ML25349A028
| ML25349A028 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/16/2025 |
| From: | John Dixon NRC/RGN-IV/DORS/PBD |
| To: | Sullivan J Entergy Operations |
| References | |
| IR 2025040 | |
| Download: ML25349A028 (0) | |
See also: IR 05000382/2025040
Text
December 16, 2025
Joseph Sullivan
Site Vice President
Entergy Operations, Inc.
17265 River Road
Killona, LA 70057
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - 95001 SUPPLEMENTAL
INSPECTION SUPPLEMENTAL REPORT 05000382/2025040 AND FOLLOW-UP
ASSESSMENT LETTER
Dear Joseph Sullivan:
On September 25, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed a
supplemental inspection using Inspection Procedure 95001, Supplemental Inspection
Response to Action Matrix Column 2 (Regulatory Response) Inputs, and discussed the results
of the inspection and the implementation of your corrective actions with David Oertling, General
Manager Plant Operations, and other members of your staff.
Due to the temporary cessation of government operations, which commenced on October 1,
2025, the NRC began operating under its Office of Management and Budget-approved plan for
operations during a lapse in appropriations. Consistent with that plan, the NRC operated at
reduced staffing levels throughout the duration of the shutdown. However, the NRC continued to
perform critical health and safety functions and make progress on other high-priority activities
associated with the ADVANCE Act and Executive Order 14300. On November 13, 2025,
following the passage of a continuing resolution, the NRC resumed normal operations.
However, due to the 43-day lapse in normal operations, the Office of Nuclear Reactor
Regulation granted the Regional Offices an extension on the issuance of the calendar year
2025 inspection reports that should have been issued by November 13, 2025, to December 31,
2025. The NRC resumed the routine cycle of issuing inspection reports on November 13, 2025.
The NRC performed this inspection to review your stations actions in response to degraded
performance that led to a violation of 10 CFR 50, Appendix B, Criterion V, Instructions,
Procedures, and Drawings and subsequent White finding regarding the failure to properly
develop and implement adequate maintenance instructions for the fuel linkage connection to the
mechanical governor for emergency diesel generator A. On August 20, 2025, you informed the
NRC that your station was ready for the supplemental inspection (ADAMS Accession No.
J. Sullivan
2
The NRC determined that your staffs evaluation of the degraded performance that led to the
White finding identified a root cause. Specifically, your staffs evaluation identified that
insufficient details were included in the preventive maintenance job plan for emergency diesel
generator A.
The inspectors determined that the licensee appropriately identified the root cause and
contributing causes using systematic methodologies, considered prior occurrences and
operating experience and documented their analyses in sufficient detail. Based on the results of
the inspection, the inspectors concluded that the objectives of the inspection procedure were
met.
The NRC determined that the completed and planned corrective actions were sufficient to
address the performance issue that led to the White finding. Therefore, the performance issue
will be closed and no longer be considered as an Action Matrix input as of the date of the exit
meeting. Based on the results of the inspection and our Action Matrix assessment, the NRC
made the determination to transition Waterford Steam Electric Station, Unit 3 to the Licensee
Response Column (Column 1) of the Action Matrix on September 25, 2025, considering the
absence of additional Action Matrix inputs.
Sincerely,
John L. Dixon, Jr., Chief
Reactor Projects Branch D
Division of Operating Reactor Safety
Docket No. 05000382
License No. NPF-38
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
Signed by Dixon, John
on 12/16/25
Publicly Available and Non-Sensitive
Non-Publicly Available and Sensitive
Keyword
OFFICE
SRI:DORS/PBD
RI:DORS/PBD
SPE:DORSPBD
BC:DORS:D
NAME
GPick
ETinger
ASanchez
JDixon
SIGNATURE
/RA/
/RA/
/RA/
/RA/
DATE
12/16/25
12/15/25
12/15/25
12/16/25
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number:
05000382
License Number:
Report Number:
Enterprise Identifier:
I-2025-040-0007
Licensee:
Entergy Operations, Inc.
