ML25216A248

Waterford Steam Electric Station - Integrated Inspection Report 05000382/2025002

ML25216A248
Person / Time
Site:	Waterford
Issue date:	08/06/2025
From:	John Dixon NRC/RGN-IV/DORS/PBD
To:	Sullivan J Entergy Operations
Chambliss K
References
EA-24-052 IR 2025002
Download: ML25216A248 (1)

Text

August 06, 2025 EA-24-052 Joseph Sullivan, Site Vice President Entergy Operations Inc.

17265 River Road Killona, LA 70057

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - INTEGRATED INSPECTION REPORT 05000382/2025002

Dear Joseph Sullivan:

On June 30, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Waterford Steam Electric Station, Unit 3. On July 21, 2025, 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.

Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Waterford Steam Electric Station, Unit 3.

J. Sullivan 2

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, 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 08/06/25

ML25216A248

SUNSI Review By: AAS

Non-Sensitive

Sensitive

Publicly Available

Non-Publicly Available OFFICE SRI:DORS/PBD RI:DORS/PBD SPE:DORS/PBD BC:DORS/PBD NAME KChambliss KCook-Smith ASanchez JDixon SUGNATURE

/RA/

/RA/

/RA/

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DATE 08/04/25 08/04/25 08/05/25 08/06/25

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

05000382 License Number:

NPF-38 Report Number:

05000382/2025002 Enterprise Identifier:

I-2025-002-0003 Licensee:

Entergy Operations Inc.

Facility:

Waterford Steam Electric Station, Unit 3 Location:

Killona, LA 70057 Inspection Dates:

April 1, 2025, to June 30, 2025 Inspectors:

K. Chambliss, Senior Resident Inspector K. Cook-Smith, Resident Inspector J. Drake, Senior Reactor Inspector N. Greene, Senior Health Physicist S. Hamilton, Project Engineer J. O'Donnell, Senior Health Physicist A. Smallwood, Senior Resident Inspector Approved By:

John L. Dixon, Jr., Chief Reactor Projects Branch D Division of Operating Reactor Safety

2

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting 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.

List of Findings and Violations Preventive Maintenance Planning Failed to Prevent a Safety-Related Valve Failure and Inoperability of an Emergency Diesel Generator Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2025002-01 Open/Closed None (NPP) 71111.15 The inspectors reviewed a self-revealed Green finding and associated non-cited violation of 10 CFR 50, Appendix B, Criterion V Instructions, Procedures and Drawings. Specifically, the licensee failed to develop and implement preventive maintenance strategies for the condensate makeup solenoids in the emergency diesel generators in accordance with procedure EN-DC-324, Preventive Maintenance Program.

Failure to Establish Adequate Surveillance Initial Conditions Resulted in Inadvertent Emergency Feedwater Isolation System Actuation and Reactor Protection Actuation Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000382/2025002-02 Open/Closed None (NPP) 71153 The inspectors reviewed a self-revealed Green finding and associated non-cited violation of Technical Specification 6.8.1a, Procedures and Programs. Specifically, the licensee failed to properly implement procedure OP-903-014, Emergency Feedwater Flow Verification, during a planned startup which resulted in the inadvertent emergency feedwater actuation signal and an inadvertent reactor protection signal. The initial conditions for the procedure did not provide adequate margin to account for shrink caused by the initiation of emergency feedwater into the steam generator resulting in steam generator water level dropping below the emergency feedwater actuation signal and reactor protection signal actuation setpoint.

Additional Tracking Items Type Issue Number Title Report Section Status LER 05000382/2024-003-00 Automatic EFAS Actuation During Surveillance Test 71153 Closed NOV 05000382/2024013-01 Failure to Perform an Adequate Steam Generator (SG) Operational Assessment EA-24-052 71153 Closed

3 PLANT STATUS Unit 3 began the inspection period at 94 percent rated thermal power. On April 26, 2025, the unit was shut down for refueling outage 26. On June 8, 2025, the unit restarted and reached 91 percent rated thermal power on June 13, 2025, and remained at 91 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 71111.01 - Adverse Weather Protection Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal hot temperatures and hurricane and tropical storm season for the following systems:

(1) ultimate heat sink, safety-related switchgear, safety injection, and emergency diesel generators on June 27, 2025 71111.04 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01) (1 Sample)

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

(1) emergency feedwater trains A and B on June 2, 2025 Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1)

The inspectors evaluated system configurations during a complete walkdown of the 4160VAC train A safety bus system on May 28, 2025.

4 71111.05 - Fire Protection Fire Area Walkdown and Inspection Sample (IP Section 03.01) (9 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 8C-001, elevation +21 switchgear room A/B on April 3, 2025 (2) fire area reactor auxiliary building 5-001, elevation +35 electrical penetration room B on April 3, 2025 (3) fire area reactor control building-001, elevations -4, +21, +46 containment on May 1, 2025 (4) fire area reactor auxiliary building 8A-001, elevation +21 switchgear room A on May 5, 2025 (5) fire area reactor auxiliary building 16-001, elevation +21 emergency diesel generator 3A on May 5, 2025 (6) fire area turbine building, elevation +15 turbine generator building switchgear/east on May 7, 2025 (7) fire area reactor auxiliary building 37-001, elevation -35 motor driven emergency feed pump room A on May 8, 2025 (8) fire area reactor auxiliary building 36-001, elevation -35 safety injection pump room A on May 8, 2025 (9) fire area reactor auxiliary building 2-001, elevation +46 H&V mechanical room on June 11, 2025 71111.08P - Inservice Inspection Activities (PWR)

The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundaries were appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities in Waterford Unit 3 during refueling outage 26 from April 28 to May 5, 2025.

PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01) (1 Sample)

The inspectors verified that the following nondestructive examination and welding activities were performed appropriately:

(1)

Ultrasonic Examination 1.

chemical and volume control, MVAAA216A, weld SW-18, pipe to valve 2.

chemical and volume control, MVAAA216A, weld SW-19, pipe to valve 3.

shutdown cooling, weld 21-004, pipe to pipe 4.

shutdown cooling, weld 21-007, elbow to pipe 5.

shutdown cooling, weld 21-009, pipe to elbow Digital Radiographic Examination 1.

chemical and volume control, MVAAA216A, weld SW-18, pipe to valve 2.

chemical and volume control, MVAAA216A, weld SW-19, pipe to valve

5 Dye Penetrant Examination 1.

chemical and volume control, MVAAA216A, weld SW-18, pipe to valve 2.

chemical and volume control, MVAAA216A, weld SW-19, pipe to valve 3.

chemical and volume control, FW-1, seal weld on CVCISV0216 A valve 4.

containment spray, support CSRR035A Visual 2 Examination 1.

chemical and volume control, MVAAA2 16 A, pressurizer auxiliary spray valve A Visual 3 Examination 1.

safety injection, pipe hangar SIRR-220 2.

safety injection, pipe hangar SIRR-498 3.

containment spray, support CSRR035 The inspectors reviewed the following volumetric and surface examination records for relevant indications from the previous outage that the licensee analytically evaluated and accepted for continued service:

1.

