IR 05000382/2025004: Difference between revisions
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| number = ML26033A350 | | number = ML26033A350 | ||
| issue date = 02/03/2026 | | issue date = 02/03/2026 | ||
| title = | | title = ISFSI - Integrated Inspection Report 05000382/2025004 07200075/2024001 and Exercise of Enforcement Discretion | ||
| author name = Dixon J | | author name = Dixon J | ||
| author affiliation = NRC/RGN-IV/DORS/PBD | | author affiliation = NRC/RGN-IV/DORS/PBD | ||
Revision as of 01:25, 21 February 2026
| ML26033A350 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 02/03/2026 |
| From: | John Dixon NRC/RGN-IV/DORS/PBD |
| To: | Sullivan J Entergy Operations |
| References | |
| EAF-NMSS-2025-0227, EA-NMSS-2023-0002 IR 2025004, IR 2024001 | |
| Download: ML26033A350 (0) | |
Text
February 03, 2026
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION - INTEGRATED INSPECTION REPORT 05000382/2025004, 07200075/2024001 AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Joseph Sullivan:
On December 31, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Waterford Steam Electric Station, Unit 3. On January 20, 2026, the NRC inspectors discussed the results of this inspection with you and other members of your staff.
The results of this inspection are documented in the enclosed report.
The NRC identified a violation of 10 CFR 72.48, paragraphs (c)(1), (c)(2), and (d)(1), and provisions of 10 CFR 72.212 that resulted from a Certificate of Compliance (CoC) holders failure to comply with 10 CFR 72.48 for a CoC holder-generated design change to its multipurpose canister (MPC) fuel basket, known as the continuous basket shim (CBS) variant, which altered the structural configuration from welded to bolted shims. However, an Interim Enforcement Policy (IEP) issued in August 2025 is applicable to this violation. Specifically, Enforcement Policy Section 9.4, Enforcement Discretion for General Licensee Adoption of Certificate of Compliance Holder-Generated Modifications under 10 CFR Part 72.48, provides enforcement discretion to not issue an enforcement action for this violation. The licensee will be expected to comply with 10 CFR 72.212 provisions after the NRC dispositions the noncompliance for a CoC holder-generated change that affects the General Licensee.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a non-cited violation (NCV)
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 IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Waterford Steam Electric Station, Unit 3.
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 IV; and the NRC Resident Inspector at Waterford Steam Electric Station, Unit 3.
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, John L. Dixon Jr., Chief Reactor Projects Branch D Division of Operating Reactor Safety Docket No. 05000382 and 07200075 License No. NPF-38
Enclosure:
As stated
Inspection Report
Docket Number:
05000382 AND 07200075
License Number:
Report Number:
05000382/2025004 and 07200075/2024001
Enterprise Identifier:
I-2025-004-0003 and I-2024-001-0120
Licensee:
Entergy Operations, Inc.
Facility:
Waterford Steam Electric Station, Unit 3 and ISFSI
Location:
Killona, LA
Inspection Dates:
October 1, 2025, to December 31, 2025
Inspectors:
L. Brookhart, Senior Spent Fuel Storage Inspector
K. Chambliss, Senior Resident Inspector
K. Cook-Smith, Resident Inspector
R. Deese, Senior Reactor Analyst
J. Freeman, Resident Inspector
S. Hedger, Senior Emergency Preparedness Inspector
L. Moore, Emergency Preparedness Inspector
C. Young, Senior Reactor Analyst
Approved By:
John L. Dixon Jr., Chief
Reactor Projects Branch D
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated 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. A licensee-identified non-cited violation is documented in report Section: 71114.0
List of Findings and Violations
Failure to Take Risk Mitigative Actions for Maintenance Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2025004-01 Open/Closed
[H.12] - Avoid Complacency 71111.04 The inspectors identified a Green finding and associated non-cited violation of 10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for the failure of the licensee to manage risk during maintenance.
Specifically, the licensee failed to display adequate protected equipment postings as required per licensee Procedure EN-OP-119, Protected Equipment Postings, Revision 19.