Facility:
Waterford Steam Electric Station, Unit 3
Location:
Killona, LA 70057
Inspection Dates:
September 22, 2025, to September 26, 2025
Inspectors:
E. Tinger, Resident Inspector
G. Pick, Senior Reactor Inspector
Approved By:
John L. Dixon, Jr., Chief
Reactor Projects Branch D
Division of Operating Reactor Safety
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting a 95001 supplemental inspection at Waterford Steam Electric
Station, Unit 3, 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
No findings or violations of more than minor significance were identified.
Additional Tracking Items
Type
Issue Number
Title
Report Section
Status
Waterford 95001 CAPR CR-
WF3-2024-04960-00017
Create and Implement a
Mechanical Maintenance
Procedure for Replacement
of the Mechanical Governor
for the Emergency Diesel
Generators
95001
Discussed
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
95001 - Supplemental Inspection Response to Action Matrix Column 2 (Regulatory Response)
Inputs
The inspectors reviewed and selectively challenged aspects of the licensees problem
identification, causal analysis, and corrective actions in response to degraded performance that
led to Waterford Steam Electric Station, Unit 3 being moved into Column 2 of the Action Matrix
for a violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings
and subsequent White finding regarding the failure to properly develop and implement adequate
maintenance instructions for the fuel linkage connection to the mechanical governor for
emergency diesel generator A. The preliminary White finding is discussed in Inspection Report 05000382/2025090, dated April 9, 2025 (ML25097A205). The final significance determination
and notice of violation are discussed in Inspection Report 05000382/2025091, dated June 5,
2025 (ML25149A059).
Objective: Ensure that the root and contributing causes of individual and collective white
performance issues are understood.
Under this objective, the inspectors reviewed the root cause evaluation the licensee
conducted for a White finding regarding the failure to properly develop and implement
adequate maintenance instructions for the fuel linkage connection to the mechanical
governor for emergency diesel generator (EDG) A, as documented in Final Significance
Determination of a White Finding, Notice of Violation, and Follow-Up Assessment Letter for
Waterford Steam Electric Station, Unit 3, dated June 5, 2025 (Report 05000382/2025091
(ML25149A059)). Their review consisted of an evaluation of the following: the licensees
identification of the issue, when and how long the issue existed, prior opportunities for
identification, documentation of significant plant-specific consequences and compliance
concerns, use of systematic methodology to identify causes with a sufficient level of
supporting detail, consideration of prior occurrences, identification of extent-of-condition and
extent-of-cause, and identification of any potential programmatic weaknesses in
performance.
NRC Assessment: The inspectors concluded that this objective was Met. The inspectors
determined that the licensee appropriately identified the root cause and contributing cause
using systematic methodologies, considered prior occurrences and operating experience,
and documented their analyses in sufficient detail.
4
The licensee used multiple techniques to analyze the performance issue and identified the
following root cause and contributing cause:
Root cause: Insufficient details included in the preventive maintenance job plan for
EDG A. Specifically, details needed to perform work on a critical component, such as
guidance on proper alignment of the lever arm, torque values, and recommendations
for thread locking compounds, were not included in the preventive maintenance job
plan.
Contributing cause: An organizational performance gap in the planning department
did not ensure workers were in rule-based performance and represented a missed
opportunity for the maintenance organization to raise standards and improve
performance in planning.
a. Identification. The performance issue was self-revealed and identified during a
walkdown of EDG A following a mechanical overspeed trip on October 10, 2024. The
inspectors did not identify any concerns with the licensee characterization of the event.
b. Exposure Time. The licensee determined that an exposure time of 94 days plus one
day of repair time was applicable. The licensee concluded that EDG A would have failed to
run for its 24-hour mission time starting on July 8, 2024. The inspectors determined that the
licensee appropriately assessed the exposure time.
c. Identification Opportunities. The licensee identified additional opportunities for
identification as follows:
The licensee identified an opportunity for identification of the missing technical
information in the EDG governor replacement work order. The licensee had
previously replaced the EDG A governor in 2014. Following this replacement, system
engineers provided handwritten feedback on the work order with recommendations
to add steps to use a thread locking compound and include vendor specified torque
values. This feedback was not incorporated into the model work order used for the
governor replacement in 2024 contributing to the lack of sufficient technical
information in the work order.
The licensee identified a potential missed opportunity for identification of contact
between the EDG governor lever arm and the rod end during required quarterly
system walkdowns. The licensee determined that the fretting damage on the corner
of the lever could have potentially been identified, but the likelihood is low due to the
small area of damage that was visible.
