ML25349A046

Waterford Steam Electric Station - Integrated Inspection Report 05000382/2025003

ML25349A046
Person / Time
Site:	Waterford
Issue date:	12/17/2025
From:	John Dixon NRC/RGN-IV/DORS/PBD
To:	Sullivan J Entergy Operations
References
IR 2025003
Download: ML25349A046 (0)

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 - INTEGRATED INSPECTION REPORT 05000382/2025003

Dear Joseph Sullivan:

On September 30, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Waterford Steam Electric Station, Unit 3. On December 3, 2025, the NRC inspectors discussed the results of this inspection with David Oertling, General Manager of Plant Operations, and other members of your staff. The results of this inspection are documented in the enclosed report.

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.

Three findings of very low safety significance (Green) are documented in this report. Three 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.

Two licensee-identified violations which were determined to be of very low safety significance are documented in this report. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

J. Sullivan 2

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 License No. NPF-38

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV Signed by Dixon, John on 12/16/25

ML25349A046 SUNSI Review By: AAS Publicly Available and Non-Sensitive Non-Publicly Available and Sensitive Keyword NRC-002 OFFICE SRI:DORS/PBD RI: DORS/PBD SPE: DORS/PBD BC: DORS/PBD NAME KChambliss KCook-Smith ASanchez JDixon SIGNATURE

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/RA/

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DATE 12/15/25 12/15/25 12/15/25 12/16/25

Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:

05000382 License Number:

NPF-38 Report Number:

05000382/2025003 Enterprise Identifier:

I-2025-003-0003 Licensee:

Entergy Operations, Inc.

Facility:

Waterford Steam Electric Station, Unit 3 Location:

Killona, LA 70057 Inspection Dates:

July 1, 2025, to September 30, 2025 Inspectors:

B. Baca, Health Physicist K. Chambliss, Senior Resident Inspector K. Cook-Smith, Resident Inspector N. Denney, Health Physicist D. Grau, Health Physicist N. Greene, Senior Health Physicist C. Harrington, Senior Operations Engineer K. Murphy, Operations Engineer J. O'Donnell, Senior Health Physicist A. Sanchez, Senior Project Engineer 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 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. Licensee-identified non-cited violations are documented in report Sections: 71111.12 and 71111.15.

List of Findings and Violations Failure to Identify and Correct a Condition Adverse to Quality Affecting the Emergency Lighting System Cornerstone Significance Cross-Cutting Aspect Report Section Not Applicable Green NCV 05000382/2025003-01 Open/Closed

[H.2] - Field Presence 71111.15 The inspectors identified a Green finding and associated non-cited violation of Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action. Specifically, the licensee failed to identify and correct a condition adverse to quality with respect to emergency lighting. The failure to identify and correct these deficiencies led to inadequate lighting in Safe Shutdown spaces per licensee Engineering Change EC-86633, Emergency DC Lighting Self-Contained Battery Pack Maintenance Rule Light Areas, which delineates what lighting is required for safe shutdown during a station blackout event.

Inadequate Troubleshooting of Charging Pump A Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2025003-02 Open/Closed

[P.3] -

Resolution 71153 A self-revealed finding of very low safety significance (Green) and an associated non-citied violation of Technical Specification 3.4.3.2 was identified when the licensee failed to ensure operability of two independent trains of auxiliary pressurizer spray in accordance with technical specifications. Specifically, the licensee failed to identify and correct a degraded lube oil pump for safety-related charging pump A. This resulted in the pump being inoperable for greater than the allowed outage time specified in Technical Specifications 3.4.3.2, a condition prohibited by the licensees technical specifications.

Inadequate Foreign Material Exclusion Practices Leading to the Inoperability of Auxiliary Component Cooling Water Pump A Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2025003-03 Open/Closed

[H.12] - Avoid Complacency 71153 A self-revealed finding of very low safety significance (Green) and an associated non-citied violation of Technical Specifications 6.8.1.a, Instructions, Procedures, and Drawings, was identified for the licensees failure to implement maintenance that can affect the performance

3 of safety-related equipment without properly preplanning and performing the maintenance in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Specifically, the failure to include cleaning of oil piping of the safety-related auxiliary component cooling water pump A following a mechanical seal replacement due to a leak as specified in the vendor technical document. This resulted in foreign material causing a significant oil leak and resulting in the pump being declared inoperable for a period greater than its allowed technical specifications outage time, a condition prohibited by technical specifications.

Additional Tracking Items Type Issue Number Title Report Section Status LER 05000382/2025-002-00 Auxiliary Pressurizer Spray Train Inoperable Resulting in a Condition Prohibited by Technical Specifications 71153 Closed LER 05000382/2025-003-00 Auxiliary Component Cooling Water Train Inoperable Resulting in a Condition Prohibited by Technical Specifications 71153 Closed

4 PLANT STATUS Unit 3 began the inspection period at 91 percent rated thermal power. On September 4, 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) (2 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) component cooling water train B on August 29, 2025 (2) 125 V direct current battery train B on September 30, 2025 71111.05 - Fire Protection Fire Area Walkdown and Inspection Sample (IP Section 03.01) (1 Sample)

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) assessment of fire door operability for safety-related boundaries and barriers in radiologically controlled areas, reactor area buildings, and switchgear rooms on August 29, 2025 Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1)

The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill on August 14, 2025.

5 71111.07A - Heat Exchanger/Sink Performance Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) component cooling water dry cooling tower heat transfer capabilities on August 29, 2025 71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance Requalification Examination Results (IP Section 03.03) (1 Sample)

(1)

The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam and biennial written examinations on August 18, 2025.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)

(1)

Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on July 17, 2025.

Annual Requalification Operating Tests The inspectors evaluated the adequacy of the licensees annual requalification operating test.

Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.

Requalification Examination Security The inspectors evaluated the ability of the licensee to safeguard examination material, such that the examination is not compromised.

Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.

Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators

6 meet the conditions of their licenses.

Control Room Simulator The inspectors evaluated the adequacy of the licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.

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 emergency diesel generator train B overspeed testing and post-maintenance activities following an extended maintenance window on August 24, 2025.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1)

The inspectors observed and evaluated a licensed operator requalification simulator scenario on September 15, 2025.

71111.12 - Maintenance Effectiveness Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:

(1) startup transformer A phase C high-side bushing oil leak and missing test port cap on September 26, 2025 71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) safe shutdown and emergency egress lighting on September 10, 2025 (2) charging pump B reduced flow and oscillating and erratic amps on September 25, 2025 (3) charging pump A repeated tripping on low lube oil pressure on September 26, 2025 (4)

Rosemount transmitters found in a non-environmentally qualified configuration on September 26, 2025 (5) auxiliary component cooling water train B header outlet isolation valve stem leakage on September 26, 2025 (6) battery charger AB abnormal noise during current limit testing on September 30, 2025

7 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) (2 Samples)

(1) emergency diesel generator train B post-maintenance testing following replacement of voltage regulator relays, intercooler, sling rings, and cylinder adjustments on September 25, 2025 (2) power supply replacement for reactor trip train B on September 30, 2025 Surveillance Testing (IP Section 03.01) (2 Samples)

(1) emergency feedwater pump A surveillance testing on September 30, 2025 (2) missed excore nuclear instrument and airlock door leakage test surveillances on September 30, 2025 Inservice Testing (IST) (IP Section 03.01) (1 Sample)

(1) auxiliary component cooling water train B pump and valve inservice test on September 26, 2025 71114.06 - Drill Evaluation Additional Drill and/or Training Evolution (2 Samples)

The inspectors evaluated:

(1) an emergency preparedness drill involving high airborne radiation on August 12, 2025.