CCRR-1184, rigid restraint EC 54082002 evaluated the support as acceptable to remain in service. Reference W-ISI-EV-23-002 2.

CCRR-0322 rigid restraint EC 54071759 evaluated the support as acceptable to remain in service. Reference W-ISI-EV-23-00 I 3.

CCRR-0393 rigid restraint EC 54088042 evaluated the support as acceptable to remain in service. Reference CR-WF3-2023-I 7773 Welding Activities 1.

gas tungsten arc welding a.

chemical and volume control, MVAAA216A, weld SW-18, pipe to valve b.

chemical and volume control, MVAAA216A, weld SW-18, pipe to valve c.

chemical and volume control, MVAAA2 16A, weld FW-1, pressurizer auxiliary spray valve A d.

extraction steam, ES-7101A/B, bypass line, FW-9 e.

extraction steam, ES-7101A/B, bypass line, FW-10 PWR Inservice Inspection Activities Sample - Vessel Upper Head Penetration Inspection Activities (IP Section 03.02)

There was no ASME code required vessel upper head penetration inspection of this outage.

PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03) (1 Sample)

The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following screenings and evaluations:

(1) 1.

22-0020, CVCMVAAA115 2.

22-0037, SI MPMP0002-A 3.

23-0006, SI MVAAA205-A 4.

23-0014, CS MVAAA122-A 5.

23-0012, SI IFT 1307-A 6.

23-0017, CS MVAAA113-A

6 7.

23-0018, SI MVAAA416-B 8.

23-0021, SI MVAAA221-A 9.

24-0006, SI MVAAA115-A

10. 24-0010, CVCMVAAA40631

11. 24-0011, FSMPMP0003

12. 24-0012, SI MVAAA2392

13. 24-0013, RC MRCT0001/1RC42-1RL1

14. 24-0014, RC MPMP0002-B

15. 24-0015, SI MVAAA407-A

16. 24-0016, SI MVAAA403-A

17. 24-0017, SI MVAAA335-A

18. 24-0018, SI MVAAA2401

19. 24-0019, SI MVAAA126-A

20. 24-0020, SI MVAAA112-A

21. 24-0021, SI MVAAA6061-B

22. 24-0022, SI MVAAA413-B

23. 24-0023, SI MVAAA2032-B

24. 24-0024, SI MVAAA2031-A

25. 24-0025, CVCMVAAA1922-A

26. 24-0026, SI MVAAA605-A

27. 24-0027, BM MVAAA121

28. 24-0028, BAMMVAAA131-B

29. 24-0029, SI MVAAA1142-B

30. 24-0030, SI MVAAA126-B

31. 24-0031, CS MVAAA113-B

32. 24-0032, CS MVAAA116-B

33. 25-0001, FS MVAAA404

34. 25-0002, CS MPMP0001-A

35. 25-0003, CS MVAAA116-B

36. 25-0004, CS MVAAA113-B

37. 25-0006, SI MVAAA115-A PWR Inservice Inspection Activities Sample - Steam Generator Tube Inspection Activities (Section 03.04) (1 Sample)

There was no ASME code required steam generator tube integrity inspection required this outage.

(1)

The inspectors evaluated the response to cited violation 05000382/2024013-01 as well as the independent third-party operational assessment for the steam generators for operating cycles 21 through 25.

The inspectors reviewed the licensee's response to NOV 05000382/2024013-01 and determined the reason, corrective actions taken and planned to address recurrence, and the date when full compliance was achieved for this violation. Full compliance was achieved on November 11, 2023, once the steam generator tubes that exceeded the structural integrity criteria were plugged and stabilized. This issue has been adequately addressed and captured on the docket.

7 71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(2 Samples)

(1)

The inspectors observed and evaluated licensed operator performance in the control room during main steam safety valve simmer testing on April 23, 2025.

(2)

The inspectors observed and evaluated licensed operator performance in the control room during reactor startup on June 6, 2025.

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

(1)

The inspectors observed and evaluated licensed operator just in time training for reactor startup in the simulator on May 31, 2025.

71111.12 - Maintenance Effectiveness Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) various quality control activities of safety-related maintenance during spring refueling outage including radiation monitor relay replacements, 125V battery maintenance, emergency safety features actuation signal relay maintenance, and essential chill water train B isolation valve maintenance on June 1, 2025 71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) yellow outage risk due to startup nuclear instrument channel 1 replacement on April 28, 2025 (2) yellow outage risk due to lowered inventory conditions on April 30, 2025 (3) yellow risk due to extensive oil leak on auxiliary component cooling water pump A on May 5, 2025 (4) yellow risk due to extensive safety bus train B work window on May 15, 2025 (5) yellow risk due to 125VDC train A battery being disconnected for maintenance on May 24, 2025 (6) orange risk due to unplanned emergency feedwater pump AB inoperability on June 3, 2025 71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

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

(1) emergency diesel generator A failure due to a failed condensate makeup solenoid valve on April 16, 2025 (2) emergency diesel generator B failure to pass post-maintenance testing following governor replacement and tuning on June 18, 2025 (3) containment purge isolation radiation monitor converter board missing a resistor and a capacitor on June 18, 2025 (4) emergency diesel generator B due to elevated copper in outboard bearing oil on June 30, 2025 71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

(2 Samples)

(1) temporary wiring modification for cold-leg temperature input to core protection calculator A on May 2, 2025 (2) permanent modification of second permissive relay for engineered safety features actuation system train B main steam isolation signal and containment spray actuation signal actuation relays to eliminate single point vulnerability on June 28, 2025 71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1)

The inspectors evaluated refueling outage 26 activities from April 25 to June 8, 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) (11 Samples)

(1) post-maintenance testing on nitrogen accumulator No. 3 pressure switches following replacement on April 9, 2025 (2) post-maintenance testing on emergency diesel generator B following governor replacement on June 23, 2025 (3) post-maintenance testing of train B 125VDC battery following outage maintenance window on June 24, 2025 (4) post-maintenance testing of pressurizer vents to quench tank header isolation valve testing following maintenance on June 24, 2025 (5) post-maintenance testing of containment spray train B header isolation valve following outage maintenance activities on June 24, 2025 (6) post-maintenance testing of emergency feed water pump AB following seal replacement due to excessive water leakage on June 26, 2025 (7) post-maintenance testing following repairs of pressurizer auxiliary spray valve train A on June 26, 2025

9 (8) post-maintenance testing following maintenance activities on component cooling water train B on June 27, 2025 (9) post-maintenance testing and system verification for emergency diesel generator train A following maintenance window during refueling outage on June 27, 2025 (10) post-maintenance testing of plant protection system following emergency feedwater actuation system component replacements on June 27, 2025 (11) post-maintenance testing of engineered safety features subgroup relay following component replacements on June 30, 2025 Surveillance Testing (IP Section 03.01) (5 Samples)

