ML25252A433

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Notice of Violation and Investigation Report No. OI-RIII-2024-0011
ML25252A433
Person / Time
Site: 05533900
Issue date: 09/30/2025
From: Jason Kozal
NRC/RGN-III
To: Mohundro S
- No Known Affiliation
References
EAI-RIII-2025-0115, OI?RIII?2024?0011
Download: ML25252A433 (1)


Text

EAI-RIII-2025-0115 Shane Mohundro

[HOME ADDRESS DELETED UNDER 10 CFR 2.390(a)]

SUBJECT:

NOTICE OF VIOLATION AND INVESTIGATION REPORT NO. OIRIII20240011

Dear Shane Mohundro:

This letter refers to U.S. Nuclear Regulatory Commission (NRC) Investigation No.

OIRIII20240011 completed on April 29, 2025, regarding your activities at Clinton Power Station located in Clinton, IL. The purpose of the investigation was to determine whether you deliberately made materially inaccurate statements and provided incomplete evidence to the licensee as well as the NRC on February 28, 2024. A factual summary of investigation OIRIII20240011, which substantiated willful behaviors by you, is provided in Enclosure 1.

Based on the information developed during the investigation, the NRC has determined that a deliberate violation of NRC requirements occurred. The violation is cited in the enclosed Notice of Violation (Notice) (Enclosure 2). On February 28, 2024, you knowingly and deliberately submitted to the NRC information that you knew to be incomplete and inaccurate in some material respect to the NRC. Specifically, you provided false information to the NRC regarding an alleged incident involving another licensed operator engaged in activities prohibited by NRC rules and regulations. Your deliberate actions placed you in violation of Title 10 of the Code of Federal Regulations (CFR) 55.9, Completeness and Accuracy of Information. Given the significance of the underlying issue and the deliberate nature of your actions, this violation has been categorized in accordance with the NRC Enforcement Policy at Severity Level (SL) IV.

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 Clinton Power Station. 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 605632657, within 30 days of the date of this letter. Please make sure to mark your response Open by Addressee Only, and include individual enforcement action number, EAI-RIII-2025-0115. You may contact Diana Betancourt-Roldan, Enforcement and Investigations Officer, if you have any questions, at 630810-4373.

September 30, 2025

S. Mohundro 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 Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. A copy of this letter and the enclosed Notice of Violation 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 website at https://www.nrc.gov/reading-rm/doc-collections/enforcement/actions/index.html.

In addition, this letter will be maintained by the Office of Enforcement in an NRC Privacy Act system of records, NRC3, 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 NRC3 system notice, which provides detailed information about this system of records, can be accessed from the NRC website 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 Paul Zurawski of my staff at 630829-9631 if you have any questions.

Sincerely, Jason Kozal, Director Division of Operating Reactor Safety Region III Docket No. 55-33900 License No. SOP500921-1

Enclosures:

1. Factual Summary
2. Notice of Violation Signed by Kozal, Jason on 09/30/25

S. Mohundro Letter to S. Mohundro from J. Kozal dated September 30, 2025.

SUBJECT:

NOTICE OF VIOLATION AND INVESTIGATION REPORT NO. OIRIII20240011 DISTRIBUTION:

Juan Peralta Gerald Gulla Eric Brothman John Giessner Mohammed Shuaibi Jason Kozal Billy Dickson Diana Betancourt-Roldan Paul Zurawski Gregory Roach Viktoria Mitlyng Prema Chandrathil Jason Draper Michelle Garza Sarah Bakhsh Jeremy Francis Shannon Rogers Marcia Simon Sandra Mendez RIDSOEMailCenter Resource OE: IA File ADAMS Accession Number: ML25252A433 Publicly Available Non-Publicly Available Sensitive Non-Sensitive OFFICE RIII-EICS RIII-DORS OE OE NAME JDraper:bw PZurawski GGulla for JPeralta SMendez DATE 9/10/2025 9/11/2025 9/17/2025 9/17/2025 OFFICE OGC for NLO RIII-EICS RIII-DORS NAME SRogers DBetancourt-Roldan JKozal DATE 9/15/2025 9/18/2025 9/30/2025 OFFICIAL RECORD COPY Factual Summary of NRC Office of Investigations Case No. OIRIII20240011 On June 10, 2024, the U.S. Nuclear Regulatory Commission (NRC), Office of Investigations (OI), Region III, initiated investigation No. OIRIII20240011 to determine whether a former Senior Reactor Operator (SRO) at the Clinton Power Station (CPS) deliberately made materially inaccurate statements and provided incomplete evidence to the NRC and licensee. The investigation was completed on April 29, 2025, and was documented in OI Report OIRIII20240011.