(2) full scale rehearsal drill for biennial inspection on September 24, 2025 RADIATION SAFETY 71124.05 - Radiation Monitoring Instrumentation Walkdowns and Observations (IP Section 03.01) (5 Samples)

The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:

(1) area radiation monitors; control room ARMIRE-5001; control room air ARMIRE-0200.2; auxiliary building HVAC +46 ARMIRE-5002; fuel pool pump hall ARMIRE-5012; post LOCA ARMIRE-5029 and ARMIRE-5030; hot machine shop ARMIRE-5132; decon facility ARMIRE-5144 (2) portable survey instruments: friskers CHP-CR-372, CHP-CR-130, and CHP-CR-113; ion chamber CHP-DR-658; telepole CHP-TEL153; air sample pump HP-AS-195, continuous air monitor HP-RD-264, HP-RD-306, and CHP-AMS-D071

8 (3) stationary radiation monitors: portal monitor(s) HP-DS-088 and HP-DS-107; personal contamination monitor(s) HP-DS-096 and HP-DS-089, tool and equipment monitor(s)

HP-DS-093 and HP-DS-110 (4) laboratory instrumentation; gamma spectroscopy Detector(s) 4, 5, and 6; liquid scintillation counter A and B; iSolo HP-CS-018; Model 3030 CHP-C-051 (5) process radiation monitors: auxiliary building duct monitor(s) PRMIRE-6710 A, B, C and D; component cooling water PRMIRE-5700; gas waste monitor PRMIRE-0648; boron waste monitor PRMIRE-0627; reactor building sump PRMIRE-6777 Calibration and Testing Program (IP Section 03.02) (10 Samples)

The inspectors evaluated the calibration and testing of the following radiation detection instruments:

(1)

Ludlum Model 9-3, ion chamber, CHP-DR-659, September 10, 2024 (2)

Ludlum Model 9-3, ion chamber, CHP-DR-485, October 14, 2024 (3)

Thermo AMS-4, continuous air monitor (noble gas), HP-RD-256, November 21, 2024 (4)

Thermo AMS-4, continuous air monitor (particulate), HP-RD-252, August 19, 2024 (5)

General Atomics RD-23, containment high range radiation monitor, ARMIR-5400B, February 17, 2025 (electronic) and May 14, 2025 (radiation)

(6)

RADECO H-809V, air sampler, HP-AS-375, January 3, 2025 (7)

General Atomics RD-11, control room area radiation monitor, ARMIR-5001, December 12, 2023 (8)

General Atomics RD-53, component cooling water, PRMIRE-7050-A, September 1, 2024 (9) gamma spectroscopy system, Detector 5, 47mm filter, Shelf 1, May 5, 2025 (10)

General Atomics RD-8, containment purge monitor, ARMIR-5027, May 21, 2025 Effluent Monitoring Calibration and Testing Program Sample (IP Section 03.03) (2 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1)

Unit 3, liquid radioactive waste effluent monitor, PRM-IR-0647, June 5, 2024 (2)

Unit 3, fuel handling building exhaust effluent monitor, PRM-IR-5107 A, February 3, 2025 71124.06 - Radioactive Gaseous and Liquid Effluent Treatment Walkdowns and Observations (IP Section 03.01) (3 Samples)

The inspectors evaluated the following radioactive effluent systems during walkdowns:

(1) fuel handling building ventilation system (2) reactor auxiliary building ventilation system (3) shield building ventilation system

9 Sampling and Analysis (IP Section 03.02) (3 Samples)

Inspectors evaluated the following effluent samples, sampling processes and compensatory samples:

(1) dip sampling of dry cooling tower sump (2) grab sampling of circulating water system discharge and yard oil separator (3) particulate, iodine, noble gas, and tritium sampling of fuel handling building ventilation system exhaust Dose Calculations (IP Section 03.03) (2 Samples)

The inspectors evaluated the following dose calculations:

(1) gaseous effluent estimated public dose with plant stack and fuel handling building exhaust sample results dated September 2, 2025 (2) liquid effluent estimated public dose with circulating waters system discharge sample dated September 3, 2025 Abnormal Discharges (IP Section 03.04) (1 Sample)

The inspectors evaluated the following abnormal discharges:

(1)

No abnormal discharges occurred since the last inspection.

71124.07 - Radiological Environmental Monitoring Program Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)

(1)

The inspectors evaluated environmental monitoring equipment and observed location of environmental samples.

Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)

(1)

The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.

GPI Implementation (IP Section 03.03) (1 Sample)

(1)

The inspectors evaluated the licensees implementation of the Groundwater Protection Initiative (GPI) program to identify incomplete or discontinued program elements.

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &

Transportation Radioactive Material Storage (IP Section 03.01) (1 Sample)

The inspectors evaluated the licensees performance in controlling, labeling and securing the following radioactive materials:

(1) sealed sources that require leak testing across the site

10 Radioactive Waste System Walkdown (IP Section 03.02) (1 Sample)

The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:

(1) resin dewatering system located in the radwaste solidification building which was in a standby configuration Waste Characterization and Classification (IP Section 03.03) (2 Samples)

The inspectors evaluated the following characterization and classification of radioactive waste:

(1) 10 CFR Part 61 Waste Stream Sample Screening and Evaluation for liquid waste management resin, #L108821-1, dated March 17, 2025 (2) 10 CFR Part 61 Waste Stream Sample Screening and Evaluation for dry active waste, #L109772-1, dated May 20, 2025 Shipment Preparation (IP Section 03.04)

No radioactive material shipments or preparation were available for observation while the inspectors were on site.

Shipping Records (IP Section 03.05) (4 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through a record review:

(1)

1. 23-1003: UN2912, radioactive material, low specific activity (LSA-I), 7; dry active waste; dated April 5, 2023 (2)

1. 24-1005: UN2916, radioactive material, type B(U) package, 7, fissile-excepted, RQ -

radionuclides; dated November 21, 2024 (3)

1. 25-3023: UN2910, radioactive material, excepted package - limited quantity of material, 7; dated May 5, 2025 (4)

1. 25-1005: UN2916, radioactive material, type B(U) package, 7, fissile-excepted, RQ -

radionuclides; dated June 30, 2025 OTHER ACTIVITIES - BASELINE 71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)

(1)

April 1, 2024, through March 31, 2025 MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)

(1)

April 1, 2024, through March 31, 2025

11 MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)

(1)

July 1, 2024, through June 30, 2025 MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)

(1)

July 1, 2024, through June 30, 2025 MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)

(1)

July 1, 2024, through June 30, 2025 71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03) (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1)

The inspectors reviewed the licensees corrective action program to identify the licensees follow-up to a self-revealed Green finding, documented in report WATERFORD STEAM ELECTRIC STATION, UNIT 3 - INTEGRATED INSPECTION REPORT 05000382/2024003 (ADAMS Accession No. ML24311A182) for the licensees failure to establish and maintain adequate procedures for maintenance and testing associated with main transformer B that resulted in a main transformer B fire.

The inspectors reviewed corrective actions, interviewed members of the engineering staff, and reviewed performance trends associated with main transformer B. The inspectors determined the licensees corrective actions and response to the finding is adequate.

71153 - Follow-Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02) (2 Samples)

The inspectors evaluated the following licensee event reports (LERs):

(1)

LER 05000382/2025-002-00, Auxiliary Pressurizer Spray Train Inoperable Resulting in a Condition Prohibited by Technical Specifications (ADAMS Accession No. ML25149A137). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 71153. This LER is Closed.

(2)

LER 05000382/2025-003-00, Auxiliary Component Cooling Water Train Inoperable Resulting in a Condition Prohibited by Technical Specifications (ADAMS Accession No. ML25160A203). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 71153. This LER is Closed.

12 INSPECTION RESULTS Licensee-Identified Non-Cited Violation 71111.12 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: Technical Specification 6.8.1.a, Procedures and Programs, states in part, written procedures shall be established, implemented, and maintained covering the applicable procedures listed in Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Revision 2, Appendix A, Section 9, Procedures for Performing Maintenance, requires, in part, maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. The licensee established Procedures EN-MA-101, Conduct of Maintenance, Revision 37, and EN-DC-105, Configuration Management, Revision 9, in part, to meet this requirement.

Procedure EN-MA-101 states, in part, the definition of maintenance includes proper equipment...restoration to service...to assure the adequacy of corrective action.

Procedure EN-DC-105 states, in part, maintenance activities...shall be accomplished in accordance with procedures that provide for plant configuration control.

Contrary to the above, from January 21, 2025, to March 27, 2025, the maintenance of the A start-up transformer (SUT) was not adequately performed in accordance with written procedures or documented instructions. The licensee failed to implement Procedure EN--MA-

-101, Conduct of Maintenance, Revision 37, and EN-DC-105, Configuration Management, Revision 9. Specifically, the licensee failed to perform adequate maintenance and reinstall this test cap led to a loss of reasonable presumption of operability of the A SUT, the failure of the gasket within the test cap, and the draining of insulating oil within the bushing. In addition, the licensee did not adequately provide vendor oversight during maintenance to ensure that configuration control was maintained.

Significance/Severity: Green. The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the finding impacted the Mitigating Systems cornerstone and used exhibit 2 to evaluate the condition. The inspectors determined the finding represented a loss of probabilistic risk assessment (PRA) function of one train of a multi-train technical specification (TS) system for greater than its TS allowed outage time. Therefore, a detailed risk evaluation was performed by a regional senior reactor analyst.

The analyst assumed that the A startup transformer would have failed to perform its required function as a source of offsite power for the applicable 24-hour mission time beginning on March 26, 2025, after a satisfactory/acceptable bushing oil level was last observed. Based on corrective maintenance having been completed on April 3, 2025, the analyst assumed a total exposure time of 8 days for this condition. Using the SPAR model version TLU15, based on model version 8.81, along with SAPHIRE version 8.2.12, the analyst adjusted the following basic events in the event and condition assessment (ECA) workspace to model the assumed conditions. For a 1-day period, ACP-TFM-FC-SUT3A (Failure of Startup Transformer from Switchyard) was set to TRUE, and for a 7-day period ACP-TFM-TM-SUT3A (Startup Transformer Test/Maintenance) was set to TRUE. The analyst quantified the SPAR model according to these assumptions to obtain a result of 5.1E-8/year increase in average annual

13 core damage frequency (delta-CDF) associated with internal events and external events, excluding fire events. The dominant sequences involved a loss of AC bus 3B3 with failure of the offsite power function and either: (1) failure of the emergency feedwater function, or (2) failure of the emergency diesel generator and FLEX functions. Since the SPAR model did not include modeling of fire events, the analyst determined that the best available information associated with the risk attributable to fire events would be obtained from the licensees fire PRA model. The analyst obtained and reviewed the results of the licensees fire PRA modeling of the impact of this condition and concluded that the increase in risk for this condition associated with fire events was best estimated to be a delta-CDF of 1.24E-7/year.