Additional Tracking Items
Type Issue Number Title Report Section Status EDG EAF-NMSS-2025-0227 Interim Enforcement Policy Discretion Associated with the Continuous Basket Shim Design Change 60855 Closed LER 05000382/2024-004-00 Automatic Reactor Trip Due to Lightning Strike 71153 Closed LER 05000382/2024-004-01 Automatic Reactor Trip due to Lightning Strike 71153 Closed
PLANT STATUS
Unit 3 began the inspection period at 94 percent rated thermal power. On November 10, 2025, the unit was lowered to 90 percent rated thermal power for maintenance. On November 11, 2025, the unit was raised to 94 percent rated thermal power and remained at 94 percent rated thermal power for the remainder of the inspection period.
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 performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)essential chilled water A and B and AB on October 14, 2025 (2)emergency diesel generator train A on October 29, 2025 (3)low-pressure safety injection train A on November 12, 2025 (4)auxiliary component cooling water train A on November 14, 2025 (5)high-pressure safety injection and containment spray train B on December 3, 2025 (6)controlled ventilation area system trains A and B on December 18, 2025
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
(1)fire area reactor auxiliary building 15-001, elevation +21.00' emergency diesel generator 3B on October 14, 2025 (2)fire area reactor auxiliary building 2-001, elevation +46.00 H&V mechanical room on October 16, 2025 (3)fire area reactor auxiliary building 38-001, elevation -35.00' motor driven emergency feed pump room B on October 16, 2025 (4)fire area reactor auxiliary building 35-001, elevation -35.00' safety injection pump room B on October 17, 2025 (5)fire area reactor auxiliary building 41-001, elevation -35.00 diesel storage tank B on October 23, 2025
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated internal flooding mitigation protections in zone 2 safeguards A and zone 2 safeguards B rooms on -35' elevation of the reactor auxiliaries building on October 22, 2025.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during control element assembly testing on December 13, 2025.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated graded requalification training scenario with simulated emergency declarations on October 21, 2025.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
(1)programmatic review of eight maintenance rule (a)(1) evaluations resulting from exceeding thresholds for condition monitoring events and review of subsequent maintenance rule function monitoring statuses on December 10, 2025 (2)maintenance rule scoping and monitoring of temporary equipment fulfilling the maintenance rule functions including the usage of temporary air compressors fulfilling both trains of instrument air on December 30, 2025
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)
The inspectors evaluated the licensees justifications and actions associated with the following operability determinations and functionality assessments:
(1)emergency diesel generator A and B potentiometers on November 6, 2025 (2)review of past operability determination for the seismic impact of a component cooling water heat exchanger B flow control valve missing taper pin on December 29, 2025
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (3 Samples)
(1)post-maintenance testing following repairs of essential chiller AB on October 22, 2025 (2)post-maintenance testing following extensive maintenance outage on emergency diesel generator train A on November 7, 2025 (3)post-maintenance testing on auxiliary component cooling pump A following pump maintenance and breaker swap on December 3, 2025
71114.01 - Exercise Evaluation
Inspection Review (IP Section 02.01-02.11) (1 Sample)
- (1) The inspectors evaluated the biennial emergency plan exercise conducted on November 18, 2025. The exercise scenario simulated seismic event (Operational Basis Earthquake) resulting in several equipment failures (dry cooling tower fan trip, startup feedwater regulator valve closure); followed by a reactor coolant system leak.
Aftershocks in the plant area led to a loss of offsite power and one emergency diesel generator's failure to run. The reactor coolant system leak worsened, resulting in a reactor trip and safety injection system actuation due to the loss of coolant accident.
Reactor vessel coolant level was at such a reduced level it resulted in the evaluation that the fuel clad barrier was lost. A low-pressure safety injection pump bearing failure occurred. Finally, a containment penetration break developed, resulting in a simulated radiological release path offsite involving response organization evaluation versus protective action guidelines.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes.