The inspectors determined that the licensee appropriately identified missed identification
opportunities for the performance issue.
d. Risk and Compliance. The inspectors determined that the licensee had identified and
understood the plant-specific risk and compliance concerns associated with the
performance issue. The risk included continued inoperability of EDG A, although additional
alternate power sources were available for use at the time. Compliance concerns were
addressed by mitigating actions taken to enhance the work instructions for replacing the
EDG governor.
5
e. Methodology. The licensee employed systematic evidence-based causal analysis to
reliably and transparently determine the root and contributing causes of the White
performance issue. The methods included equipment failure evaluation, failure modes
analysis, organizational and programmatic screening, common cause review, and a why
staircase.
f. Level of Detail. The inspectors determined the root cause evaluation was conducted and
documented to a level of detail commensurate with the significance and complexity of the
issue and regulatory requirements.
g. Operating Experience. The licensee reviewed operating experience for the performance
issue, and the following internal and external operating experience was relevant to the
diesel linkage failure.
The licensee performed an internal operating experience search and found three applicable
events related to diesel generators and inadequate work order quality. The licensee
identified one event from Waterford in 2016, which described a mechanical linkage that
disengaged from an auxiliary component cooling water valve due to an incorrectly installed
nut. The licensee documented two applicable events from Arkansas Nuclear One. In 2016,
an emergency diesel generator experienced a generator bearing failure due to inadequate
lubrication caused by an oil level sight glass that was installed upside down. In 2021, a
diesel generator experienced an inadvertent overspeed trip due to inadequate vendor
technical information in a test procedure. These events supported the licensees conclusion
regarding the importance of work order quality for successful task completion.
The licensee determined that external operating experience identified similar events related
to emergency diesel generators and fuel rack linkages.
In 2013, the EDG at Salem Hope Creek experienced frequency oscillations during a
monthly surveillance. The most likely apparent cause was determined to be
mechanical binding in the fuel rack linkage.
In 2003 at Susquehanna, the EDG fuel control linkage separated from the governor
terminal shaft lever causing loading to unexpectedly decrease during a surveillance
run. The bolt that attached the fuel control linkage to the governor terminal shaft
lever had backed out, likely due to not being tightened adequately during
maintenance.
The licensee determined that while the operating experience supported the conclusions
related to the failure of EDG A, it would not have prevented the event from occurring. The
inspectors determined that the licensee appropriately considered past operating experience
related to the failure of EDG A.
h. Safety Culture Traits. The inspectors determined that the licensee performed a safety
culture assessment and appropriately considered the safety culture traits in NUREG-2165,
Safety Culture Common Language. For the root cause, the licensee identified a weakness
in the work management process of planning, controlling, and executing work activities,
which led to the deficient preventive maintenance job plan for EDG A. For the contributing
cause, the licensee identified weaknesses in corrective action resolution and complacency
of station personnel. A weakness in corrective action resolution was identified due to the
6
licensee identifying multiple previous opportunities to address planning organization
performance gaps prior to the failure of EDG A. The licensee identified complacency of
station personnel because the preventive maintenance job plan for EDG A had been used
several times prior to the failure of EDG A, and station personnel failed to identify and
communicate deficiencies in the job plan. The inspectors determined the licensee
established corrective actions to address these weaknesses.
i. Common Cause. Common Cause is not applicable for this report because there is only
one White performance deficiency.
Objective: Ensure that the extent-of-condition and extent-of-cause of individual and collective
white performance issues are identified.
Under this objective, the inspectors independently assessed the extent of condition and
extent of cause evaluations that were performed in relation to the White performance issue
to ensure the licensees evaluation was sufficiently comprehensive.
NRC Assessment: The inspectors concluded that this objective was Met. The inspectors
found that the licensee appropriately identified the extent of condition and, generally,
appropriately identified the extent of cause for the performance issue.
The extent of condition for the performance issue identified other diesel-driven safety-related
components, backup to safety-related components, and augmented quality program
components that had the potential for a governor linkage to become bound or disconnected.