The analyst also evaluated the risk impact of assuming that the transformer would fail to perform its required function in response to any seismic event or hurricane event that would cause a plant trip but that would not also cause a loss of offsite power (LOOP) due to other induced failures (e.g. grid conditions) during the time period from January 20, 2025, through March 27, 2025. The analyst determined that the estimated delta-CDF attributable to this assumption would represent negligible additional risk (approximately 3.6E-10/year).

The risk significance of the finding was also evaluated for impact on large early release frequency (LERF). The analyst evaluated the increase in LERF using IMC 0609, Appendix H, Containment Integrity Significance Determination Process. The analyst reviewed all sequences contributing to CDF for any elements affecting LERF and determined that risk due to LERF implications would not represent a dominant risk metric for this evaluation. Based on a review of the licensees modeling approach and results, the analyst determined the best-estimate of increase in LERF for this condition was 4.48E-10/year.

Based on total best-estimate results of 1.75E-7/year for delta-CDF and 4.48E-10/year for delta-LERF, the analyst concluded that the condition associated with this violation was of very low safety significance (Green).

Corrective Action References: The licensee entered this issue into the corrective action program with Condition Report CR-WF3-2025-01392.

Failure to Identify and Correct a Condition Adverse to Quality Affecting the Emergency Lighting System Cornerstone Significance Cross-Cutting Aspect Report Section Not Applicable Green NCV 05000382/2025003-01 Open/Closed

[H.2] - Field Presence 71111.15 The inspectors identified a Green finding and associated non-cited violation of Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action. Specifically, the licensee failed to identify and correct a condition adverse to quality with respect to emergency lighting. The failure to identify and correct these deficiencies led to inadequate lighting in Safe Shutdown spaces per licensee Engineering Change EC--86633, Emergency DC Lighting Self-Contained Battery Pack Maintenance Rule Light Areas, which delineates what lighting is required for safe shutdown during a station blackout event.

==

Description:==

Over the course of several months, NRC inspectors identified several emergency lights that were non-functional and/or required servicing:

1.

November 20, 2024, an NRC inspector identified emergency safe shutdown lights that required servicing in the reactor auxiliary buildings stair 9 - both lights had the charging status light illuminated - meaning that the 8-hour functionality of the light

14 couldnt be guaranteed. The licensee generated Condition Report CR-WF3--2024-05543 for this deficiency.

2.

January 22, 2025, an NRC inspector identified emergency safe shutdown lights that required servicing in the relay room - both lights had the charging status light illuminated. The licensee generated Condition Report CR--WF3--2025--00221 for this deficiency.

3.

July 9, 2025, an NRC inspector identified emergency safe shutdown lights that required servicing throughout the reactor auxiliary building - nine lights had either the charging status or low battery light illuminated. The licensee generated Condition Reports CR-WF3-2025-03368 and CR-WF3-2025-03369 for these deficiencies.

Numerous other lights in the reactor auxiliary building were noted as being deficient as well.

Per the licensee's Engineering Change EC-86633, Emergency DC Lighting Self-Contained Battery Pack Maintenance Rule Light Areas, there is a minimum number of lights required to be functional in each of certain spaces in order to have adequate lighting for safe shutdown during a station blackout event. It was noted that a number of these spaces fell below this threshold for required lighting.

In discussions with the licensee, it was determined that the reporting of deficient emergency and safe shutdown lights under the corrective action program was inadequate. According to licensee Procedure EN-LI-102, Corrective Action Program, revision 55, a condition adverse to quality warrants a condition report being written to document the deficiency. After further discussion it was also determined that maintenance for these emergency lights was also inadequate, with the maintenance of these lights having not been performed at a frequency to maintain functionality of the emergency lighting system.

Corrective Actions: The licensee initiated a condition report to enter this issue into the corrective action program. The condition report initiated the corrective action to reinstate the preventive maintenance of the egress lighting.

Corrective Action References: The licensee entered this issue into the corrective action program with Condition Report CR-WF3-2025-03511.

Performance Assessment:

Performance Deficiency: The failure to identify and correct a condition adverse to quality with respect to the emergency lighting system was a performance deficiency. Specifically, per licensee Procedure EN-LI-102, Corrective Action Program, revision 55, promptly identifying and correcting conditions adverse to quality is the responsibility of site employees and contractors and is therefore within the licensees ability to foresee and correct.

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 continued lack of identifying and correcting deficiencies of emergency lighting would have the potential to challenge safe shutdown response as more spaces fall below the required lighting threshold(s), which would then impact the Mitigating Systems cornerstone and adversely affect the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Significance: The inspectors assessed the significance of the finding using IMC 0609,

15 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the finding impacted mitigating systems and used exhibit 2 to evaluate the condition. The finding was determined to be of very low safety significance (Green) because it: (1) was not a deficiency affecting design or qualification of a mitigating system; (2) does not represent a loss of the PRA function of a single train TS system for greater than allowed outage time; (3) does not represent a loss of PRA function of one train of a multi-train TS system for greater than its allowed outage time; (4) does not represent a loss of the PRA function of two separate TS systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; (5) does not represent a loss of PRA system and/or function as defined by the plant risk information eBook or the licensees PRA for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and (6) does not result in the loss of a high safety-significant, non-TS train for greater than 3 days.

Cross-Cutting Aspect: H.2 - Field Presence: Leaders are commonly seen in the work areas of the plant observing, coaching, and reinforcing standards and expectations. Deviations from standards and expectations are corrected promptly. Senior managers ensure supervisory and management oversight of work activities, including contractors and supplemental personnel.

Specifically, the standards and expectations of Procedure EN-LI-102 to identify and correct conditions adverse to quality were not met and a deviation from that standard was not corrected promptly. As a result, several spaces did not meet the minimum lighting standard per the licensees engineering change.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. The licensee established Procedure EN-LI-102, Corrective Action Program, revision 55, in part to meet this requirement.

Contrary to the above, as of July 9, 2025, the licensee failed to adequately identify and correct conditions adverse to quality with respect to emergency lighting. Specifically, any failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances of emergency and safe shutdown lights were not being identified and corrected - condition reports were not being written in accordance with procedure EN-LI-102.

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 71111.15 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 50.49, Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants, Section (f) requires, in part, each item of electric equipment important to safety must be qualified by one of the following methods:

1.

Testing an identical item of equipment under identical conditions or under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable.

2.

Testing a similar item of equipment with a supporting analysis to show that the

16 equipment to be qualified is acceptable.

3.

Experience with identical or similar equipment under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable.

4.

Analysis in combination with partial type test data that supports the analytical assumptions and conclusions.

Contrary to the above, as of April 10, 2025, the licensee failed to qualify items of electric equipment important to safety by one of the following methods:

1.

Testing an identical item of equipment under identical conditions or under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable.

2.

Testing a similar item of equipment with a supporting analysis to show that the equipment to be qualified is acceptable.

3.

Experience with identical or similar equipment under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable.

4.

Analysis in combination with partial type test data that supports the analytical assumptions and conclusions.

Specifically, the licensee determined that a total of 80 safety-related Rosemount transmitters did not have environmentally qualified process connections due to using an unqualified thread sealant.

Significance/Severity: Green. The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was determined to be of very low safety significance (Green) because it was a deficiency affecting the design or qualification of the transmitters, but the transmitters maintained their operability or PRA functionality.

Corrective Action References: The licensee entered this issue into the corrective action program with Condition Report CR-WF3-2025-01392.

Very Low Safety Significance Issue Resolution Process: Question as to if the NRC Licensee Shipped Licensed Radioactive Material to an Unauthorized Entity (10 CFR 30.41) 71124.08 This issue is a current licensing basis question and inspection effort is being discontinued in accordance with the Very Low Safety Significance Issue Resolution (VLSSIR) process. No further evaluation is required.

==

Description:==

The inspectors identified an issue of concern regarding the licensees shipment of contaminated instruments to the Entergy Central Calibration Facility (CCF) for calibration.

The CCF is the corporate center for calibration of fleet radiological instrumentation. Based on a recent finding at the Grand Gulf Nuclear Station for transfer of radioactive sources to the CCF (ML25129A077), it was identified that the CCF did not have a radioactive material license to possess radioactive material sources in quantities greater than exempt quantities.