(1) safety injection valve SI-207B, high pressure safety injection pump B discharge check valve, quarterly surveillance valve test on April 25, 2025 (2) safety injection valve SI-120A, safety injection recirculating header A to refueling water storage pool upstream isolation valve, motor operated valve diagnostic test on May 9, 2025 (3)

N+1 FLEX water transfer pump 3-year surveillance test on June 11, 2025 (4) emergency diesel generator B integrated testing on June 25, 2025 (5) emergency feedwater flow verification test on June 26, 2025 Inservice Testing (IST) (IP Section 03.01) (1 Sample)

(1) train A auxiliary component cooling water operability test on April 21, 2025 Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)

(1) containment isolation valve testing during refueling outage 26 on June 30, 2025 Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)

(1)

N+1 FLEX diesel 3-year 100 percent load test on May 13, 2025 RADIATION SAFETY 71124.01 - Radiological Hazard Assessment and Exposure Controls Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1)

The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels, identifies the concentrations and quantities of radioactive materials, and assesses radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1)

The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)

10 The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) surveys of potentially contaminated material leaving the radiologically controlled area (2) workers exiting the containment building during a refueling outage Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)

The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:

(1) preparation for the removal of the upper guide structure using radiation work permit 2025-1702, Revision 0, task 7 (2) removal and replacement of manual valve CVCMVAAA105 in the regenerative heat exchanger room using radiation work permit 2025-1454, Revision 0, task 4 (3) removal and inspection of check valve SI MVAAA604 B in the overhead of the reactor auxiliary building -35' elevation using radiation work permit 2025-1454, Revision 0, task 2 High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)

The inspectors evaluated licensee controls of the following high radiation areas (HRAs) and very high radiation areas (VHRAs):

(1)

(HRA) spent resin tank room on the -35' elevation of the reactor auxiliary building (2)

(HRA) boric acid pre-concentration filter cubicles A and B on the -35' elevation of the reactor auxiliary building (3)

(HRA) purification ion exchanger rooms A and B on the -4' elevation of the reactor auxiliary building (4)

(HRA) chemical and volume control filter cubicle on the -4' elevation of the reactor auxiliary building (5)

(HRA) process shield No.1 in the radwaste solidification building Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)

(1)

The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation Permanent Ventilation Systems (IP Section 03.01) (2 Samples)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) control room emergency filtration, units A and B (2) controlled ventilation areas filter, units A and B Temporary Ventilation Systems (IP Section 03.02) (2 Samples)

11 The inspectors evaluated the configuration of the following temporary ventilation systems:

(1) high-efficiency particulate air (HEPA) filter set up for decontamination work, May 5-6, 2025 (2)

HEPA filter usage for work associated with RWP 20251454, May 6, 2025 Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1)

The inspectors evaluated the licensees use of respiratory protection devices.

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1)

The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.

OTHER ACTIVITIES - BASELINE 71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)

(1)

April 1, 2024, through March 31, 2025 OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1)

April 1, 2024, through December 31, 2024 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1)

April 1, 2024, through December 31, 2024 71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03) (2 Samples)

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

(1)

Failure of the emergency diesel generator A to reach 4600-4800 KW loading. The inspection conclusions associated with this issue are documented as a minor violation in this report under Inspection Results Section.

(2)

The inspectors reviewed as a selected issue for follow-up a Green non-cited violation of 10 CFR 50 Appendix B Criterion V (as issued in Waterford Steam Electric Station, Unit 3 Inspection Report 05000383/20240002, ADAMS Accession No. ML24215A277) for failure to provide adequate guidance and instructions when taking an oil sample from an operating auxiliary component cooling water pump motor which caused a bearing failure and the pump to become inoperable. The inspectors

12 reviewed the causal product, the corrective actions, and reviewed recent oil sampling briefings. The inspectors determined the licensees actions and responses for the Green non-cited violation to be adequate.

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02) (1 Sample)

(1)

The inspectors reviewed the licensees corrective action program to identify potential trends in the emergency diesel generator that might be indicative of a more significant safety issue.

The inspectors performed a semi-annual trend review of the sites recent issues with unplanned emergency diesel generator inoperabilities. These issues have resulted from maintenance practices, work planning practices, and engineering practices.

Each individual issue has resulted in regulatory action. During the course of the semi-annual trend review, the licensee developed an internal comprehensive review of the recent emergency diesel generator trends to assess any common cause amongst the issues. Additionally, the licensee elevated two emergency diesel generator issues to full root cause evaluations. These root cause evaluations will be inspected using a separate inspection procedure. The inspectors determined the sites approach to determining the cause of the issue trend, the corrective actions, and planned actions are adequate.

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02) (1 Sample)

(1)

LER 05000382/2024-003-00, Automatic EFAS Actuation During Surveillance Testing (ADAMS Accession No. ML24192A173). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section. This LER is closed (2)

Enforcement Action Number: EA-24-052, Inspection Report 05000382/2024013 (ADAMS Accession No. ML24228A261). The inspectors evaluated the response to cited violation 05000382/2024013-01 as well as the independent third-party operational assessment for the steam generators for operating cycles 21 through 25.

The inspectors reviewed the licensee's response to NOV 05000382/2024013-01 and determined the reason, corrective actions taken and planned to address recurrence, and the date when full compliance was achieved for this violation. Full compliance was achieved on November 11, 2023, once the steam generator tubes that exceeded the structural integrity criteria were plugged and stabilized. This issue has been adequately addressed and captured on the docket.

13 INSPECTION RESULTS Preventive Maintenance Planning Failed to Prevent a Safety-Related Valve Failure and Inoperability of an Emergency Diesel Generator Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2025002-01 Open/Closed None (NPP) 71111.15 The inspectors reviewed a self-revealed Green finding and associated non-cited violation of 10 CFR 50, Appendix B, Criterion V Instructions, Procedures and Drawings. Specifically, the licensee failed to develop and implement preventive maintenance strategies for the condensate makeup solenoids in the emergency diesel generators in accordance with procedure EN-DC-324, Preventive Maintenance Program.

==

Description:==

On March 16, 2025, emergency diesel generator A (EDG A) was declared inoperable due to jacket water temperature falling below its alarm setpoint of 100°F, to approximately 95°F. According to a 2005 evaluation by the licensee, a 10 second start of the diesel cannot be guaranteed with jacket water temperatures below 100°F; the 10-second diesel start time is a technical specification (TS) requirement. The lowered jacket water temperature was due to condensate makeup solenoid valve, CMU-524A, failing open, which provided constant flow through the system from the condensate storage pool, through the jacket water heat exchanger, to the jacket water standpipe overflow line. Troubleshooting of the valve found that the solenoids coil had failed.

During investigation of the failure, it was found that the valve was incorrectly classified as non-critical, high duty cycle, mild environment. This classification resulted in no preventive maintenance strategy for this valve. In accordance with procedure EN-DC-153, Preventive Maintenance Component Classification, revision 24, the solenoid valve should have been classified as high critical, high duty cycle, mild environment due to the valves failure resulting in the inoperability of EDG A.