Diesel-driven safety-related and backup to safety-related components were classified as
medium risk and included the EDGs, the turbine-driven emergency feed pump, and the
permanent temporary emergency diesel. Augmented quality program components were
classified as low risk and included the security diesel, FLEX diesel, and diesel-driven fire
pumps. The inspectors reviewed the extent of condition analysis and did not identify
concerns.
The extent of cause reviewed a sample of other preventive maintenance work orders and
work orders associated with both critical and non-critical components. Specifically, the
extent of cause ensured the sampled work orders included the proper vendor technical
information, the correct work order level, and appropriate operating experience related to the
work order subject matter. During this review, the inspectors identified that the extent of
cause did not specifically include a review of work orders associated with the diesel-driven
components classified as medium risk in the extent of condition analysis. This is
documented below as Minor Weakness 1.
Minor Weakness 1
The inspectors identified a minor weakness associated with the extent of cause review
performed by the licensee. The extent of cause actions sampled work orders associated
with critical and non-critical components to ensure specific technical elements were included
properly. As part of the extent of cause, the licensee did not specifically review the work
orders associated with the medium risk extent of condition diesel-driven components. The
inspectors determined that unless a work order associated with a medium risk component
was picked as part of an extent of cause sample then the work order would not be reviewed.
This created a potential gap for a work order associated with a medium risk diesel-driven
7
component to include inadequate technical information and not be corrected. The licensee
documented this weakness in condition report CR-WF3-2025-04439.
Objective: Ensure that completed corrective actions to address and preclude repetition of white
performance issues are timely and effective.
Under this objective, the inspectors assessed the appropriateness and timeliness of the
licensee's corrective actions.
NRC Assessment: The inspectors concluded that this objective was Met. The inspectors
determined that the completed corrective actions the licensee had implemented were timely
and effective.
a. Completed Corrective Actions to Preclude Repetition
The licensee has one open corrective action to preclude repetition (CAPR) associated with
the root cause. This CAPR will be discussed in the planned corrective actions section below.
b. Other Completed Corrective Actions
The inspectors sampled other completed corrective actions (non-CAPRs) for the root cause
and contributing cause to determine the appropriateness and timeliness of the actions to
correct each cause documented in condition report CR-WF3-2024-04960. The inspectors
reviewed these completed corrective actions and did not have any concerns.
Cause
Corrective Action
Root Cause
The licensee updated controlled technical documents to
include vendor recommendations regarding alignment of the
lever arm; updated EDG job plans to include updated vendor
technical information, torque requirements, and thread
locking compounds; evaluated the design of the lever and
rod end to determine if a change would allow for greater
clearance margin; and evaluated adding a step to the EDG
pre-startup check procedure for operators to visually inspect
the governor and associated linkages.
Contributing Cause
The licensee developed and implemented a teach and learn
to reset and reinforce ownership and engagement in
improving maintenance department performance standards
and performed a benchmark to identify areas for improved
planning performance.
Objective: Ensure that pending corrective action plans direct prompt and effective actions to
address and preclude repetition of white performance issues.
Under this objective, the inspectors assessed the appropriateness and timeliness of the
licensees planned corrective actions.
NRC Assessment: The inspectors concluded that this objective was Met. The licensee
established one CAPR that addressed the root cause of insufficient details in the preventive
maintenance job plan for EDG A. When complete, the NRC plans to inspect and assess the
planned CAPR identified in Section a.
8
a. Planned Corrective Actions to Preclude Repetition
The licensee established one open CAPR that addressed the root cause of insufficient
details in the preventive maintenance job plan for EDG A. The inspectors reviewed the plan
for implementation and determined the licensee established an acceptable plan. The
planned implementation date for the CAPR is December 18, 2025, and the CAPR will
remain open pending further review by NRC inspectors.
Cause
Root Cause
Open CAPR 1: CR-WF3-2024-04960-00017
Create and implement a mechanical maintenance safety-related
continuous use procedure for replacement of the mechanical
governor and governor linkage rod ends for EDGs (A and B). Ensure
section 1.0 of the new procedure includes reference to this CAPR.
Incorporate all vendor documents (TD-C629 series, TD-W290.0075,
Woodward Manual 82340, and any other identified) including the
implementation of vendor standards (torque values, locking
compounds, configurations, and freedom of movement checks), listed
steps and sequence of steps, troubleshooting methods, and include
this root cause evaluation as operating experience.