Since the issuance of the Grand Gulf Nuclear Station finding, the CCF obtained a specific radioactive materials license from the State of Mississippi on April 14, 2025, for onsite calibration of instruments.

During a review of the licensee's radioactive shipping records, it was determined that the licensee shipped contaminated portable survey instruments to the CCF (an Agreement State

17 licensee) for calibration on three different occasions. The calibration facility had conducted the same service prior to obtaining the materials license for calibration. Inspectors and others reviewed the CCFs materials license and found no license condition that allowed receipt of radioactive material. However, the reactor personnel, not being familiar with materials license conditions, perceived the materials license did allow the receipt of their contaminated portable survey instruments for calibration as had been done for many years previously. As the materials license was recently issued, a misunderstanding or miscommunication of the license conditions and limitations occurred. Since April 14, 2025, when the materials license was issued, there have been three shipments of contaminated portable survey instruments to the calibration licensee facility. The shipments were identified as 25-3019 on April 23, 2025, 25-3023 on May 5, 2025, and 25-3035 on July 9, 2025. The isotopic activity of radioactive materials in each shipment totaled 165 microcuries, 327 microcuries, and 586 microcuries, respectively.

After discussing the identified concern with the inspectors, the licensee entered the issue into their corrective action program. The inspectors did not have an immediate safety concern because the sources were stored in a secure facility with access controlled to authorized users, and the licensee confirmed to the inspectors that all licensed radioactive material shipments would stop until this issue has been resolved.

The licensee informed the NRC that continued efforts would be implemented to fully understand what the CCF is authorized for through their fleet operations before shipments resume.

After considering the available information, the inspectors concluded that the licensee shipping the contaminated instrumentation to the CCF after the CCF received a State of MS license to conduct calibrations, but not authority for the receipt of additional licensed byproduct material, was a violation. However, the inspectors determined that this issue met the criteria for the VLSSIR process because:

1.

The inspection staff identified that the issue of concern appears to be a non-compliance after considering licensee-provided supporting information and relevant information developed during the inspection process. However, there was ambiguity as to what the licensee understood the State of MS authorized the CCF for, which can take substantial resources to resolve.

2.

The specific issue of concern cannot have any potential to be Greater than Green safety significance.

3.

The resources required to resolve the current licensing basis question would not effectively serve the agencys mission.

This issue of concern was discussed with the licensee.

Licensing Basis: Title 10 CFR 30.41(c) states before transferring byproduct material to a specific licensee of the Commission or an Agreement State or to a general licensee who is required to register with the Commission or with an Agreement State prior to receipt of the byproduct material, the licensee transferring the material shall verify that the transferee's license authorizes the receipt of the type, form, and quantity of byproduct material to be transferred. There was a question of how the CCFs Agreement State license was verified to receive the shipments. There was a question as to whether the CCF could receive the contaminated portable instruments for calibrations. The licensee stated that the verification was performed by their vendor for shipping.

18 Significance: The staff determined that a violation, if proven to exist, would be no greater than a Severity Level IV (SL-IV) violation. As part of the VLSSIR process, the inspectors screened the issue of concern through the NRC Enforcement Policy, Section 6.7, and determined the issue to be of no more than a SL-IV violation based on the activity of the highest of the three instrument shipments (25-3035). The aggregated quantity of the shipment would be greater than 10 times, but less than 1000 times, the quantity specified in Appendix C to 10 CFR Part 20, and the licensed radioactive material was labeled and controlled as radioactive material.

Technical Assistance Request: No technical assistance request was processed for this issue.

Corrective Action Reference: CR-WF3-2025-04158 Inadequate Troubleshooting of Charging Pump A Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2025003-02 Open/Closed

[P.3] -

Resolution 71153 A self-revealed finding of very low safety significance (Green) and an associated non-citied violation of Technical Specification 3.4.3.2 was identified when the licensee failed to ensure operability of two independent trains of auxiliary pressurizer spray in accordance with technical specifications. Specifically, the licensee failed to identify and correct a degraded lube oil pump for safety-related charging pump A. This resulted in the pump being inoperable for greater than the allowed outage time specified in Technical Specifications 3.4.3.2, a condition prohibited by the licensees technical specifications.

==

Description:==

From December 16, 2024, to March 31, 2025, charging pump A tripped five times due to low lube oil pressure. During the course of the first four trips, the licensee did not adequately troubleshoot the true source for the pump failure because not all potential causes for a low lube oil trip were vetted until the fifth trip. The pumps form part of the auxiliary pressurizer spray system which are credited in UFSAR, Section 9.3.4.1, for cooling the pressurizer and in Section 15.6.3.2.1.2 for mitigating the effects of a steam generator tube rupture.

On both December 16, 2024, and January 31, 2025, the pump tripped on low lube oil upon starting the pump after performance of a surveillance. As a result of this, the pump was declared inoperable, and an unplanned entry into a technical specification action statement was made by the licensee. The licensee corrected this issue by manually adjusting the lube oil relief valve setpoint and restarted the pump. The pump was then declared operable after the successful restart.

Subsequently, on February 3, the pump again tripped on low lube oil pressure after attempting to start the pump, and the pump was again declared inoperable. The licensee theorized the pressure-regulating relief valve on its lube oil system was the cause of this inoperability and replaced the relief valve on February 13. The licensee then declared the pump operable following a successful start of the pump. The pump ran until February 23, when the pump was secured for a seal pressure issue.

Furthermore, on March 3, during the performance of a quarterly surveillance, the pump

19 tripped 30 seconds after starting due to low lube oil pressure. The licensee postulated the cause of the low lube oil pressure condition was due to the oil filter, so the licensee replaced the oil filter. The licensee formed an emergent issue team (EIT) to also correct the seal pressure issue. The EIT recommended an engineering change to replace the pressure-regulating relief valves. Additionally, the EIT did conclude the cause of the recent trip was due to oil pressure and not the seal pressure issue. Also, the EIT did create a task to evaluate oil pump degradation as a potential cause. The licensee replaced the oil filter, inspected and replaced internal check valves and packing, and then restarted the pump. The pump was declared operable on March 15 without the oil pump being troubleshot. The pump was secured on March 17.

On March 31, the pump was started in preparation for the pump pulsation dampener pressure check. Similar to previous trips, the pump tripped after 30 seconds due to low lube oil pressure. The licensee formed another EIT to investigate and correct the issue. During troubleshooting, the licensee discovered the pumps lube oil pump packing gland was damaged. This caused oil to leak past the packing and back to the reservoir. The licensee replaced the oil pump and declared the pump operable on April 8. Since the oil pump was the ultimate cause for the low lube oil condition resulting in the pump tripping, the licensee determined the pump was inoperable from February 23 (when the pump was secured due to the seal pressure issue) until April 8.

Waterford 3 Technical Specification 3.4.3.2 states, in part, two auxiliary pressurizer spray trains shall be operable. The trains consist of at least one independent charging pump. If one of the required trains is inoperable, then condition A requires the licensee to restore the inoperable train within 30 days or be in Mode 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Mode 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Since the pump was inoperable for greater than 30 days (total of 36 days), the licensee should have entered Mode 3 on March 24, at 3:54 a.m. per condition A of Technical Specification 3.4.3.2. By remaining in Mode 1, the licensee was in a condition prohibited by technical specifications. The site submitted Licensee Event Report 05000382/2025-002-00 (ML25149A137) to the NRC to document the condition prohibited by technical specifications.

Corrective Actions: The licensee initiated a condition report to enter this issue into the corrective action program. The condition report initiated the following corrective actions:

(1) replace the oil pump in the pump lube oil system; (2) after charging pump maintenance, wait 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before starting the pump to ensure no deficiency is masked; and (3) updated maintenance documentation and preventive maintenance documentation to ensure troubleshooting and lube oil replacement captures the lessons learned.

Corrective Action References: Condition Report CR-WF3-2025-01195 Performance Assessment:

Performance Deficiency: The failure to identify and correct a condition adverse to quality is a performance deficiency that was within the licensees ability to foresee and correct.

Specifically, the failure to properly identify and correct the lube oil pump degraded packing resulted in a condition prohibited by technical specifications as charging pump A was inoperable for greater than its allowed outage time.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating

20 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 failure resulted in charging pump A, which is credited as part of the auxiliary pressurizer spray system in mitigating steam generator tube ruptures, being declared inoperable for greater than its technical specifications allowed outage time.

Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the finding impacted mitigating systems and used exhibit 2 to evaluate the condition. The inspectors determined the finding represented a loss of PRA function of one train of a multi-train TS system for greater than its TS allowed outage time. Therefore, a detailed risk evaluation was performed by a senior reactor analyst.

The analyst assumed that the performance deficiency resulted in a condition where charging pump A would have failed to perform its required function for the applicable 24-hour mission time. The analyst assumed that the pump was unavailable to perform its required function for a period of 36 days. As a bounding case, the analyst assumed that no recovery credit would be applicable.