It was also found that the current testing of the valve only included quarterly testing of open and close stroke times. The licensee reviewed this data for both CMU-524A and CMU-524B and found very little variance in results. This data shows that these valves remain operable during testing, but they do not adequately predict a failure of the solenoid operated valve. In accordance with procedure EN-DC-324, Preventive Maintenance Program, revision 31, successful implementation of a [Preventive Maintenance] Program should ultimately result in the identification of optimum level of [preventive maintenance] tasks necessary to achieve balance between plant equipment performance and effective use of resources. The licensee failed to adequately identify the optimum level of tasks to predict or prevent failure of CMU-524A. In order to identify the correct preventive maintenance strategy, the licensee used their own operating experience for the service life of these valves (22 years for CMU-524A and 30 years for CMU-524B), and industry guidance (20 year recommended coil replacement) to determine the correct maintenance periodicity.

Corrective Actions: The licensee initiated a condition report to enter this issue into the corrective action program. The condition report initiated an equipment failure evaluation with the following corrective actions: 1) issue a preventive maintenance change to revise the coding of the valve and create a 15-year replacement preventive maintenance for CMU-524A

14 and CMU-524B, and 2) perform an extent of condition for EDG components that may be currently classified incorrectly or not have a preventive maintenance strategy that could potentially effect EDG operability.

Corrective Action References: CR-WF3-2025-00951.

Performance Assessment:

Performance Deficiency: The failure to develop and implement a replacement preventive maintenance strategy for the condensate makeup solenoid coils was a performance deficiency.

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 availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to properly implement replacement preventive maintenance strategies resulted in the failure of the condensate makeup valve coil, challenged the ability of the diesel to meet TS requirements, and resulted in inoperability of EDG A.

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 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 probability risk analysis (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 e-book 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: No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion V Instructions, Procedures and Drawings, states in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances. The licensee established procedure EN-DC-324, Preventive Maintenance Program, Revision 31, in part to meet this requirement.

Contrary to the above, from 1989 to March 16, 2025, the licensee failed to adequately establish a preventive maintenance strategy in accordance with their quality procedure for the replacement of the condensate makeup solenoid valve coil, which resulted in the inoperability of emergency diesel generator A. Specifically, the licensee failed to properly classify the solenoid valves as high critical components due to their failure effecting the operability of the emergency diesel generators, and subsequently failed to develop a preventive maintenance

15 strategy adequate to predict and prevent failures of the valve which resulted in the inoperability of EDG A.

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

Minor Violation 71152A Minor Violation: Title 10 CFR 50, Appendix B, Criterion III Design Control, states in part, that measures shall be established to assure that applicable regulatory requirements and the design basis for systems, structures and components are correctly translated into specifications, drawings, procedures and instructions and that measures also be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the SSCs. The licensee established procedure EN-DC-115, Engineering Change Process, revision 15, in part to meet this requirement.

Contrary to the above, from 2013 to February 8, 2025, the licensee failed to adequately assure that the design basis was correctly translated into specifications, procedures, and instructions for emergency diesel generator A. Specifically, the licensee did not adequately evaluate the digital reference unit (DRU) high limit droop setpoint during the engineering change process, nor did the licensee adequately evaluate vendor recommendations for the DRU high limit droop setpoint during the causal analysis process. The emergency diesel generator only operates in the droop mode of operation when paralleling to the grid, therefore this setpoint does not affect the isochronous mode of the diesel used in an emergency; however, the inadequate evaluation of the setpoint resulted in emergency diesel generator A not being able to achieve 4700-4900 KW during the 24-hour diesel surveillance as required by technical specifications and resulted in the inoperability of the diesel.

Screening: The inspectors determined the performance deficiency was minor. Based on review of more-than-minor questions in IMC 0612, appendix B, informed by minor issue examples for performance deficiencies (IMC 0612, appendix E), this issue screens to minor.

Specifically, due to the fact the emergency diesel generator only operates in isochronous mode during an emergency run, this performance deficiency did not adversely affect a cornerstone objective, would not lead to a more significant safety concern if left uncorrected, and could not reasonably by viewed as a precursor to a significant event.

Enforcement: This failure to comply with 10 CFR 50, Appendix B, Criterion III Design Control constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Failure to Establish Adequate Surveillance Initial Conditions Resulted in Inadvertent Emergency Feedwater Isolation System Actuation and Reactor Protection Actuation Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000382/2025002-02 Open/Closed None (NPP) 71153 The inspector reviewed a self-revealed Green finding and associated non-cited violation of Technical Specification 6.8.1a, Procedures and Programs. Specifically, the licensee failed to properly implement procedure OP-903-014, Emergency Feedwater Flow Verification, during

16 a planned startup which resulted in the inadvertent emergency feedwater actuation signal and an inadvertent reactor protection signal. The initial conditions for the procedure did not provide adequate margin to account for shrink caused by the initiation of emergency feedwater into the steam generator resulting in steam generator water level dropping below the emergency feedwater actuation signal and reactor protection signal actuation setpoint.

==

Description:==

On July 17, 2024, during a reactor startup, while in Mode 3, the site performed a surveillance of the emergency feed water pump AB in accordance with procedure OP-903-014, Emergency Feedwater Flow Verification. As allowed per the procedure at the time, the site lowered steam generator 1 water level to 30 percent upon initiating emergency feed flow per procedure OP-903-014, the initial shrink caused by the introduction of emergency feedwater due to the difference in enthalpies between the condensate storage pool and the steam generator resulted in steam generator 1 water level dropping below 27.4 percent which corresponds to the reactor trip signal and the emergency feed actuation signal setpoints.

Since all control element assemblies were fully inserted and all control element assembly disconnects were open, no reactor trip occurred; however, the reactor trip circuit breakers did open on the valid reactor trip actuation signal. Additionally, the entire emergency feed system did fully actuate as designed on a valid loss of steam generator water level signal. The operators took manual control of the emergency feed system and restored steam generator water level above emergency feed actuation signal reset setpoint.

In a previous revision of procedure OP-903-014 from at least before 1999, the licensee procedures initial conditions stated the steam generator level should be above at least 27.4 percent, which corresponds to the reactor trip signal and the emergency feed actuation signal setpoints. The site recognized the need for additional margin to prevent an inadvertent trip condition and established the initial conditions to be at least 30 percent steam generator water level. In the most recent performances of the surveillance, the site established a steam generator water level of at least 39.78 percent or higher. In each of these previous surveillances, the steam generator water level did experience an initial shrink when emergency feedwater was initiated. When revising the initial conditions of the minimum steam generator water level for the emergency feedwater flow surveillance from 27.4 to 30 percent, the site did not adequately assess for the effects of shrink and established adequate initial conditions to prevent an unplanned initiation of the emergency feedwater actuation signal nor a reactor trip.

Corrective Actions: The licensee initiated a condition report to enter this issue into the corrective action program. The condition report initiated an adverse condition analysis with the following corrective action: revise procedure OP-903-014 to provide a more restrictive steam generator level control band to provide adequate margin to the emergency feedwater actuation signal (EFAS) and reactor protection signal (RPS) trip setpoint.