- Waterford 3 Steam Electric Station, Updated Alert/Notification System Design Report, Revision 10 [NRC notified on May 14, 2025 (ML25134A136)]
- Waterford 3 Emergency Plan, Revision 53 [NRC notified on July 14, 2025 (ML25196A279)]
- EP-001-001, Recognition and Classification of Emergency Conditions, Revision 38 [NRC notified on October 8, 2025 (ML25281A009)]
This evaluation does not constitute NRC approval.
71114.08 - Exercise Evaluation - Scenario Review
Inspection Review (IP Section 02.01 - 02.04)
The licensee submitted the exercise scenario on September 17, 2025, as required per 10 CFR Part 50, Appendix E.IV.F.2.b. However, the scenario was not reviewed per NRC Inspection Procedure 71114.08 as the review period occurred during the 2025 government shutdown. Note that this review is not required by regulation. It is completed as part of the Reactor Oversight Process with the goal of ensuring that exercise scenarios are reviewed allowing time for the licensee to make any recommended changes prior to conducting the exercise if necessary. The inspection of the exercise per NRC Inspection Procedure 71114.01 will ensure that all applicable regulatory requirements have been met, which will also ensure that the scenario was adequate to meet these requirements.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===
- (1) October 1 2024, through September 30, 2025
BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)
- (1) October 1 2024, through September 30, 2025
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
- (1) October 1, 2024, through September 30, 2025 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
- (1) October 1, 2024, through September 30, 2025 EP04: Emergency Response Facility and Equipment Readiness (ERFER) (IP Section 02.14) (1 Sample)
- (1) January 1, 2025, through September 30, 2025
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees corrective action program to identify potential trends in the work planning that might be indicative of a more significant safety issue.
Specifically, the inspectors reviewed the system health of the work planning process for both preventive and corrective maintenance including: review of condition reports related to work planning process, interviewed individuals responsible for each stage of work planning, and reviewed the required training to execute all phases of the work planning process. The inspectors determined the sites response to recent issues within the work planning process was adequate. No more than minor issues were identified.
71153 - Follow-Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000382/2024-004-01, Automatic Reactor Trip due to Lightning Strike (ADAMS Accession No. ML25226A260). The inspectors reviewed the updated LER submittal.
The previous LER submittal was reviewed in Inspection Report 05000382/2024040 (ML25023A150). The inspectors determined that the cause of the condition described in the LER was not reasonably within the licensee's ability to foresee and correct, and therefore, was not reasonably preventable. No performance deficiency nor violation of NRC requirements was identified. This LER is Closed.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
===60855 - Operation of an Independent Spent Fuel Storage Installation The inspectors performed a follow-up review of the licensees independent spent fuel storage installation (ISFSI) activities to verify conformance with regulatory requirements.
Operation of an Independent Spent Fuel Storage Installation===
- (1) In accordance with Inspection Procedure 60855, Section 04.03, inspectors performed an in-office follow-up review of Waterford's acceptance and use of Holtec canisters with the continuous basket system (CBS) variant design change. The inspector focused on the review of the licensees implementation of the 10 CFR 72.48 process and associated corrective actions related to the CBS canisters.
INSPECTION RESULTS
Enforcement Discretion Enforcement Action EAF-NMSS-2025-0227: Interim Enforcement Policy discretion associated with the Continuous Basket Shim design change 60855
Description:
Holtec International (also referred to as the Certificate of Compliance (CoC) holder) implemented a design change to its multi-purpose canister (MPC) fuel basket, known as the continuous basket shim (CBS) variant, which altered the structural configuration from welded to bolted shims. This change resulted in a departure from the method of evaluation (MOE) described in the Final Safety Analysis Report (FSAR) used to establish the design basis for tip-over events. Holtec did not fully evaluate the cumulative impact of the MOE changes or apply them consistently within the licensing basis. As a result, the NRC issued three Severity Level IV violations to Holtec for noncompliance with 10 CFR 72.48 requirements (see NRC Inspection Reports 07201014/2022-201, Holtec International (ADAMS Accession No. ML23145A175) and 07201014/2022-201, Holtec International, Inc. -
Notice of Violation (ML24016A190)).