Using the SPAR model version TLU15, based on model version 8.81, along with SAPHIRE version 8.2.12, the analyst adjusted the basic event CVC-MDP-FR-A (Failure of Charging Pump A to Run) to TRUE in the ECA workspace to model the assumed conditions. The analyst quantified the SPAR model to obtain a result of 7.47E-9/year increase in average annual core damage frequency (delta-CDF) associated with internal events and external events, excluding fire events. The dominant sequence involved an anticipated transient without scram (ATWS) event with failure of the emergency boration function. The risk significance of the finding was also evaluated for impact on LERF using Inspection Manual Chapter 0609, Appendix H, Containment Integrity Significance Determination Process. The analyst reviewed all sequences contributing to CDF for any elements affecting LERF and identified core damage sequences resulting from an ATWS event as having the potential to contribute to LERF by increasing the potential for a consequential steam generator tube rupture to occur. The analyst estimated that an increase in LERF due to these considerations would be less than 1E-7/year. Based on the above best-estimate results, the analyst concluded that the significance of this finding was very low safety significance (Green).

Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance. Specifically, the licensees failure to challenge incorrectly identified components suspected of causing the inoperability delayed the identification of the actual component that faulted. As a result, the pump experienced repeated trips and was subsequently inoperable for 36 days - a condition prohibited by technical specifications.

Enforcement:

Violation: Waterford 3 Technical Specification 3.4.3.2 states, in part, two auxiliary pressurizer spray trains shall be operable. The trains consist of at least one independent charging pump.

If one of the required trains is inoperable, then condition A requires the licensee to restore the inoperable train within 30 days or be in Mode 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Mode 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Contrary to the above, from February 23, 2025, to April 8, 2025, the licensee did not maintain

21 operability of two auxiliary pressurizer spray trains in accordance with technical specifications, nor did the licensee execute the technical specification action statement requiring the licensee to restore the inoperable train within 30 days or be in Mode 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Mode 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Specifically, charging pump A was inoperable for 36 days while the plant remained in Mode 1, a condition prohibited by the licensees technical specifications.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Inadequate Foreign Material Exclusion Practices Leading to the Inoperability of Auxiliary Component Cooling Water Pump A Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2025003-03 Open/Closed

[H.12] - Avoid Complacency 71153 A self-revealed finding of very low safety significance (Green) and an associated non-citied violation of Technical Specifications 6.8.1.a, Instructions, Procedures, and Drawings, was identified for the licensees failure to implement maintenance that can affect the performance of safety-related equipment without properly preplanning and performing the maintenance in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Specifically, the failure to include cleaning of oil piping of the safety-related auxiliary component cooling water pump A following a mechanical seal replacement due to a leak as specified in the vendor technical document. This resulted in foreign material causing a significant oil leak and resulting in the pump being declared inoperable for a period greater than its allowed technical specifications outage time, a condition prohibited by technical specifications.

==

Description:==

On April 10, 2025, during a surveillance run of auxiliary component cooling water (ACCW) pump A, the licensee discovered an oil leak of approximately 150-200 dpm from the inboard pump bearing housing. The pump was subsequently declared inoperable. Based on previous operating experience, the licensee removed and cleaned the oil reservoir vent caps.

The licensee then started ACCW pump A successfully with no noted oil leaks. Upon engineering recommendation, the pump was then secured for approximately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> and restarted to re-create the initial oil leak conditions. This subsequent pump start resulted in further leakage. As a result, the licensee then replaced the vent caps. Two following pump runs were completed successfully, and no leakage was noted; the ACCW pump was declared operable on April 12, 2025.

Post-event discussions with the industry on April 14, 2025, yielded another two possible causes of the oil leak: clogged oil reservoir passages or high oil level. Oil level checks were previously verified satisfactory during the previous pump runs. On April 16, 2025, the licensee removed the pump from operation to do further investigation and identified foreign material had clogged the oil passage to the outboard bearing and that another oil passage to the oil cooler was partially blocked by an oversized Garlock (paper) gasket. The gasket material had previously been changed from paper to Loctite in 2010; therefore, the foreign material is theorized to have been introduced some time prior to the 2010 change to Loctite. Following the removal of the foreign material, the licensee declared ACCW pump A operable on April 17, 2025, following a successful post-maintenance test.

22 In November 2023, NRC inspectors discovered a mechanical seal leak on ACCW pump A and notified the licensee. Work Order 570436 was generated to repair the mechanical seal leak. As part of the work order, Procedure MM-006-025, Component Cooling Water Pump Maintenance, Revision 10, a safety-related procedure, was used to provide instruction for the disassembly, inspection, and assembly for ACCW pump A. Procedure MM-006-025 references Vendor Technical Document TD-B015.0045, Babcock A & Wilcox Component Cooling Water Pump Model 12x14x16 DE, as a performance reference for the instructions in the procedure. The vendor technical document specifies, in part, all parts should be taken apart and thoroughly cleaned before assembling. The interior of the housing and the oil piping should be cleaned. Procedure MM-006-025, and Work Order 570436 did not provide any instructions for the cleaning of the interior piping as noted in the vendor technical document.

After performing a past operability evaluation, the licensee determined that the ACCW pump was inoperable from April 10, 2025, to April 17, 2025, without having entered the risk-informed completion time process. Waterford 3 Technical Specification 3.7.3 requires, in part, at least two independent auxiliary component cooling water trains be operable in Mode 1. Its associated action requires that the inoperable train be restorable to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or in accordance with the prescribed risk-informed completion time or be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 within 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Since the licensee failed to enter and take action per technical specification action statement, the licensee had been in a condition prohibited by technical specifications. The site submitted Licensee Event Report 05000382/2025-003-00 to the NRC to document the condition prohibited by technical specifications.

Corrective Actions: The licensee initiated a condition report to enter this issue into the corrective action program. The condition report initiated the following corrective actions:

(1) develop and communicate findings from the pump inspection and communicate lessons learned; (2) revise Procedure MM-006-025, Component Cooling Water Pump Maintenance, to inspect/clean bearing tubing and the oil cooler when prudent, and to check for oil passages and foreign material prior to reassembly; and (3) add a note to Procedure MM-006-025 detailing the lessons learned and equipment impact of foreign material blockage of oil passageways.

Corrective Action References: Condition Report CR-WF3-2025-01400 Performance Assessment:

Performance Deficiency: The failure to properly develop and implement adequate maintenance instructions for auxiliary component cooling water pumps during disassembly, inspection, and assembly was a performance deficiency. Specifically, the licensee failed to establish a procedure that provided adequate work instructions in accordance with the Vendor Technical Document TD-B015.0045, Babcock A & Wilcox Component Cooling Water Pump Model 12x14x16 DE, for ensuring that inspection and cleaning of the oil piping should be performed prior to reinstallation. Procedure MM-006-025, Component Cooling Water Pump Maintenance, failed to include specific steps to clean and inspect oil piping to ensure no existing foreign material was present in the auxiliary component cooling water pump lubrication subsystem. This resulted in auxiliary component cooling water pump A being declared inoperable due to an excessive oil leak caused by foreign material for greater than its technical specifications allowed outage time.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the

23 availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the inadequate procedures resulted in there being foreign material left in the oil system of auxiliary component cooling water pump A, which caused a leak and the inoperability of the pump longer than its technical specification allowed outage time.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the finding impacted mitigating systems and used exhibit 2 to evaluate the condition. The inspectors determined the finding represented a loss of PRA function of one train of a multi-train TS system for greater than its TS allowed outage time. Therefore, a detailed risk evaluation was performed by a senior reactor analyst.

The analyst assumed that the performance deficiency resulted in a condition where the ACCW pump A would have failed to perform its required function for the applicable 24-hour mission time. Based on a review of the timeline of events involving the testing and maintenance of this component in light of the degraded condition that was identified, the analyst assumed that the pump was unavailable to perform its required function for a period of 7 days and 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> from April 10, 2025, through April 17, 2025. Specifically, during this total time period of 175 hours0.00203 days <br />0.0486 hours <br />2.893519e-4 weeks <br />6.65875e-5 months <br /> involving periods of troubleshooting, corrective maintenance, and testing, the analyst determined: (a) for 107 hours0.00124 days <br />0.0297 hours <br />1.76918e-4 weeks <br />4.07135e-5 months <br /> the pump was in a standby condition where it would have failed to run for its mission time if demanded; and (b) for 68 hours7.87037e-4 days <br />0.0189 hours <br />1.124339e-4 weeks <br />2.5874e-5 months <br /> the pump was unavailable due to being in a testing/maintenance condition. As a bounding case, the analyst assumed that no recovery credit would be applicable.

