the inspections are conducted by personnel who meet the qualifications specified in ACI 349.3R, at intervals not exceeding 5 years, as required by the AMP.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On June 27, 2025, the inspectors presented the License Renewal Pre-Approval Inspection IP 71002 results to Norha Plumey, Site Vice President, and other members of the licensee staff.
11 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date 00104137 Cracking Identified in the Core Shroud Weld H4 04/17/2002 00764743 Earthquake Off-Normal Entry 04/18/2008 01040325 Containment Penetrations - Liner / Wall Degradation 03/09/2010 01545314 Loss of WD to the Power Block and Surrounding Buildings 08/10/2013 01549050 Inspection of Excavated Line 0DW005-6" 08/21/2013 02436853 1HC02G: 1 Loose Bolt Found During Crane Inspection 01/13/2015 02464446 EOID: 0RA02C Failed to Reach -50 Degrees Dewpoint 03/06/2015 02684138 CCW Component Cooling Demin Conductivity Approaching Limit 06/21/2016 02706215 NRC NCV 2016002-05 Lack of Acceptance Criteria for Containment Exam 08/19/2016 03971733 Need Oil Changed Based on Oil Condition of the Last Sample 02/08/2017 03973954 NRC NCV 2016004-01 Failed to Ensure Flood Seals Controlled 02/14/2017 03995087 Actions Needed for WO System Corrosion Control 04/06/2017 04012873 UT Indiction in N1B-W-1 05/19/2017 04057349 System Disolved Oxygen is Higher Than Expected 09/29/2017 04077439 Evaluation of Containment Visual Inspection Indications Identified in C1R17 11/22/2017 04078859 RCIC Tank Inspection Results 11/29/2017 04104823 0WE050 Valve Bonnet Bolt Found Broken Off 02/16/2018 04136734 Divers Bolt Inspect Locates Loose Jam Nut on ECCS Strainer 05/11/2018 04136970 Divers Found 6 Loose Jam Nuts on 1E12D331 ECCS Strainer 05/12/2018 04187378 Division 2 DG 12 CYL Fuel Pump Bolt Found Loose 10/24/2018 04192481 Reactor Water Chlorides Above Action Level 1 AL-1 Post C1M23 11/07/2018 04282958 Minor Discrepancies During Refuel Bridge (F15) Walkdown 09/27/2019 71002 Corrective Action Documents 04284830 INR C1R19 IVVI-19-07 SRM D 38-35 10/03/2019
12 Inspection Procedure Type Designation Description or Title Revision or Date 04284958 Elevated Copper in 1B33C001B Motor Lower Bearing Oil 10/04/2019 04287793 NOS ID Gap IDd in Wall in the Aux Electrical Equipment Room 10/14/2019 04338031 Diesel Fuel Oil Prelim Truck Sample Sulfur OOS Cab Rejected 04/23/2020 04352219 EOID: 1VY03S RHR 1A Roomer Cooler Thru Leak 06/24/2020 04352621 Emerging Trend for ECCS Room Cooler Tubing Leaks 06/25/2020 04509371-07 4010.02 Chemistry Off-Normal Entered (Sulfates >AL1) 11/10/2022 04552063 Clinton Tank Self-Assessment QTR 4 2022 02/02/2023 04705164 C1R21 IVVI Steam Dryer Support Bracket Indications 09/26/2023 04749482 Reactor Internals Health Report Cornerstone Yellow 02/12/2024 04767447 LS1 not working in OSHB-1D Cable Vault 04/17/2024 04870801 Cable Vault 0SHD Communications and Power Issues 09/29/2024 04874392 781 FB East Roof Leak 06/18/2025 04874667 NOS ID: NDE Not Conducted FB Crane Hook for 3 Years 06/19/2025 04866362 Cathodic Protection System Deficiencies.