Corrective Action References: CR-WF3-2024-02523 Performance Assessment:

Performance Deficiency: The failure to implement adequate initial conditions for the performance of a surveillance affecting safety-related equipment was a performance deficiency. Specifically, the failure to implement a restrictive steam generator level control band prior to manually initiating emergency feedwater flow resulted in steam generator 1 water level dropping below the EFAS and RPS trip setpoint causing an inadvertent initiation of both EFAS and RPS.

17 Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to implement adequate initial conditions prior to the manual initiation of emergency feedwater pump AB resulted in an unplanned actuation of EFAS system components and an unplanned actuation of RPS components due to steam generator 1 water level dropping below the trip setpoint.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.

Specifically, this event did not cause a reactor trip, did not prevent safety systems such as emergency feedwater from operating as designed, and did not prevent main feedwater from being returned to service by the operators.

Cross-Cutting Aspect: No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: Technical Specification 6.8.1.a, Procedures and Programs, states in part, that 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 3.k Procedures for Startup, Operation, and Shutdown of Safety-Related PWR Systems, states, in part, that instructions for the startup, shutdown, and changing modes of operation should be prepared, as appropriate, for the feedwater system.

Contrary to the above, from 1999 to July 17, 2024, the licensee failed to prepare, as appropriate, instructions for the startup, shutdown, and changing modes of operation for the feedwater system. Specifically, the licensee failed to establish adequate initial conditions for the performance of a surveillance for the emergency feedwater system which resulted in the steam generator 1 water level dropping below the EFAS and RPS trip setpoints and causing an inadvertent EFAS and RPS actuation.

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 May 5, 2025, the inspectors presented the exit meeting for inservice inspection results to David Oertling, General Manager Plant Operations, and other members of the licensee staff.

18 On May 10, 2025, the inspectors presented the occupational radiation safety inspection results to Joeseph Sullivan, Site Vice President, and other members of the licensee staff.

On July 21, 2025, the inspectors presented the integrated inspection results to Joseph Sullivan, Site Vice President, and other members of the licensee staff.

19 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date 71111.01 Miscellaneous EN-WM-112, Site Certification Letter and Seasonal Reliability Plan 0

71111.01 Procedures EN-FAP-010 Severe Weather Response 10 71111.01 Work Orders 5255494, 5419260, 54202873 71111.04 Corrective Action Documents CR-WF3-YYYY-NNNNN 2024-00759, 2024-00148, 2024-03504, 2025-01051, 2025-01765, 2025-02626, 2025-02632, 2025-02706, 71111.04 Drawings 1564-4331 4.16 KV Class 1E SWGR Installation Details 2

71111.04 Drawings 1564-6242 4.16 KV Switchgear 3A2 Element Diagram, Sheet 1 0

71111.04 Procedures OP-006-001 Plant Distribution (7KV, 4KV, and SSD) Systems 351 71111.04 Procedures OP-009-003 System Operating Procedure Emergency Feedwater 313 71111.04 Procedures OP-010-004 Power Operations 350 71111.04 Procedures OP-010-005 Plant Shutdown 350 71111.04 Procedures OP-901-310 Loss of Train A Safety Bus 317 71111.05 Corrective Action Documents CR-WF3-YYYY-NNNNN 2022-03613, 2022-03592, 2024-01190, 2024-01330, 2024-01684 71111.05 Fire Plans RAB 2-001 H&V Mechanical Room 16 71111.05 Fire Plans RAB 36-001 Safety Injection Pump Room A 11 71111.05 Fire Plans RAB 5-001 Electrical Penetration Room B 11 71111.05 Fire Plans RAB 8A-001 Switchgear Room A 14 71111.05 Fire Plans RAB 8C-001 Switchgear Room A/B 13 71111.05 Fire Plans RAB-16-001 Emergency Diesel Generator 3A 13 71111.05 Fire Plans RAB-37-001 Motor Driven Emergency Feed Pump Room A 9

71111.05 Procedures EN-EE-S-048-W Fire Detector Replacement Standard 00 71111.05 Procedures FP-001-015 Fire Protection System Impairments 335 71111.08P Corrective Action Documents CR-WF3-YYYY-NNNNN 2022-01839, 2022-01891, 2022-01900, 2022-01901, 2022-01929, 2022-01945, 2022-01949, 2022-01960, 2022-01977, 2022-01978, 2022-01979, 2022-01993, 2022-02011, 2022-02012, 2022-02013, 2022-02014, 2022-02015, 2022-02016, 2022-02017, 2022-02018, 2022-02029, 2022-02030, 2022-02031, 2022-02032, 2022-02142, 2022-02156, 2022-02178, 2022-02287, 2022-02289, 2022-02291, 2022-02293, 2022-02295,

20 Inspection Procedure Type Designation Description or Title Revision or Date 2022-02296, 2022-02301, 2022-02302, 2022-02303, 2022-02304, 2022-02307, 2022-02309, 2022-02310, 2022-02312, 2022-02314, 2022-02385, 2022-02387, 2022-02401, 2022-02449, 2022-02452, 2022-02461, 2022-02462, 2022-02463, 2022-02491, 2022-02555, 2022-02630, 2022-02639, 2022-02703, 2022-02730, 2022-02731, 2022-02732, 2022-02736, 2022-02741, 2022-02742, 2022-02814, 2022-02821, 2022-02937, 2022-03003, 2022-03016, 2022-03017, 2022-03018, 2022-03085, 2022-03086, 2022-03449, 2022-03452, 2022-03501, 2022-03506, 2022-03846, 2022-03959, 2022-03975, 2022-03979, 2022-04023, 2022-04178, 2022-04279, 2022-04280, 2022-04290, 2022-04392, 2022-04649, 2022-04650, 2022-04651, 2022-04656, 2022-04658, 2022-04659, 2022-04661, 2022-04662, 2022-04664, 2022-04665, 2022-04667, 2022-04670, 2022-04672, 2022-04673, 2022-04675, 2022-04987, 2022-04988, 2022-04989, 2022-04990, 2022-04992, 2022-04993, 2022-04994, 2022-04995, 2022-04996, 2022-04998, 2022-05000, 2022-05126, 2022-05132, 2022-05133, 2022-05134, 2022-05135, 2022-05136, 2022-05138, 2022-05139, 2022-05145, 2022-05146, 2022-05147, 2022-05148, 2022-05149, 2022-05150, 2022-05151, 2022-05221, 2022-05270, 2022-05403, 2022-06402, 2022-06403, 2022-06404, 2022-06405, 2022-06406, 2022-06407, 2022-06408, 2022-06409, 2022-06411, 2022-06412, 2022-06413, 2022-06414, 2022-06415, 2022-06609, 2022-06617, 2022-06779, 2022-06895, 2022-06896, 2022-06897, 2022-06898, 2022-06899, 2022-06900, 2022-06901, 2022-06902, 2022-06903, 2022-06904, 2022-06905, 2022-06906, 2022-06907, 2022-06908, 2022-06909, 2022-06910, 2022-06911, 2022-06912, 2022-06915, 2022-07340, 2022-07636, 2022-08022, 2022-08024, 2022-08036,