Using the SPAR model version TLU15, based on model version 8.81, along with SAPHIRE version 8.2.12, the analyst adjusted the following basic events in the ECA workspace to model the assumed conditions. For the applicable 107-hour exposure time, ACW-MDP-FR-A (ACCW MDP A Fails to Run) was set to TRUE. For the applicable 68-hour exposure time, ACW-MDP-TM-A (ACCW MDP A Unavailable Due to Test & Maintenance) was set to TRUE, while ACW-MDP-TM-B (ACCW MDP B Unavailable Due to Test & Maintenance), ACW-CTF-TM-B (ACCW Wet Cooling Tower Loop B Test & Maint), CCW-CTF-TM-B (Loop B CCW Dry Cooling Tower Test & Maint), and CCW-HTX-TM-B (Test & Maint of Loop B CCW Heat Exchanger) were all set to FALSE to preclude overestimation of risk due to illogical combinations of test and maintenance events. The analyst quantified the SPAR model according to these assumptions to obtain a result of 4.15E-7/year increase in average annual core damage frequency (delta-CDF) associated with internal events and external events, excluding fire events. The dominant sequence involved a stuck open relief valve event with failure of the high-pressure recirculation function. Since the SPAR model did not include modeling of fire events, the analyst determined that best available information associated with the risk attributable to fire events would be obtained from the licensees fire PRA model. The analyst obtained and reviewed the results of the licensees fire PRA modeling of the impact of this condition and concluded that the increase in risk for this condition associated with fire events was best estimated to be a delta-CDF of 3.08E-7/year.

The risk significance of the finding was also evaluated for impact on LERF. The analyst evaluated the increase in LERF using Inspection Manual Chapter 0609, Appendix H, Containment Integrity Significance Determination Process. The analyst reviewed all sequences contributing to CDF for any elements affecting LERF and screened out all internal and external event sequences from the SPAR results. The analyst determined that best available information regarding LERF risk from fire events would be obtained from a review of

24 the LERF results obtained from the licensees model. Based on a review of the licensees modeling approach, the analyst determined the best-estimate of increase in LERF due to fire events was 2.77E-10/year.

Based on total best-estimate results of 7.23E-7/year for delta-CDF and 2.77E-10/year for delta-LERF, the analyst concluded that the significance of this finding was very low safety significance (Green).

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. The licensee did not inspect nor clean oil piping during disassembly and reassembly of the safety-related auxiliary component cooling water pump which was contrary to vendor maintenance guidance. This resulted in ACC pump A being declared inoperable for longer than its technical specification limiting condition for operation allowed outage time, a condition prohibited by technical specifications.

Enforcement:

Violation: Technical Specification Section 6.8.1.a requires, in part, written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.

NRC Regulatory Guide 1.33, Revision 2, Appendix A, Section 9, provides recommendations for "Procedures for Performing Maintenance." Section 9, states, in part, maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. The licensee established Procedure MM-006-025, Component Cooling Water Pump Maintenance, to perform maintenance of the auxiliary component cooling water pumps.

Contrary to the above, in November 2023, the licensee failed to establish a procedure to address the requirements of Regulatory Guide 1.33, Appendix A, Section 9. Specifically, Procedure MM-006-025, Component Cooling Water Pump Maintenance, did not provide any instructions for the cleaning of the interior piping as noted in the vendor technical document prior to reinstallation of auxiliary component cooling water pumps. As a result, foreign material caused a significant oil leak on the inboard pump bearing of auxiliary component cooling water pump A, rendering the pump inoperable. Because of this, the auxiliary component cooling water pump A was inoperable longer than technical specification allowed outage time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, between April 13, 2025, and April 17, 2025.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS The inspectors verified that no proprietary information was retained or documented in this report.

On September 4, 2025, the inspectors presented the public radiation safety inspection results to Joseph Sullivan Site Vice President and other members of the licensee staff.

25 On September 11, 2025, the inspectors presented the public radiation safety inspection results to Joseph Sullivan, Site Vice President, and other members of the licensee staff.

On December 3, 2025, the inspectors presented the integrated inspection results to David Oertling, General Manager of Plant Operations, and other members of the licensee staff.

26 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date 71111.04 Miscellaneous W3-DBD-4 Component Cooling Water Auxiliary Component Cooling Water Design Basis Document 307 71111.04 Procedures 309 Loss of a 125V Volt DC Bus 71111.04 Procedures OP-002-003 Component Cooling Water 323 71111.04 Procedures OP-006-003 125V DC Electrical Distribution 309 71111.04 Procedures OP-903-049 Component Cooling Water and Auxiliary Component Cooling Water Loop Operability Check 14 71111.05 Corrective Action Documents CR-WF3-2025-NNNN 01631, 01867, 01874, 02440, 02542, 02598, 02730, 03152, 03164, 03374, 03420, 03447, 04006 71111.05 Drawings 5817-14291 Dry Cooling Towers Plug Locations Dry Cooling Tower B

1 71111.05 Drawings 5817-14296 Dry Cooling Towers Plug Locations Dry Cooling Tower A

1 71111.05 Engineering Evaluations EN-ME-S-001-W Tube Sleeve Installations for Dry Cooling Towers 1

71111.05 Miscellaneous W3-DBD-4 Component Cooling Water Auxiliary Component Cooling Water Design Basis Document 307 71111.05 Procedures DP-001-015 Fire Protection System Impairments 336 71111.05 Procedures FP-001-018 Pre-Fire Strategies, Development and Revision 306 71111.11A Miscellaneous IP 71111.11, Table 03.03-1 Results Table for Annual Exam 08/18/2025 71111.11B Corrective Action Documents CR-WF3-2023-16209 PDP MC was Inadvertently Deenergized 10/13/2023 71111.11B Corrective Action Documents CR-WF3-2023-18308 TS 3.9.2 Action (a.) Entry was Inadvertently Missed 12/17/2023 71111.11B Corrective Action Documents CR-WF3-2024-02523 ESFAS (EFAS 1) Actuation while Performing EFW Flow Test 05/11/2024 71111.11B Corrective Action Documents CR-WF3-2024-1597 Auto Rx Trip with loss of Main Transformer B 03/22/2024 71111.11B Corrective Action Documents CR-WF3-2024-2530 Unintended Positive Reactivity Addition 05/12/2024 71111.11B Corrective Action CR-WF3-2024-3475 Simulator PEST Failure for Rx Trip Main Transformer 07/10/2024

27 Inspection Procedure Type Designation Description or Title Revision or Date Documents Event 71111.11B Miscellaneous Licensed Operator Medical Records (6 total) 71111.11B Miscellaneous ENOP-115-06 Activation and Deactivation of Licenses, and Maintaining Active License Status (Multiple Records) 3 71111.11B Miscellaneous JPMs - Plant, Simulator, Admin Week 1 (total of 6)

Week 2 (total of 6) 71111.11B Miscellaneous TQF-200-TRG Training Review Committee (TRG) Meeting Agenda/Minutes for 05/07/2024 05/07/2024 71111.11B Miscellaneous TQF-201-IM05 Remedial Training Plans - Tagging Error, TS Error, 2023 Biennial Exam Failure, 2024 Cycle 3 Written Failure 15 71111.11B Miscellaneous TQF-202-SBI Scenario Based Testing Checklist 03/31/2025 71111.11B Miscellaneous TQF-202-SRB Simulator Review Board (SRB) Meeting Minutes 12 24 12/05/2024 71111.11B Miscellaneous TQF-210-DD03 LOR Simulator Crew Performance Evaluation Report (Week 1) 07/08/2025 71111.11B Miscellaneous TQF-210-DD03 LOR Simulator Crew Performance Evaluation Report (Week 2) 07/15/2025 71111.11B Miscellaneous TQF-210-DD04 RO/SRO Performance Evaluation Report (Week2) 07/15/2025 71111.11B Miscellaneous TQF-210-DD04 RO/SRO Performance Evaluation Report (Week1) 07/08/2025 71111.11B Miscellaneous TQF-210-DD05 STA/SE Performance Evaluation Report (Week 1) 07/08/2025 71111.11B Miscellaneous TQF-210-DD05 STA/SE Performance Evaluation Report (Week 2) 07/15/2025 71111.11B Miscellaneous TQF-218-DD04 JPM Examination Coversheet (Week 2) 07/15/2025 71111.11B Miscellaneous TQF-218-DD04 JPM Examination Coversheet (Week 1) 07/08/2025 71111.11B Miscellaneous WLP-LOR-244PAR00 Precise Parameter Control 0

71111.11B Miscellaneous WLP-LOR-246CVC00 Chemical and Volume Control System 0

71111.11B Miscellaneous WSEM-OPS-235HUIS00 Operations Human Performance Refresher 0

71111.11B Miscellaneous WSXM-LOR-254EXM Scenarios E-320, E-321, E-322, E-323, E-324, E-325 0

71111.11B Miscellaneous WWEX-LOR-254 Biennial Week 1 (RO)

Biennial Week 1 (SRO)

Biennial Week 2 (RO)

Biennial Week 2 (SRO) 07/01/2025 71111.11B Procedures WTRN-OPS-NRC Simulator Exam Security Checklist 2