05/16/2025 04871793 NRC ID: OSHA1B Submersible Pump Tripped 06/09/2025 04872644 LR-INSP: Trend in Cable Vault Dewatering Issues 06/12/2025 04873801 NRC ID: USAR 9.3.1.4 Not Updated to ANSI Standard ISA-S7.3 06/17/2025 04875921 NRC ID: Level Controller for Safety-Related Cable Vault Unplugged 06/24/2025 04876103 NRC ID: CPS 3221.02 Attachment 3 Not Followed 06/25/2025 04876197 NRC ID: Cable Vault SmartCover IRs Not Generated 06/25/2025 Corrective Action Documents Resulting from Inspection 04886837 NRC ID: SR 0SHA-1D Not Dewatered IAW ER-AA-300-150 07/29/2025 4138 Test Coupon & Coupon Tree Spent Fuel Storage Racks 1
D-77-267 Diesel Generator Fuel Oil Day Tank 5
E05-1037 Screenhouse Manholes Sections & Details P
E05-1202 OSHA/OSHD Cable Vault Control Panel Electrical Installation 1
E05-1700-01 Cable Routing Outdoor Duct Runs H
Drawings JN-D51749 Alum. RCIC Storage Tank 3
Engineering 349325 Spent Fuel Storage Capacity Expansion Phase 1 -Cask 2
13 Inspection Procedure Type Designation Description or Title Revision or Date Storage Pool 362811 Spent Fuel Pool Re-Rack Phase 2
619862 Evaluation of In-Vessel Visual Inspection Notification Reports C1R17 0
620464 Permanent Power and Ultrasonic Indication for SR Cable Vaults 1
636557 CPS Fatigue Monitoring Report Through March 2022 0
639878 CR21 Technical Evaluation of In-Vessel Indications 10/23/2023 Changes 643531 CPS Fatigue Monitoring Report Through September 2024 and March 2025 0
Engineering Evaluations 639807 C1R21 Evaluation of VT-3 As-Found Setting for Spring Hangers 0
007N8539 Clinton Unit 1 License Renewal Top Head Closure CMTR Data Review (Proprietary) 0 494962 Purchase Order for Reactor Vessel Head Stud Assembly 4
Auxiliary Steam System System and Structure Scoping Report, Rev 0 Auxiliary Steam System 08/17/2022 C286-000005 Operation and Service Manual of Steel Housed Storage Unit Low Pressure Carbon Dioxide 1-12.5 Tons 0
Cable Vault Vtip Part 1 Operation Manual for Cable Vault Pump Controller and Level Sensor 0
CL-AMPBD-SLI Selective Leaching Inspection Sample Basis Document 2
CL-PBD-AMP-X.E1 Environmental Qualification (EQ) of Electric Components 1
CL-PBD-AMP-X.M1 Fatigue Monitoring 4
CL-PBD-AMP-XI.E1 Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements 2
Miscellaneous CL-PBD-AMP-XI.E2 Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification 2
14 Inspection Procedure Type Designation Description or Title Revision or Date Requirements Used in Instrumentation Circuits CL-PBD-AMP-XI.E3 Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements 3
CL-PBD-AMP-XI.E4 Metal Enclosed Bus 1
CL-PBD-AMP-XI.E6 Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements 1
CL-PBD-AMP-XI.M1 ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD 1
CL-PBD-AMP-XI.M17 Flow-Accelerated Corrosion 3
CL-PBD-AMP-XI.M18 Bolting Integrity 2
CL-PBD-AMP-XI.M2 Water Chemistry 1
CL-PBD-AMP-XI.M20 Open-Cycle Cooling Water System 4
CL-PBD-AMP-XI.M21A Closed Treated Water Systems 5
CL-PBD-AMP-XI.M23 Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems 2
CL-PBD-AMP-XI.M24 Compressed Air Monitoring 2
CL-PBD-AMP-XI.M26 Fire Protection 2
CL-PBD-AMP-XI.M27 Fire Water System 3
CL-PBD-AMP-XI.M29 Aboveground Metallic Tanks 1
CL-PBD-AMP-XI.M3 Reactor Head Closure Stud Bolting 2
CL-PBD-AMP-XI.M30 Fuel Oil Chemistry 3
CL-PBD-AMP-One-Time Inspection 6
15 Inspection Procedure Type Designation Description or Title Revision or Date XI.M32 CL-PBD-AMP-XI.M33 Selective Leaching 2
CL-PBD-AMP-XI.M36 External Surfaces Monitoring of Mechanical Components 2
CL-PBD-AMP-XI.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components 3
CL-PBD-AMP-XI.M39 Lubricating Oil Analysis 2
CL-PBD-AMP-XI.M4 BWR Vessel ID Attachment Welds 2
CL-PBD-AMP-XI.M40 Monitoring of Neutron-Absorbing Materials Other Than Boraflex 2
CL-PBD-AMP-XI.M41 Buried and Underground Piping and Tanks 4
CL-PBD-AMP-XI.M5 BWR Feedwater Nozzle 1
CL-PBD-AMP-XI.M6 BWR Control Rod Drive Return Line Nozzle 1
CL-PBD-AMP-XI.M7 BWR Stress Corrosion Cracking 1
CL-PBD-AMP-XI.M8 BWR Penetrations 1
CL-PBD-AMP-XI.M9 BWR Vessel Internals 1
CL-PBD-AMP-XI.S1 ASME Section XI, Subsection IWE 2
CL-PBD-AMP-XI.S2 ASME XI, Subsection IWL 3