21 Inspection Procedure Type Designation Description or Title Revision or Date 2022-08054, 2022-08055, 2022-08056, 2022-08060, 2022-08061, 2022-08062, 2022-08066, 2022-08069, 2022-08071, 2022-08073, 2022-08076, 2022-08078, 2023-00044, 2023-00046, 2023-00049, 2023-00054, 2023-00055, 2023-00056, 2023-00058, 2023-00060, 2023-00061, 2023-00062, 2023-00063, 2023-00064, 2023-00065, 2023-00066, 2023-00083, 2023-00179, 2023-00180, 2023-00399, 2023-00418, 2023-00518, 2023-00623, 2023-00726, 2023-00792, 2023-01008, 2023-01026, 2023-01215, 2023-01298, 2023-01303, 2023-01304, 2023-01305, 2023-01306, 2023-01313, 2023-01315, 2023-01316, 2023-01317, 2023-01343, 2023-01700, 2023-01702, 2023-01703, 2023-01705, 2023-01707, 2023-01709, 2023-01712, 2023-01716, 2023-01717, 2023-01726, 2023-01729, 2023-01731, 2023-01773, 2023-01774, 2023-01972, 2023-01989, 2023-02142, 2023-02169, 2023-02251 71111.08P Corrective Action Documents Resulting from Inspection CR-WF3-YYYY-NNNNN 2025-01683, 2025-01690, 2025-01787, 2025-01810, 2025-01820, 2025-01823, 2025-01851, 2025-1904 71111.08P Miscellaneous W3F1-2024-0041 Reply to a Notice of Violation, EA-24-052 Waterford Steam Electric Station, Unit 3 Docket No. 50-382 Renewed Facility Operating License No. NPF-38 11/19/2024 71111.08P Miscellaneous Weld package CVC MVAAA2 16 A, pressurizer aux spray valve A 0

71111.08P Procedures CEP-BAC-001 Boric Acid Corrosion Control (BACC) Program Plan 2

71111.08P Procedures CEP-NDE-0404 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) 9 71111.08P Procedures CEP-NDE-0407 Straight Beam Ultrasonic Examination of Bolts and Studs (ASME XI) 6 71111.08P Procedures CEP-NDE-0423 Manual Ultrasonic Examination of Austenitic Piping Welds (ASME XI) 10 71111.08P Procedures CEP-NDE-0641 Liquid Penetrant Examination (PT) for ASME Section XI 10 71111.08P Procedures CEP-NDE-0731 Magnetic Particle Examination (MT) for ASME Section XI 7

22 Inspection Procedure Type Designation Description or Title Revision or Date 71111.08P Procedures CEP-NDE-0901 VT-1 Examination 6

71111.08P Procedures CEP-NDE-0902 VT-2 Examination 10 71111.08P Procedures CEP-NDE-0903 VT-3 Examination 9

71111.08P Procedures CEP-WP-GWS-1 General Welding Standard ASME/ANSI 8

71111.08P Procedures EN-DC-127 Control of Hot Work and Ignition Sources 22 71111.08P Procedures EN-DC-319 Boric Acid Corrosion Control Program (BACCP) 15 71111.08P Procedures EN-DC-328 Entergy Nuclear Welding Program 8

71111.08P Procedures EN-DC-334 Primary Containment Leakage Rate Testing (Appendix J) 5 71111.08P Procedures EN-EV-112 Chemical Control Program 25 71111.08P Procedures EN-IS-109 Compressed Gas Cylinder Handling and Storage 8

71111.08P Procedures EN-IS-114 Fall Protection 17 71111.08P Procedures EN-MA-133 Control of Scaffolding 26 71111.08P Procedures SEP-APJ-005 Waterford 3 Primary Containment Leakage Rate Testing (Appendix J) Program 11 71111.08P Procedures SEP-BAC-WF3-001 Waterford 3 Boric Acid Corrosion Control Program (BACCP)

Program Section 1

71111.08P Procedures SEP-ISI-104 Program Section for ASME Section XI, Division 1 WF3 Inservice Inspection Program 16 71111.11Q Corrective Action Documents CR-WF3-YYYY-NNNNN 2024-05669 71111.11Q Procedures MM-007-015 Main Steam Safety Valve Test 332 71111.11Q Procedures OP-010-003 Plant Startup 371 71111.11Q Procedures OP-010-004 Power Operations 350 71111.11Q Procedures OP-010-005 Plant Shutdown 350 71111.11Q Procedures OP-010-007 Plant Cooldown 347 71111.11Q Work Orders 54061139 71111.12 Corrective Action Documents CR-WF3-YYYY-NNNNN 2025-00889, 2025-01024, 2025-01977, 2025-01980, 2025-02389, 2025-02583 71111.12 Procedures EN-QV-102 Quality Control Inspection Program 12 71111.12 Work Orders 53026924, 54122524, 54163201, 54163202, 54189378 71111.13 Corrective Action Documents CR-WF3-YYYY-NNNNN 2025-01400, 2025-02648, 2025-02653, 2025-02671, 2025-02673, 2025-02684, 2025-02706, 71111.13 Procedures EN-OM-132 Nuclear Risk Management Process 4

23 Inspection Procedure Type Designation Description or Title Revision or Date 71111.13 Procedures EN-OP-119 Protected Equipment Postings 19 71111.13 Procedures OP-001-003 Plant Shutdown 371 71111.13 Procedures OP-006-009 Electrical Bus Outages 35 71111.13 Procedures PLG-009-014 Conduct of Planned Outages 323 71111.13 Work Orders 54122485 71111.15 Corrective Action Documents CR-WF3-YYYY-NNNNN 2025-00049, 2025-00951, 2025-00966, 2025-01126 71111.15 Engineering Changes 0054260118 Operability Input - Emergency Diesel Generator B Outboard Generator Slinger Ring 71111.15 Procedures EN-DC-153 Preventive Maintenance Component Classification 24 71111.15 Procedures EN-DC-324 Preventive Maintenance Program 17 71111.18 Drawings B425-T122CA Reactor Coolant Cold Leg 2A Temperature Channel A 8

71111.18 Engineering Changes EC-5260652 Temporary Modification of 2A Cold Leg Temperature Loop RC IT0122-CA 0

71111.18 Engineering Changes EC-54172687 ESFAS Single Point Vulnerability Elimination Train B 0

71111.18 Work Orders 54163201, 54163202, 54261266 71111.20 Corrective Action Documents CR-WF3-YYYY-NNNNN 2025-01601, 2025-01627, 2025-01837, 2025-02165, 2025-02265, 2025-02422, 2025-02468, 2025-02617, 2025-02837 71111.20 Procedures EN-OM-123 Fatigue Management Program 20 71111.20 Procedures OP-001-003 Reactor Coolant System Drain Down 331 71111.20 Procedures OP-010-003 Plant Startup 371 71111.20 Procedures OP-010-005 Plant Shutdown 350 71111.20 Procedures OP-010-006 Outage Operations 347 71111.20 Procedures OP-903-24 Reactor Coolant System Water Inventory Balance 26 71111.20 Procedures PLG-009-014 Conduct of Planned Outages 323 71111.20 Procedures UNT-007-008 Control of Heavy and Critical Loads 324 71111.24 Corrective Action Documents CR-WF3-YYYY-NNNNN 2025-01603, 2025-01681, 2025-01815, 2025-02174, 2025-02175, 2025-02543 2025-02563 71111.24 Miscellaneous W3-DBD-4 Design Basis Document: Component Cooling Water and Auxiliary Component Cooling Water 307 71111.24 Procedures EN-MA-148 Motor Operated Valve Diagnostics 12