Intent: Create a standard for the replacement of the mechanical
governor and rod ends for EDGs and to create consistent instructions
for successful outcomes in all future evolutions.
b. Other Planned Corrective Actions
The inspectors reviewed a sample of other planned corrective actions (non-CAPRs) for each
cause to determine the appropriateness and timeliness of the actions to correct each cause
documented in condition report CR-WF3-2024-04960. The inspectors did not have any
concerns with the planned corrective actions.
Cause
Corrective Action
Root Cause
The licensee planned actions to obtain higher quality vendor
documents to enhance document searchability and visual
clarity of drawings; actions for managers to review completed
critical component work orders and provide feedback to the
planning department; and actions to perform testing and
inspection of governor linkages associated with components
identified in the extent of condition review.
Contributing Cause
The licensee planned actions to perform a common cause
evaluation of the issues identified by the contributing cause to
determine why previous action plans did not result in
sustained improvement in the maintenance organizations
standards.
9
Conclusion
Overall, the inspectors determined that the licensees problem identification, causal analysis,
and corrective actions sufficiently addressed the performance issue that led to the White
finding regarding the failure to properly develop and implement adequate maintenance
instructions for the fuel linkage connection to the mechanical governor for EDG A. All
inspection objectives listed in Inspection Procedure 95001 were met, and this inspection is
closed. The open corrective action to preclude repetition will be inspected as part of the
ongoing NRC baseline inspection program.
INSPECTION RESULTS
(Discussed)
Waterford 95001 CAPR CR-WF3-2024-04960-00017
Create and Implement a Mechanical Maintenance
Procedure for Replacement of the Mechanical Governor
for the Emergency Diesel Generators
95001
Description:
Create and implement a mechanical maintenance safety-related continuous use procedure
for replacement of the mechanical governor and governor linkage rod ends for emergency
diesel generators (A and B). Ensure section 1.0 of the new procedure includes reference to
this CAPR.
Incorporate all vendor documents (TD-C629 series, TD-W290.0075, Woodward manual
82340, and any other identified) including the implementation of vendor standards (torque
values, locking compounds, configurations, and freedom of movement checks), listed steps
and sequence of steps, troubleshooting methods, and include this root cause evaluation as
operating experience.
Intent: Create a standard for the replacement of the mechanical governor and rod ends for
emergency diesel generators and to create consistent instructions for successful outcomes in
all future evolutions."
The inspectors reviewed the plan for implementation of this CAPR and determined that the
licensee established an acceptable plan. The licensee was tracking this CAPR in their
corrective action program as CR-WF3-2024-04960-00017 and had planned to implement this
CAPR by December 18, 2025, at the time of the onsite inspection.
This CAPR will remain open pending further review.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified that no proprietary information was retained or documented in this
report.
On September 25, 2025, the inspectors presented the 95001 supplemental inspection
results to David Oertling, General Manager Plant Operations, and other members of the
licensee staff.
10
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-WF3-
2020-03193, 2021-03144, 2023-00197, 2024-02159, 2024-
03700, 2024-03809, 2024-04960, 2025-01498, 2025-03905,
2025-03919, 2025-03921, 2025-03928, 2025-04410, 2025-
04439
Engineering
Changes
0054260328
EDG Linkage Washer Installation Detail Update
0
JA-PI-16
Sample Size Selection Guidance
1
Job Plan
00062289
Emergency Diesel Generator B Engine Control Governor B
Replacement
09/30/2025
Job Plan
00062291
Emergency Diesel Generator A Engine Control Governor A
Replacement
09/30/2025
Miscellaneous
TD-C629.0045
Cooper Bessemer KSV Diesel Generator Nuclear Power
Plant Emergency Stand-By Operation and Maintenance
Manual
2
Control of Engineering Documents
14
Preventive Maintenance Component Classification
24
Corrective Action Program
55
Causal Analysis Process
38
Planning
8
Work Implementation and Closeout
15
Planning
23
Procedures
OP-009-002
363
Self-Assessments
LO-WF3-2025-
00072
Pre-Inspection Assessment Worksheet for IP 95001
Inspection
08/15/2025
95001
Work Orders
WO 54199975, 54240437