When the licensee (also referred to as a General Licensee) chooses to adopt a change the CoC holder made pursuant to a CoC holder's change authority under 10 CFR 72.48 (referred to herein as a CoC holder-generated change), the licensee must perform a separate review using the requirements of 10 CFR 72.48(c). Accordingly, when the licensee chooses to adopt a CoC holder-generated change, and that change results in a non-conforming cask, there is a violation of 10 CFR 72.48 and certain provisions of 10 CFR 72.212 by the licensee, in addition to a CoC holder violation of 10 CFR 72.48.
In support of the 2023 loading campaign, the licensee adopted Holtecs generic design change, as documented in Waterford's 72.48 Evaluation #1574, and subsequently loaded casks using the CBS basket design. Because the CoC holder-generated change was found to be noncompliant by the NRC, the loaded casks at the Waterford Nuclear Station were also rendered non-conforming.
Corrective Actions: The licensee entered this into their corrective action program with actions to restore compliance with the 10 CFR 72.212 provisions that require each cask to conform to the terms, conditions, and specifications of a CoC or an amended CoC listed in 10 CFR 72.214.
Corrective Action References: CR-WF3-2024-03372
Enforcement:
Significance/Severity: The licensees failure to request that the CoC holder obtain an amendment prior to implementing the change was determined to be of Severity Level IV significance based on the guidance in Section 1.2.6.D of the NRC's Enforcement Manual.
The severity of the violation was determined based on its very low safety significance, as documented in NRC memorandum titled Safety Determination of a Potential Structural Failure of the Fuel Basket During Accident Conditions for the HI-STORM 100 and HI-STORM Flood/Wind Dry Cask Storage Systems (ML24018A085) and its similarity with violation example 6.1.d.2 in the NRCs Enforcement Policy.
Violation: Title 10 CFR 72.48(c)(1) requires, in part, the licensee or certificate holder may make changes in the facility or spent fuel storage cask design as described in the FSAR (as updated), without obtaining:
- (ii) CoC amendment submitted by the certificate holder pursuant to § 72.244 if:
- (c) The change, test, or experiment does not meet any of the criteria in paragraph (c)(2) of this section.
Title 10 CFR 72.48(c)(2) requires, in part, a general licensee shall request that the certificate holder obtain a CoC amendment, prior to implementing a proposed change, if the change would: (viii) Result in a departure from an MOE described in the FSAR used in establishing the design bases or in the safety analyses.
Title 10 CFR 72.48(d)(1) requires, in part, the licensee shall have a written evaluation which provides the bases for the determination that the change does not require a CoC amendment pursuant to 72.48(c)(2).
Title 10 CFR 72.212(b)(3) requires, in part, a general licensee must ensure that each cask used by the general licensee conforms to the terms, conditions, and specifications of a CoC or an amended CoC listed in 72.214.
Contrary to the above, since the 2023 loading campaign, the licensee failed to:
- (1) request Holtec, the certificate holder, obtain a CoC amendment for a change to the CBS cask design that resulted in a departure from an MOE described in the FSAR;
- (2) have a written evaluation providing the bases for the determination that the adopted change did not require a CoC amendment; and
- (3) ensure that the affected casks conformed to the terms, conditions, and specifications of the applicable CoC.
Specifically, Waterfords 10 CFR 72.48 #1574 titled Implementation of Holtec's HI-STORM FW System at Waterford Steam Electric Station Unit 3 (WF3) failed to identify that the CBS variant design change resulted in a departure from a method of evaluation described in the FSAR used in establishing the design bases, failed to request the certificate holder obtain a CoC amendment pursuant to 10 CFR 72.244, and failed to ensure each cask conformed to the terms conditions, and specifications of a CoC or an amended CoC listed in 72.214, prior to using the CBS variant design.