24 Inspection Procedure Type Designation Description or Title Revision or Date 71111.24 Procedures OP-903-014 Emergency Feedwater Flow Verification 319 71111.24 Procedures OP-903-033 Cold Shutdown IST Valve Tests 64 71111.24 Procedures OP-903-046 Emergency Feed Pump Operability Check 326 71111.24 Procedures OP-903-049 Component Cooling Water and Auxiliary Cooling Water Loop Operability Check 14 71111.24 Procedures OP-903-050 Component Cooling Water and Auxiliary Component Cooling Water Pump and Valve Operability Test 47 71111.24 Procedures OP-903-094 ESFAS Subgroup Relay Test - Operating 38 71111.24 Procedures OP-903-115 Train A Integrated Emergency Diesel Generator/Engineering Safety Features Test 61 71111.24 Procedures OP-903-116 Train B Integrated Emergency Diesel Generator/Engineering Safety Features Test 62 71111.24 Procedures OP-903-119 Secondary Auxiliaries Quarterly IST Valve Tests 38 71111.24 Procedures OP-903-121 Safety Systems Quarterly IST Valve Tests 37 71111.24 Procedures OP-903-121 Safety Systems Quarterly IST Valve Tests 37 71111.24 Procedures STA-001-001 Containment Air Lock Door Seal Leakage Test 304 71111.24 Work Orders 00558906, 00582638, 54073316, 54082875, 54082906, 54140427, 54141427, 54180650, 54183293, 54244318, 54065513, 54065510, 54127031, 00579184, 00579185, 00579197, 54140427, 54209905, 54078303, 54078293, 54139211, 54135480, 54132130, 54131774, 54119240, 54141427, 54125344, 54085283, 54131751, 54078403, 54093506, 53020780, 54094363, 54135260, 00559200, 54084263, 54067334, 54067334, 54078411, 54183293, 54074533, 54082906, 54082875, 54180650, 54085176, 54282661, 54034262, 54149050, 54115250, 54074824, 54273789, 54127020, 54092060 71124.01 ALARA Plans RWP 2025-1702 ALARA Plan 04/26/2025 71124.01 Corrective Action Documents CR-WF3-YYYY-NNNNN 2024-02475, 2024-02504, 2024-02827, 2024-03049, 2024-03360, 2024-03579, 2024-03580, 2024-04009, 2024-04655, 2024-04757, 2024-05200, 2024-05245, 2024-05671, 2024-05876, 2025-00019, 2025-00370, 2025-00718, 2025-00846, 2025-00929, 2025-01075, 2025-01197, 2025-01245, 2025-01247

25 Inspection Procedure Type Designation Description or Title Revision or Date 71124.01 Corrective Action Documents Resulting from Inspection CR-WF3-YYYY-NNNNN WF3-2025-01931, HQN-2025-00456 71124.01 Miscellaneous Waterford-3 RF26 RWP Status Report 05/08/2025 71124.01 Procedures EN-RP-101 Access Control for Radiologically Controlled Areas 17 71124.01 Procedures EN-RP-108 Radiation Protection Posting 24 71124.01 Procedures EN-RP-110 ALARA Program 14 71124.01 Procedures EN-RP-121 Radioactive Material Control 19 71124.01 Procedures EN-RP-122 Alpha Monitoring 10 71124.01 Procedures EN-RP-123 Radiological Controls for Highly Radioactive Objects 1

71124.01 Procedures EN-RP-131 Air Sampling 18 71124.01 Procedures HP-001-213 Control of Reactor Containment Building Power Entries 306 71124.01 Procedures RF-001-012 Upper Guide Structure 322 71124.01 Radiation Surveys WF3-2407-00033 RAB +21 Decontamination Area 07/02/2024 71124.01 Radiation Surveys WF3-2504-00098 Resin Sluice - post flushing of sluicing CVC IX C to Spent Resin Tank 04/09/2025 71124.01 Radiation Surveys WF3-2504-00150 PA/Outside RM Storage Area - quarterly survey 04/15/2025 71124.01 Radiation Surveys WF3-2504-00244 Rad Waste Compactor Building 04/25/2025 71124.01 Radiation Surveys WF3-2504-00254

-4' Reactor Containment Building - RF 26 initial entry 04/26/2025 71124.01 Radiation Surveys WF3-2504-00260

+21' Reactor Containment Building - RF 26 initial entry 04/26/2025 71124.01 Radiation Surveys WF3-2504-00264

+46' Reactor Containment Building - RF 26 initial entry 04/26/2025 71124.01 Radiation Surveys WF3-2504-00275

-11' Reactor Containment Building - RF 26 initial entry 04/26/2025 71124.01 Radiation Surveys WF3-2504-00371 Radwaste Solidification Building - quarterly survey 04/28/2025 71124.01 Radiation Surveys WF3-2505-00173 Upper Guide Structure Work Platform - post thimble support plate move to upper position 05/05/2025

26 Inspection Procedure Type Designation Description or Title Revision or Date 71124.01 Radiation Surveys WF3-2505-00177 Regenerative Heat Exchanger (Upper Level) pre and post shielding survey 05/05/2025 71124.01 Radiation Surveys WF3-AS-011625-0003 Noble Gas Sample Report - Containment RCB +21 01/16/2025 71124.01 Radiation Surveys WF3-AS-031025-0025 Particulate Sample Report - charging pump 'A' disassembly 03/10/2025 71124.01 Radiation Surveys WF3-AS-031025-0028 Particulate Sample Report - charging pump A disassembly -

35 RAB 03/10/2025 71124.01 Radiation Surveys WF3-AS-061124-0171 Noble Gas Sample Report - RDT - 11 RCB 06/11/2024 71124.01 Radiation Surveys WF3-AS-073124-0176 Particulate Sample Report - charging pump 'A' plunger pull 07/31/2024 71124.01 Radiation Surveys WF3-AS-080124-0179 Particulate Sample Report - charging pump A repacking (seal water box) -35' RAB 08/01/2024 71124.01 Radiation Work Permits (RWPs) 2025-1405-02 Tours and Inspections in High Radiation Areas 0

71124.01 Radiation Work Permits (RWPs) 2025-1454-02 RF26 - Valve Maintenance Activities - Task 2: Valve Maintenance Activities in High Radiation Areas 0