28 Inspection Procedure Type Designation Description or Title Revision or Date NRCEXAMSECURITY 71111.11B Procedures WTRN-OPS-SIMJPMSETUP Simulator JPM Setup Checklist [Typical]

0 71111.11B Procedures WTRN-OPS-SIMSETUP Simulator Setup Checklist [Typical]

4 71111.11Q Corrective Action Documents CR-WF3-2025-NNNN 04005 71111.11Q Procedures ME-004-021 Emergency Diesel Generator 46 71111.11Q Work Orders 54260765 Emergency Diesel Generator B Overspeed Test 0

71111.12 Corrective Action Documents CR-WF3-YYYY-NNNN 2025-01400 71111.12 Work Orders WO-570436, 54237076 71111.15 Corrective Action Documents CR-WF3-2024-NNNN 05931 71111.15 Corrective Action Documents CR-WF3-2025-NNNN 01392, 03418, 03564, 03822, 03989, 01195, 00335, 00378, 00781 71111.15 Corrective Action Documents CR-WF3-YYYY-NNNN 2024-05543, 2025-03368, 2025-03369 71111.15 Engineering Changes 86633 Emergency DC Lighting Self-Contained Battery Pack Maintenance Rule Light Areas 71111.15 Miscellaneous W3-DBD-8 Electrical Distribution DC Portion 1

71111.15 Procedures OP-903-003 Charging Pump Operability Check 317 71111.15 Procedures OP-904-007 Charging Pump Pulsation Dampener Pressure Check 18 71111.24 Corrective Action Documents CR-WF3-2025-NNNN 03172, 03910, 03929, 03937, 03957, 04007, 04008, 04092, 04333 71111.24 Miscellaneous SD-CHW System

Description:

Essential Chilled Water 13 71111.24 Miscellaneous W3-DBD-037 Design Basis Document: Essential Chilled Water System 302 71111.24 Procedures EN-OP-115 Conduct of Operations 34 71111.24 Procedures OI-004-000 Operations Shift Logs 305 71111.24 Procedures OP-903-014 Emergency Feedwater Flow Verification 319 71111.24 Work Orders 54146113 71111.24 Work Orders 54360765

29 Inspection Procedure Type Designation Description or Title Revision or Date 71111.24 Work Orders 5490184 71114.06 Procedures OP-901-110 Pressurizer Level Control Malfunction 11 71114.06 Procedures OP-901-112 Charging or Letdown Malfunction 12 71114.06 Procedures OP-901-510 Component Cooling Water System Malfunction 307 71114.06 Procedures OP-901-523 Security Events 30 71114.06 Procedures OP-902-001 Reactor Trip Recovery 16 71114.06 Procedures OP-902-008 Functional Recovery 32 71124.05 Calibration Records W/O 00594040 Perform Transfer Calibration Using MCA on PRMIRE6775 01/25/2024 71124.05 Calibration Records W/O 52983852 PRMIR6776, Cal Dry Cooling Tower Sump Rad Mon IAW MI-003-466 06/09/2023 71124.05 Calibration Records W/O 52993068 PRMIR0002, Cal (24/7) Rad Monitor Electronics IAW MI-003-387 10/01/2023 71124.05 Calibration Records W/O 53016865 PRMIR6775, Perform Calibration of Monitor IAW MI-003-466 03/04/2024 71124.05 Calibration Records W/O 53020384 PRMIR0100-2, Calibrate Plant Vent Stack IAW MI-003-380 06/05/2024 71124.05 Calibration Records W/O 54001417 PRMIR6776, Cal Dry Cooling Tower Sump Rad Mon IAW Ml-003-466 07/16/2025 71124.05 Calibration Records W/O 54136057 Investigate and Repair Plant Stack PIG B CR-WF3-2024-02134 06/05/2024 71124.05 Corrective Action Documents CR-HQN-2023-02785, 2023-03170, 2023-03417, 2023-03759 Rad Monitor 71124.05 Corrective Action Documents CR-WF3-YYYY-NNNN 2023-14704, 2023-14917, 2023-14923, 2023-15326, 2023-15385, 2023-15456, 2023-15890, 2023-16177, 2023-16419, 2023-17478, 2023-17709, 2023-18361, 2024-00044, 2024-00414, 2024-00418, 2024-00442, 2025-00241, 2025-00991, 2025-02680, 2025-03357 Rad Monitor 71124.05 Corrective Action Documents CR-WF3-YYYY-NNNN 2023-01068, 2023-01803, 2023-02195, 2023-13280, 2023-14393, 2023-14818, 2023-15129, 2023-15137, 2023-15210, 2023-15211, 2023-15269, 2023-15541, 2023-15846, 2023-16132, 2023-16166, 2024-00948, 2024-02696, 2024-03774, 2024-03827, 2024-03832, 2024-04122, 2024-05967, 2025-00678, 2025-00679, General

30 Inspection Procedure Type Designation Description or Title Revision or Date 2025-00680, 2025-00681, 2025-00682, 2025-00744, 2025-00744, 2025-01382, 2025-01831, 2025-02414 71124.05 Procedures EN-WM-100 Work Order Generation, Screening and Classification 20 and 23 71124.05 Procedures Ml-005-906 Radiation Monitoring System Desk Guide 7

71124.05 Procedures Ml-005-919 Containment Post LOCA Area Radiation Monitor Safety Channel A or B Calibration ARMIR5028, 5029, 5030, 5031 310 71124.05 Procedures Ml-005-920 General Atomic Area Radiation Monitor Assemblies 0359-3501 and 0359-3502 325 71124.05 Self-Assessments LO-WF3-2024-00073 Radiation Monitoring Instrumentation (IP71124.05) 06/12/2025 71124.06 Corrective Action Documents CR-WF3-YYYY-NNNN 2022-04588, 2022-04883, 2022-05164, 2022-06648, 2022-06858, 2022-07308, 2022-07627, 2023-00015, 2023-00273, 2023-00766, 2023-00848, 2023-01123, 2023-01646, 2023-01900, 2023-15008, 2023-15705, 2023-16099, 2023-16271, 2024-00581, 2025-04228 71124.06 Corrective Action Documents Resulting from Inspection CR-WF3-YYYY-NNNN 2025-04228, 2025-04265, 2025-04266 71124.06 Engineering Evaluations WF3-SE-24-00005 10 CFR 50.69 System Categorization Document -

Waterford 3 Shield Building Ventilation (SBV) 0 71124.06 Miscellaneous 2024 Liquid Waste Management (LWM) Waste Stream Analysis 03/17/2025 71124.06 Miscellaneous 2022-2025 Inoperable Gaseous Effluent Radiation Monitor Log: June 2022 through August 2025 71124.06 Miscellaneous 2022-2025 Inoperable Liquid Effluent Radiation Monitor Log: June 2022 through August 2025 71124.06 Miscellaneous Compensatory Sampling Log - PRM-IRE-0002 Out of Service: 07/31/2025-08/04/2025 71124.06 Miscellaneous Compensatory Sampling Log - PRM-IRE-5107A Out of Service: 05/13/2023-05/19/2023 71124.06 Miscellaneous Compensatory Sampling Log - PRM-IRE-0647 Out of Service: 07/24/2024-08/15/2024 71124.06 Miscellaneous Effluent Release Permits W3GB2024-160, W3GB2024-031, W3GB2025-013, W3GC2023-011, W3LB2023-084, W3LB2025-024

31 Inspection Procedure Type Designation Description or Title Revision or Date 71124.06 Miscellaneous ML013270214 Waterford Steam Electric Station, Unit 3 - Issuance of Amendment Re: Relaxation of Fuel Handling Building Ventilation System Requirements (TAC NO. MB2462) 11/21/2001 71124.06 Procedures CE-003-509 Routine Filter Replacement and Grab Sampling On PIG Monitors and WRGMS 314 71124.06 Procedures CE-003-513 Gaseous Radioactive Waste Release Permit (Manual) 306 71124.06 Procedures CE-003-514 Liquid Radioactive Waste Release Permit (Computer) 307 71124.06 Procedures CE-003-515 Gaseous Radioactive Waste Release Permit (Computer) 308 71124.06 Procedures CE-003-700 General Grab Sampling Techniques 323 71124.06 Procedures UNT-005-014 Offsite Dose Calculation Manual 310 71124.06 Radiation Surveys Gamma Spectroscopy Results 04_2025-09-09_003, 04_2025-09-09_004, 04_2025-09-09_005, 04_2025-09-09_006, 06_2025-09-09_003, 06_2025-09-09_005, FHB A Tritium 71124.07 Calibration Records MI-003-395 Primary Meteorological Tower Instrument Calibration EM IM0100 304 71124.07 Calibration Records MI-003-396 Secondary Meteorological Tower Instrument Calibration EM IM0110 014 71124.07 Calibration Records TBE 3001 Teledyne Brown Engineering Environmental Services Calibration and Control of Gamma-Ray Spectrometers 9