Basis for Discretion: Section 9.4 of the Enforcement Policy, titled Enforcement Discretion for General Licensee Adoption of Certificate of Compliance Holder-Generated Changes under 10 CFR 72.48 (ML25224A097), states the NRC will exercise enforcement discretion and not issue an enforcement action to a General Licensee, for a noncompliance with the requirements of paragraphs (c)(1) and
- (2) and (d)(1) of 10 CFR 72.48 and with provisions of 10 CFR 72.212 that require General Licensees to ensure use of casks that conform to the terms, conditions, and specifications of a CoC listed in 10 CFR 72.214, when the noncompliance results from a CoC holders failure to comply with 10 CFR 72.48 for a CoC holder-generated change. In support of the 2023 loading campaign, the licensee adopted a generic CoC holder design change (the CBS basket variant) and subsequently loaded the casks. On January 30, 2024, the NRC issued a notice of violation to the CoC holder, identifying the noncompliance, for the generic design change associated with the CBS basket variant (ML24016A190). As a result, the licensee became noncompliant due to the CoC holders failure to comply with 10 CFR 72.48 for the CoC holder-generated change. Since this violation meets the criteria of Section 9.4 of the policy, the NRC is exercising enforcement discretion by not issuing an enforcement action for this violation.
Failure to Take Risk Mitigative Actions for Maintenance Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2025004-01 Open/Closed
[H.12] - Avoid Complacency 71111.04 The inspectors identified a Green finding and associated non-cited violation of 10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for the failure of the licensee to manage risk during maintenance.
Specifically, the licensee failed to display adequate protected equipment postings as required per licensee Procedure EN-OP-119, Protected Equipment Postings, Revision 19.
Description:
On October 7, 2025, during a walkdown of the reactor auxiliary building, inspectors noted that essential chiller AB was being protected by operations. Inspectors verified this by reviewing the licensees tagging system that tracks protected equipment posting. However, chillers A and B were running, not chiller AB. During this walkdown, an individual was observed specifically interacting with chiller B and the surrounding area.
The inspectors informed operations of this condition. Upon discussion with operations personnel, chiller AB had previously been running, on October 6, 2025, but was secured in favor of running chiller B while planned maintenance was being conducted on chiller A.
During this maintenance, chiller A was declared inoperable and only chiller B was operable.
Technical Specification (TS) 3.7.12 was entered for approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> for this condition - a 72-hour shut down action statement. The protected equipment postings were not changed to protect chiller B during this maintenance.
According to licensee Procedure EN-OP-119, Protected Equipment Postings, Revision 19, Section 5.2, when the loss of the redundant component or system would result in a Technical Specifications action statement that requires an immediate plant shutdown (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less) and not performing a surveillance...then protect the component or system.
Loss of the redundant chiller B would have entered TS 3.0.3 - a 7-hour shutdown action statement. Operational risk was not mitigated to guard against personnel inadvertently operating or disabling a component or system that is credited for maintaining safety margins.
Corrective Actions: The licensee correctly posted essential chiller B as protected equipment in accordance with Procedure EN-OP-119. The licensee then initiated a condition report to enter this issue into the corrective action program.
Corrective Action References: Condition Report CR-WF3-2025-04630
Performance Assessment:
Performance Deficiency: The failure to adequately mitigate risk during plant operations as required by 10 CFR 50.65(a)(4) was a performance deficiency that was within the licensees ability to foresee and correct. Specifically, the licensee failed to post protected equipment postings on essential chiller B as required by Procedure EN-OP-119, Protected Equipment Postings, Revision 19, Section 5.2.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Configuration Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensees failure to display protected equipment postings on chiller B could result in inappropriate work in that area and the loss of redundant chilled water systems.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management SDP. Because the performance deficiency was related to inadequate risk management actions (RMAs), the inspectors were directed to IMC 0609, Appendix K, Flowchart 2, Assessment of RMAs. The inspectors determined the finding to be of very low safety significance (Green) because the incremental core damage probability for the maintenance was less than 1E-6.
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, when the equipment lineup was changed in support of maintenance on chiller A, the inherent risk of the change was not understood and error reduction tools were not in place, which resulted in the correct risk mitigative actions not being implemented.