CL-PBD-AMP-XI.S3 ASME Section XI, Subsection IWF 2
CL-PBD-AMP-XI.S4 10 CFR Part 50, Appendix J 1
CL-PBD-AMP-Masonry Walls 2
16 Inspection Procedure Type Designation Description or Title Revision or Date XI.S5 CL-PBD-AMP-XI.S6 Structures Monitoring 3
ISI-IN Vessel Inspection Program Clinton Power Station In-Vessel Inspectoin (IVI) Program Plan 07/25/2022 NPOA Nuclear Plant Operating Agreement for Clinton Power Station 02/05/2021 SIR-00-049 Cycle Counting and Cycle-Based Fatigue Report for the Transient and Fatigue Monitoring System for CPS 3
Y-109831 Maintenance Rule Program - Structures Monitoring Assessment 04/26/2019 Y-109910 C1R21 Containment Drywell Coatings Inspection Report 09/20/2023 C1R19-7480-198940-LH1-Shroud UT Core Shroud Ultrasonic Inspection Final Report 09/26/2019 NDE Reports INR C1R21 IVVI-23-03 Steam Dryer Support Bracket-Indication Notification Report Steam Dryer Support Bracket 09/24/2023 2400.01 Circulating Water Screenhouse (CWSH) Intake Structure Inspection 9
3870.01C001 Fuel Handling Platform (F11) Walkdown Checklist 4a 8106.03F001 Crane Inspections 18b CPS 3221.02 Operating Cable Vault Pumping Stations 6c CPS 8901.01 Oil Sampling 8
CPS 9071.13 Fire Protection Diesel Generator Bay 1B CO2 System Auto Actuation Test 5a CY-AA-120-4000-F-04 Clinton Closed Cooling Water Treatment and Control 0
Procedures CY-AA-120-4110-F-03 Clinton Raw Water Treatment and Control 4
17 Inspection Procedure Type Designation Description or Title Revision or Date CY-AA-120-5000 Diesel Fuel Oil Program Guide 1
CY-CL-1937-01 Diesel Fuel Oil Testing Program 1
CY-CL-3221-02 Sampling Cable Vault Pumping Stations 22 CY-CL-6001-01 Sampling and Analysis Requirements 18 ER-AA-300-150 Cable Condition Monitoring Program 9
ER-AA-330 Conduct of Inservice Inspection Activities 19 ER-AA-330-002 Inservice Inspection of Section XI Welds and Components 18 ER-AA-330-005 Visual Examination of Section XI Class CC Concrete Containment Structures 16 ER-AA-330-009 ASME Section XI Repair/Replacement Program 18 ER-AA-335-018 Visual Examination of ASME IWE Class MC and Metallic Liners of Class CC Components 17 ER-AA-340 GL 89-13 Program Implementing Procedure 10 ER-AA-430-1001 Guidelines for Flow Accelerated Corrosion Activities 14 ER-AA-450 Structures Monitoring 11 ER-AA-700 License Renewal Implementation Program 10 ER-AA-700-1003 Use of Operating Experience for License Renewal Implementation/Aging Management 6
ER-AA-700-404 Aging Management Program for Aboveground Metallic Tanks 2 ER-AA-700-405 Compressed Air Monitoring Aging Management Program 2
ER-CL-330-001 Containment IWE and IWL Inspection Acceptance Criteria 1
ER-CL-330-1001 ISI Program Plan 0
ER-CL-330-1001 ISI Program Plan Fourth Ten-Year Interval Clinton Power Station, Unit 1 0
ER-CL-330-1001 Fourth Interval ISI Program Plan 0
ER-CL-330-1003 ISI Selection Document, Fourth Ten-Year Inspection Interval 1
ER-CL-450-1006 Clinton Structures Monitoring Instructions 2
ER-CL-450-1007 Clinton Surveillance Inspection Program for Flood Seals 4
MA-AA-410 Bolting Integrity Aging Management Program 3
MA-AA-716-006 Control of Lubricants Program 16 MA-AA-716-021 Rigging and Lifting Program 34 MA-AA-736-600 Torquing and Tightening of Bolted Connections 13 and 14 MA-CL-716-103 Reactor Assembly 16
18 Inspection Procedure Type Designation Description or Title Revision or Date MA-CL-736-6001 Tightening of Flanged Connections 1
01353158 ERAT Outdoor Non-Seg Bus Visual Inspections 05/20/2014 01471754 Perform SER 5-09 Non-Seg Bus Torque / DLRO Checks for RATS 10/10/2013 01485238-24 ED Perform Coatings Inspection for 1DG01TB 06/27/2016 01545326 RAT B Non-Seg Internal Inspection Indoor Portion 10/10/2013 01765922-01 MM - Dive Areas 1 & 2 Inspect/Clean Screenhouse Structure 04/08/2017 04685556 Level Transient on MSDT 1A During Downpower 05/15/2018 04710777 Inspect 0SA01D Dryer Desiccant and Replace as Necessary 02/27/2019 04846440 Trend in UT Results Indicate Pip Replacement Needed 05/07/2019 05233950 Mechanical Annual Inspection 03/01/2023 1703749 C1R15 CISI Inspections 10/20/2015 4835791 Perform Containment CISI Inspections 12/02/2019 Work Orders 5307812-01 ED Perform Structures Monitoring Inspections - Online 06/13/2024