71124.07 Calibration Records TBE-3003 Teledyne Brown Engineering Environmental Services Calibration and Control of Alpha and Beta Counters 8

71124.07 Calibration Records TBE-3004 Teledyne Brown Engineering Environmental Services -

Calibration and Control of Liquid Scintillation Counters 9

71124.07 Corrective Action Documents CFR-WF3-YYYY-NNNN 2022-04734, 2023-01942, 2025-03440, 2025-03971, 2025-03972, 2025-03974, 2025-03976, 2025-03977, 2025-03978, 2022-06783, 2022-08238, 2025-03803, 2024-04599, 2024-04600, 2023-00315, 2024-01342, 2024-02339, 2025-03682, 2025-03474, 2024-05301, 2025-00067, 2025-01072, 2022-06392, 2023-14647, 2023-15548, 2023-00147, 2022-04353, 2022-04529, 2022-07645, 2023-13208 71124.07 Corrective Action Documents Resulting CR-WF3-2025-O4218 Primary Met Tower Guide Wire Fence 09/09/2025

32 Inspection Procedure Type Designation Description or Title Revision or Date from Inspection 71124.07 Miscellaneous 4th Quarter 2024 Quality Assurance Report: Teledyne Brown Engineering Environmental Services 01/10/2025 71124.07 Miscellaneous UTAH 2025 Audit Report - UTAH Dept of Health and Human Services Audit of Teledyne Engineering Services 03/07/2025 71124.07 Miscellaneous 024-05548 2024 Radiological Environmental Monitoring Program Land Use Census 12/31/2024 71124.07 Miscellaneous 50-382 2023 Annual Radioactive Effluent Release Report 04/17/2024 71124.07 Miscellaneous 50-382 2024 Annual Radiological Environmental Operating Report 09/25/2025 71124.07 Miscellaneous CE-003-522 Annual Meteorological Monitoring Program Report 2024 04/18/2025 71124.07 Miscellaneous EN-AD-103 Supplemental Form Revision of ODCM 08/20/2023 71124.07 Miscellaneous EN-CY-130 Radiological Environmental Monitoring Program 1

71124.07 Miscellaneous EN-DC-343 Underground Piping and Tanks Inspection and Monitoring Plan 14 71124.07 Miscellaneous EN002-3ERGWMPWF-13 Teledyne Brown Engineering Sample Receipt Verification/Variance Report May 2025 Monitoring Well Results 06/07/2025 71124.07 Miscellaneous NAQA-23-0030 Audit Report for the DTE Audit of Environmental Dosimetry Company (DTE Audit No.23-001), Revision 1 1

71124.07 Miscellaneous NUPIC Audit Number:

25559 Constellation Energy Generation Audit Number:

SR-2024-14 71124.07 Miscellaneous QA-2/6-2023-W3-1 Quality Assurance Audit Report: Combined Chemistry, Effluents and Environmental Monitoring: August 21, 2023, through September 28, 2023 71124.07 Miscellaneous TBD MDA Environmental Detection Limits 71124.07 Miscellaneous UNT-005-014 Offsite Dose Calculation Manual 310 71124.07 Procedures 024-01362 Waterford-3 Groundwater Protection Program Plan 3

71124.07 Procedures CE-003-700 General Grab Sampling Techniques 323 71124.07 Procedures EN-CY-111 Radiological Groundwater Protection Program 13

33 Inspection Procedure Type Designation Description or Title Revision or Date 71124.07 Procedures EN-CY-127 Land Use Census 3

71124.07 Procedures EN-CY-130-04 Radiological Environmental Monitoring Program (REMP) - Waterford 3 4

71124.07 Work Orders WO 54109352-01 Work Order for Calibrating the Met Tower 71124.08 Corrective Action Documents CR-HQN-YYYY-NNNN 2023-03516, 2025-00281, 2025-00554 71124.08 Corrective Action Documents CR-WF3-YYYY-NNNN 2023-14673, 2023-16181, 2023-16630, 2023-17228, 2023-17607, 2023-18438, 2024-01032, 2024-01185, 2024-01388, 2024-01468, 2024-01817, 2024-01969, 2024-02379, 2024-02900, 2024-03022, 2024-03025, 2024-04721, 2024-05878, 2025-01156, 2025-01321, 2025-01428, 2025-01604, 2025-02215, 2025-02673, 2025-03238 71124.08 Corrective Action Documents Resulting from Inspection CR-WF3-YYYY-NNNN 2025-03594, 2025-03965, 2025-4119, 2025-04158 71124.08 Drawings G170 SH.1 Liquid Waste Management System 31 71124.08 Drawings G170 SH.2 Liquid Waste Management System 38 71124.08 Drawings G170 SH.5 Solid Waste Management System 14 71124.08 Miscellaneous Annual Inventory Reconciliation Report 08/21/2025 71124.08 Miscellaneous CVC-2022-7-5 Filter Characterization Report: RCS 2022 Filter Listing (Part 61 RCS 2022 L94362-1, 11/18/2021) 07/05/2022 71124.08 Miscellaneous W3F1-2024-0014 Annual Radioactive Effluent Release Report 2024 04/30/2025 71124.08 Miscellaneous W3F1-2024-0015 Annual Radioactive Effluent Release Report (ARERR) 2023 with Revised ODCM and Revised Process Control Program Procedure 04/17/2024 71124.08 Procedures Waterford 3 / Entergy Part 37 Security Plan for the Protection of Category 1 and Category 2 Quantities of Radioactive Material 2

71124.08 Procedures EN-RP-121 Radioactive Material Control 19 71124.08 Procedures EN-RP-143 Source Control 14 71124.08 Procedures EN-RW-101 Radioactive Waste Management 3

71124.08 Procedures EN-RW-102 Radioactive Shipping Procedure 22 71124.08 Procedures EN-RW-104 Scaling Factors 14

34 Inspection Procedure Type Designation Description or Title Revision or Date 71124.08 Procedures EN-RW-105 Process Control Program 6

71124.08 Procedures HP-002-224 Spent Resin Operations 8

71124.08 Procedures OP-007-004 Liquid Waste Management System 325 71124.08 Procedures OP-007-005 Resin Waste Management 313 71124.08 Procedures RW-002-200 Collection and Packaging of Solid Radioactive Waste 306 71124.08 Procedures RW-002-240 Blowdown Demineralizer Resin Transfer 17 71124.08 Procedures RW-002-310 Storage of Radioactive Waste and Radioactive Equipment 11 71124.08 Radiation Surveys WF3-2107-00082 Vault 1 and 2 Low Level Radwaste Storage Building (LLRWSB) 07/08/2021 71124.08 Radiation Surveys WF3-2504-00150 Protected Area / Outside Radioactive Material Storage Area Quarterly Survey 04/15/2025 71124.08 Radiation Surveys WF3-2504-00371 Owner Controlled Area (OCA) +18 Elevation, Radwaste Solidification Building 04/28/2025 71124.08 Radiation Surveys WF3-2507-00078 Unit 1 Reactor Aux Building +21 Elevation, Decontamination Area 07/14/2025 71124.08 Radiation Surveys WF3-2508-00044 Owner Controlled Area (OCA) +15 Elevation, Radwaste Compactor Building 08/07/2025 71124.08 Radiation Surveys WF3-2508-00061 Unit 1 RAB +21 Elevation Drumming Station 08/11/2025 71124.08 Self-Assessments 2024 Waterford-3 10 CFR Part 37 Annual Review 07/29/2025 71124.08 Self-Assessments 2023 Waterford-3 10 CFR Part 37 Annual Review 02/14/2024 71124.08 Self-Assessments LO-WF3-2024-00073 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation (IP 71124.08) 06/12/2025 71124.08 Self-Assessments QA-14/15-2023-W3-1 Combined Radiation Protection and Radwaste Audit 11/07/2023 71124.08 Work Orders 54246004-01 Semi-Annual Source Inventory 03/20/2025 71151 Miscellaneous W3F1-2025-0005 Waterford 3 Performance Indicator Data 71151 Miscellaneous W3F1-2024-0048 Waterford 3 Performance Indicator Data 71151 Miscellaneous W3F1-2025-0021 Waterford 3 Performance Indicator Data 71151 Miscellaneous W3F1-2025-0035 Waterford 3 Performance Indicator Data 71151 Procedures EN-LI-114 Regulatory Performance Indicator Process 23 71152A Corrective Action Documents CR-WF3-YYYY-NNNN 2025-02665, 2025-03000, 2024-01597

35 Inspection Procedure Type Designation Description or Title Revision or Date 71152A Work Orders WO-54250445, 54127766, 555211 71153 Corrective Action Documents CR-WF3-YYYY-NNNN 2024-04591, 2024-05222, 2024-05931, 2025-00335, 2025-00378, 2025-00782, 2025-00195, 2024-02557, 2024-04819, 2024-05854, 2025-00675 71153 Work Orders WO-54303371