Enforcement:
Violation: Title 10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, requires, in part, licensees manage the increase in risk that may result from maintenance activities.
Contrary to the above, on October 6, 2025, the licensee failed to mitigate the risk of personnel inadvertently operating or disabling a component during maintenance activities in accordance with their procedure. Specifically, the redundant essential chiller B was not protected in accordance with Procedure EN-OP-119, Revision 19, Section 5.2 to mitigate risk during maintenance of essential chiller A.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Licensee-Identified Non-Cited Violation 71114.04 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: Title 10 CFR 50.54(q)(2) requires, in part, a holder of a license under this part shall maintain the effectiveness of an emergency plan that meets the requirements in Appendix E to this part and the planning standards of 50.47(b). Planning standard 10 CFR 50.47(b)(4)requires, in part, a standard emergency classification and action level scheme is in use by the nuclear facility licensee. Contrary to the above, from July 28, 2021, to November 25, 2024, the licensee failed to maintain the effectiveness of an emergency plan which met the requirements in Appendix E to this part and the planning standards of 10 CFR 50.47(b).
Specifically, the licensee failed to maintain a standard emergency classification scheme as required by 10 CFR 50.47(b)(4) because Procedure EP-001-001, Recognition and Classification of Emergency Conditions, Revisions 35 through 37, contained emergency classification thresholds in EAL EU1.1 that in cases rendered it deficient such that an Unusual Event would be declared for a particular off-normal event prior to the appropriate classification thresholds being met (over-classification).
Significance/Severity: Green. The finding was evaluated using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, issued September 22, 2015, and determined to be of very low safety significance (Green) because it was a failure to comply with NRC requirements, was associated with a risk-significant planning standard, and was not a lost or degraded planning standard function.
Corrective Action References: Condition Report CR-WF3-2025-05043
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On December 16, 2025, the inspectors presented the ISFSI follow-up review related to Continuous Basket System (CBS) canister design inspection results to John Twarog, Regulatory and Emergency Planning Manager, and other members of the licensee staff.
- On January 7, 2026, the inspectors presented the emergency preparedness exercise inspection results to Joseph Sullivan, Site Vice President, and other members of the licensee staff.
- On January 20, 2026, the inspectors presented the integrated inspection results to Joseph Sullivan, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
60855
Corrective Action
Documents
CR-WF3-2024-
NNNN
03372
Corrective Action
Documents
CR-WF3-2025-
NNNN
4630, 4708, 5115, 5116
DWG 1564-72
High Pressure Safety Injection Pump General Arrangement
DWG 1564-755
Containment Spray Pump
DWG 1564-85
Low Pressure Safety Injection Pump General Arrangement
LOU-1564-G-163,
Sheet 1
Flow Diagram Containment Spray and Refueling Water
Storage Pool
Drawings
LOU-1564-G-167,
Sheets 1 and 2
Flow Diagram Safety Injection System
OP-002-004
Chilled Water System
27
OP-009-008
Safety Injection System
Procedures
OP-903-052
Controlled Ventilation Area System Operability Check
RAB 15-001
Emergency Diesel Generator 2B Reactor Auxiliary Building