The investigation showed that on February 28, 2024, the SRO who was the subject of the investigation (SRO 1) submitted a photograph to the NRC Senior Resident Inspector (SRI) of a fellow SRO (SRO 2) with his head down on a desk inside the control room at CPS. On February 29, 2024, SRO 1 made an anonymous report to the licensees ethics hotline stating that he had received a text message containing a photograph of SRO 2 sleeping in the control room and had reported this to the NRC. In his report to the ethics hotline, SRO 1 stated that no one else could be seen in the picture. On March 18, 2024, the NRC provided a printed copy of the photo to the licensee, and the licensee initiated an internal investigation.

According to the licensees investigation report dated April 18, 2024, SRO 1 acknowledged that he had made the ethics hotline report. SRO 1 also stated that the photo showed SRO 2 sleeping in the main control room, that the only person in the photo was SRO 2, and that he (SRO 1) received the photo in a text message on his personal cell phone from a number and person he did not know. However, during its internal investigation the licensee learned that the photograph provided to the NRC was a cropped version of a photograph taken by a reactor operator (RO) on September 27, 2020, at approximately 8:00 a.m. Text messages revealed that the RO had sent the original, uncropped photo to a group chat that included SRO 1 on January 31, 2024. The original uncropped photograph showed another person standing near the desk where the SRO had his head down. The text messages also revealed that SRO 1 had sent an earlier text suggesting that the group chat members send him lazy pictures of SRO 2.

The OI interviewed SRO 1 on two different occasions. Each time, SRO 1 repeatedly claimed that he received the photo in a text message from an unknown person and number. SRO 1 admitted that he was part of the group chat but claimed that his phone never received the photo that was sent on January 31, 2024, as part of that group chat. Other ROs who were on the group chat told OI that they did receive the photo on that date. The RO who took the picture told OI that he had not shared the photo with anyone before January 31, 2024.

The OI investigation also revealed that SRO 2 was SRO 1s supervisor and that SRO 2 gave SRO 1 his 2023 year-end performance review in January 2024. In that review, SRO 1 received the lowest possible rating and thus was not eligible for a bonus or a raise. Also in January 2024, SRO 1 was taken off shift and placed in a position with administrative duties. During his OI interview, SRO 2 stated that SRO 1 did not take his review well, and that site leaderships decision to remove SRO 2 from shift duties was something SRO 2 did not want.

Based on the evidence gathered during the NRC OI investigation, including the results of the licensees internal investigation, it appears that SRO 1 violated Title 10 of the Code of Federal Regulations (10 CFR) 55.9 when he submitted the cropped photograph to the NRC SRI and subsequently made inaccurate statements to the NRC during OI interviews. Furthermore, it appears that SRO 1 submitted information to the NRC knowing that it was inaccurate, which would make the apparent violation of 10 CFR 55.9 a willful violation.

NOTICE OF VIOATION Shane Mohundro Docket No. 55-33900

[HOME ADDRESS DELETED License No. SOP-500921-1 UNDER 10 CFR 2.390(a)]

EAI-RIII-2025-0115 During the review of NRC Investigation Report OIRIII20240011 that was completed on April 29, 2025, 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 SOP5009211 issued to Shane Mohundro on March 1, 2017, 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 55.9, Completeness and Accuracy of Information, states, Information provided to the Commission by an applicant for a license or by a licensee or information required by statute or by the Commissions regulations, orders, or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects.

Contrary to the above, on February 28, 2024, you, at the time a licensed Senior Reactor Operator (SRO) at the Clinton Power Station (CPS), knowingly and deliberately submitted to the NRC information that you knew to be incomplete and inaccurate in some respect material to the NRC. Specifically, you provided false information to the NRC through the allegation process regarding an alleged incident involving another licensed operator engaged in activities prohibited by NRC rules and regulations.

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

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 CPS. 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-2025-0115, and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 205550001, with a copy to the Regional Administrator, Region III, 2056 Westings Avenue, Suite 400, Naperville, IL, 605632657, and a copy to the NRC Resident Inspector at the Clinton Power Station 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 205550001.

2 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 website 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, NRC3, 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 NRC3 system notice, which provides detailed information about this system of records, can be accessed from the NRC website at http://www.nrc.gov/reading-rm/foia/privacy-systems.html.

Dated this 30th day of September 2025.