+21.00' Elevation
RAB 35-001
Safety Injection Pump Room B Reactor Auxiliary Building -
35.00' Elevation
Drawings
RAB 38-001
Motor Driven Emergency Feed Pump Room B Reactor
Auxiliary Building -35.00' Elevation
CT 4-001
Wet Cooling Tower B
RAB 2-001
H&V Mechanical Room
Fire Plans
RAB 41-001
Diesel Storage Tank B
ECM15-004
Waterford 3 FLEX Internal Flooding Calculation
MNQ3-5
Flooding Analysis Outside Containment
Calculations
WF3-CS-15-
00009
Beyond Design Basis External Event Internal Flooding
Evaluation of Non-Seismic Water Sources
Corrective Action
Documents
CR=WF3-2025-
NNNN
05557
Emergency Classifications
Conduct of Operations
Procedures
Time Critical Action Program Standard
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
24-05843, 2024-05829, 2024-02663, 2024-02172, 2024-
2566, 2024-02567, 2024-02536, 2023-14740, 2023-01376,
24-00689, 2024-00773, 2024-01018, 2024-01634, 2024-
03729, 2024-05639, 2024-05640, 2024-05933, 2023-15615
Condition Monitoring of Maintenance Rule Structures
Maintenance Rule Scope and Bias
Procedures
Maintenance Rule (A)(1) Process
Calculations
SQ-MN-7
Fisher Control Valves 12"
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
25-01961, 2025-03529, 2025-04842,
0054326190
Emergency Diesel Generator Motor-Operated-
Potentiometer/Power-Operated-Potentiometer Dual to Single
Engineering
Changes
EC Reply to Address ACC-126B Taper Pin Past Operability
Seismic Concerns
Procedures
Operability Determination Process
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
2008-05564, 2022-01221, 2025-03147, 2025-03151, 2025-
214, 2025-03726, 2025-03799, 2025-03863, 2025-03979,
25-04458, 2025-04477, 2025-04666
Drawings
TD-C150.0095
Carrier Start-Up & Operation and Maintenance Instructions
for 19F Hermetic Centrifugal Liquid Chillers, Form 19FA-2SS
OP-903-118
Primary Auxiliaries Quarterly IST Valve Tests
Procedures
OP-903-118
Primary Auxiliaries Quarterly IST Valve Tests
Work Orders
WO 2790253, 53019917, 54119351, 54202737, 54291159,
293283, 54306734
CR-WF3-YYYY-
NNNN
22-00054, 2022-00114, 2024-02339, 2024-03291, 2024-
03458, 2024-03866, 2024-04189, 2024-06044, 2025-02182,
25-05220, 2025-05222, 2025-05235, 2025-05254, 2025-
258, 2025-05260, 2025-05300, 2025-05315, 2025-05319,
25-05538
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
23-13779, 2024-01084, 2024-03999, 2024-04898, 2024-
05373, 2024-05717, 2024-05883, 2025-00827, 2025-01064,
25-01292
Miscellaneous
Management Debrief, 11/18/2025 NRC /FEMA Evaluated
2/16/2025
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Exercise
Offsite Dose Assessment Using the Unified RASCAL
Interface
Emergency Operations Facility (EOF) Operations
EN-EP-612-04
WF3 Joint Information Center (JIC)
Recognition and Classification of Emergency Conditions
Site Area Emergency
311
Notifications and Communications
317
Offsite Dose Assessment
309
Procedures
Protective Action Guidelines
Work Orders
WO 577195, 51452833, 51452834, 53008255, 54072561,
54158575, 54161155, 54228106, 54289082
ECI92-006
ESF-Containment Pressure Instrumentation Loop
Uncertainty Calculation
ECI92-007
ESF-Containment Pressure (Wide Range) Instrumentation
Loop Uncertainty Calculation
ECI98-007
OP-903-001 and OP-903-013 Channel Check Tolerance
Determination
Calculations
ECS98-001
EOP Action Value Basis Document
8, 9
Condition Reports
(CR-ANO-C-)
24-01642
Corrective Action
Documents
Condition Reports
(CR-WF3-)
24-04793, 2024-05043, 2025-03492
CFR 50.54(q)(3) Screening - Procedure/Document
Number: EP-001-001, Revision: 38,
Equipment/Facility/Other: Waterford 3, Title: Recognition and
Classification of Emergency Conditions
10/24/2024
CFR 50.54(q)(3) Evaluation - Procedure/Document
Number: EP-001-001, Revision: 38,
Equipment/Facility/Other: Waterford 3, Title: Recognition and
Classification of Emergency Conditions
10/28/2024
Miscellaneous
CFR 50.54(q)(3) Screening - Procedure/Document
Number: N/A, Revision: 10, Equipment/Facility/Other:
Waterford 3 Steam Electric Station (SES), Title: Waterford-3
05/09/2025
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Steam Electric Station Updated Alert/Notification System
Design Report
CFR 50.54(q)(3) Evaluation - Procedure/Document
Number: N/A, Revision: N/A, Equipment/Facility/Other:
Waterford 3 Steam Electric Station (SES), Title: Change in
Available Helicopter Vendors for EPlan Support
2/13/2025
CFR 50.54(q)(3) Evaluation - Procedure/Document
Number: N/A, Revision: 053, Equipment/Facility/Other:
Waterford 3, Title: Waterford 3 SES Emergency Plan
06/05/2025
CFR 50.54(q)(3) Screening - Procedure/Document
Number: N/A, Revision: 053, Equipment/Facility/Other:
Waterford 3, Title: Waterford 3 SES Emergency Plan
06/05/2025
Emergency Preparedness Updated Alert/Notification System
(ANS) Design Report, Revision 10, September 2024;
Waterford Steam Electric Station, Unit 3; Docket No. 50-382;
Renewed Facility Operating License No. NPF-38
05/14/2025
Emergency Plan Revision 053, Waterford Steam Electric
Station, Unit 3; Docket No. 50-382; Renewed Facility
Operating License No. NPF-38
07/14/2025
Emergency Preparedness Procedure Update, Waterford
Steam Electric Station, Unit 3; Docket No. 50-382; Renewed
Facility Operating License No. NPF-38
10/07/2025
WOTH-OPS-
2KICKOFF
25 Cycle 2 LOR/AOR Kickoff
DFS-007-003
Radiation Protection Requirements for Loading and Storage
HI-STORM
9-12
Procedures
Emergency Planning 10CFR50.54(q) Review Program
Emergency Preparedness Full Participation Exercise
Scenario; Waterford Steam Electric Station, Unit 3; Docket
No. 50-382; Renewed Facility Operating License No. NPF-
04/24/2023
Miscellaneous
Emergency Preparedness Exercise Scenario; Waterford
Steam Electric Station, Unit 3; Docket No. 50-382; Renewed
Facility Operating License No. NPF-38
09/17/2025
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Recognition and Classification of Emergency Conditions
Notifications and Communications
317
Offsite Dose Assessment
309
Procedures
Protective Action Guidelines
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
24-05736, 2025-01142, 2025-01495, 2025-03303, 2025-
03836, 2025-04138, 2025-04490, 2025-04536, 2025-04625,
25-04629
Emergency Response Facility and Equipment Readiness
(ERFER)
ERFER
3Q2025
WF3 1st QTR 2025 Green EOF Cold Shutdown EAL
Scenario
2/12/2025
Red Team Drill
03/18/2025
4th Qtr 2024 Orange Team EOF Tabletop
11/20/2024
WSXM-LOR-246DEPSIM
11/19/2024
WSIM-LOR-246SM1
10/15/2024
25-01EC
04/03/2025
24-01EC
04/03/2025
WF3 Green Team 3Q2025 EOF Tabletop
07/23/2025
WSXM-LOR-255ECPE2
09/29/2025
Blue Team Site Drill
08/12/2025
BI-01
Waterford 3 Performance Indicator Data
BI-02
Waterford 3 Performance Indicator Data
DEP-EBN Report
4Q2024, 1Q2025, 2Q2025, 3Q2025
EBN ERO Roster
4Q2024 (31 Dec 2024), 1Q2025 (31 Mar 2025), 2Q2025
(30 Jun 2025), 3Q2025 (30 Sep 2025)
Miscellaneous
Qualifications
Matrix
4Q2024, 1Q2025, 2Q2025, 3Q2025
EN-FAP-EP-005
Emergency Preparedness Indicators
Regulatory Performance Indicator Process
71151
Procedures
Emergency Operations Facility (EOF) Activation, Operation
and Deactivation
311
Corrective Action
CR-WF3-2025-
3902, 4022, 4244, 4459, 4460, 4461, 4464, 4462, 4466,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
NNNN
4502
Procedures
Planning
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
24-03067, 2024-03099