71124.01 Radiation Work Permits (RWPs) 2025-1454-04 RF26 - Valve Maintenance Activities - Task 4: Valve Maintenance Activities in the Regen Hx Room (HRA) 0 71124.01 Radiation Work Permits (RWPs) 2025-1702-07 RF26 - Reactor Disassembly (to include all associated work activities) - Task 7: ***MEDIUM RISK*** Remove Upper Guide Structure and Store in the Lower Refuel Cavity 0

71124.03 Corrective Action Documents CR-WF3-YYYY-NNNNN 2022-02868, 2022-03587, 2022-05994, 2022-05996, 2022-05998, 2023-00623, 2023-16705, 2023-17095, 2023-17136, 2024-03049, 2024-03266, 2024-03272, 2024-03312, 2024-03579, 2024-03942, 2024-04251, 2024-04308, 2024-04494, 2024-04602, 2025-00080, 2025-00536, 2025-00565, 2025-00572, 2025-00586, 2025-00607, 2025-00870, 2025-00931, 2025-00933, 2025-00935, 2025-01247 71124.03 Corrective Action Documents Resulting from CR-WF3-YYYY-NNNNN 2025-02029

27 Inspection Procedure Type Designation Description or Title Revision or Date Inspection 71124.03 Engineering Evaluations 2024-0308-02 TEDE-ALARA Evaluation: Forced Outage - Removal of the RCP Seals 04/09/2024 71124.03 Engineering Evaluations 2024-0312-01 TEDE-ALARA Evaluation: Forced Outage - Work on Highly Contaminated Valves in the Regen Heat Exchanger Room 04/17/2024 71124.03 Engineering Evaluations 2025-1454-02 TEDE-ALARA Evaluation: Valve Inspection, Testing, and Repair 10/24/2024 71124.03 Engineering Evaluations 2025-1708-02/03 TEDE-ALARA Evaluation: Refuel 26 - Reactor Cavity / UGS Structure ICI Activities and ICI Guide Tube Measurements 04/26/2025 71124.03 Engineering Evaluations 2025-1900-04 TEDE-ALARA Evaluation: Refuel 26 - Emergent Work -

Insulation Removal from RCP 05/07/2025 71124.03 Miscellaneous Employee SCBA Mask Sizes 04/14/2025 71124.03 Miscellaneous Respiratory Protection Equipment - Monthly Inspection 04/16/2025 71124.03 Miscellaneous WSES-FSAR-Unit-3, Table 12,5-4, Health Physics Equipment 305 71124.03 Miscellaneous WSES-FSAR-Unit-3, Equipment, Instrumentation, and Facilities 305 71124.03 Miscellaneous Inventory Checklist for OSC Storage Rooms, Field Kit Back-up for OSC, EOF Storage Locker, Ambulance Kit, Hospital Locker, Security, Dosimetry Office, and RAB -4 Access Control Point 03/26/2025 71124.03 Miscellaneous Training and Qualifications for Entergy Corporation (AirHawk, FireHawk, SCBAs) 03/27/2025 71124.03 Miscellaneous 220615042-01 Laboratory Report - Compressed Air/Gas Quality Testing 08/08/2024 71124.03 Miscellaneous 71400941 MSA FireHawk M7 Air Mask Posi3 USB Test Results -

Complete SCBA Test, Unit 2, UEM-6119 02/01/2024 71124.03 Miscellaneous 71403719 MSA FireHawk M7 Air Mask Posi3 USB Test Results -

Complete SCBA Test, Unit 66, UEM-6168 01/30/2024 71124.03 Miscellaneous Att. 9.5 to EN-RP-502 Annual Respiratory Protection Equipment Inventory and Inspection: Annual In-Service Inspection 01/15/2025 71124.03 Miscellaneous Ref. G-853 Fig. 03 Control Room Emergency Filtration Unit (HVC) High Radiation / SIAS Mode 05/05/2025 71124.03 Miscellaneous Ref. G-853 SH1 Fig. 06 Controlled Ventilation Areas Filter Unit (CVAS) 05/05/2025 71124.03 Miscellaneous Ref. G-853 SH2 Fig. 03 Shield Building Ventilation Systems (SBV) 05/05/2025

28 Inspection Procedure Type Designation Description or Title Revision or Date 71124.03 Procedures Standard Operating Procedure for Emergency Breathing Air Supply 1

71124.03 Procedures EN-RP-131 Air Sampling 18 71124.03 Procedures EN-RP-404 Operation and Maintenance of HEPA Vacuum Cleaners and HEPA Ventilation Units 9

71124.03 Procedures EN-RP-501 Respiratory Protection Program 8

71124.03 Procedures EN-RP-502 Inspection and Maintenance of Respiratory Protection Equipment 10 71124.03 Procedures EN-RP-502-01 FireHawk M7 SCBA 3

71124.03 Procedures EN-RP-503 Selection, Issue and Use of Respiratory Protection Equipment 10 71124.03 Procedures EN-RP-504 Breathing Air 4

71124.03 Procedures EN-RP-505 PortaCount Respirator Fit Testing 9

71124.03 Procedures HP-002-603 Inspection and Use of Control Room EBA filtration Panel 12 71124.03 Radiation Surveys WF3-2504-00094

-4 Reactor Containment Building 04/09/2025 71124.03 Radiation Surveys WF3-2505-00253 Pre-Job Survey for Insulation Removal 05/06/2025 71124.03 Radiation Surveys WF3-AS-031025-0026 20250004/4 Maintenance Activities, Unit 1 RAB -35 03/10/2025 71124.03 Radiation Surveys WF3-AS-031025-0027 20250004/4 Maintenance Activities, Unit 1 RAB -35 03/10/2025 71124.03 Radiation Surveys WF3-AS-050625-0184 20251454/4 - RF26 Valve Maintenance Activities, Unit 1 RCB +21 05/06/2025 71124.03 Radiation Surveys WF3-AS-050725-0209 20251900/4 - RF26 Emergent Work - Minor Maintenance Activities, Unit 1 RCB D-Rings 05/07/2025 71124.03 Radiation Surveys WF3-AS-050725-0209 Lapel Sampling: 20251900/4 RF-26 Emergent Work - Minor Maintenance Activities, Unit 1 RCB D-Rings 05/07/2025 71124.03 Radiation Surveys WF3-AS-050725-0210 Lapel Sampling: 20251900/4 RF-26 Emergent Work - Minor Maintenance Activities, Unit 1 RCB D-Rings 05/07/2025 71124.03 Radiation Surveys WF3-AS-101923-0278 20230702/2 Refuel 25 - Disassembly of Reactor Head and All Associated Work Activities, Unit 1 RCB +46 10/19/2023 71124.03 Radiation Work Permits (RWPs) 20251405 RF26 Tours and Inspections 0

29 Inspection Procedure Type Designation Description or Title Revision or Date 71124.03 Radiation Work Permits (RWPs) 20251454 RF26 - Valve Maintenance Activities 0

71124.03 Radiation Work Permits (RWPs) 20251455 RF26 - Remove/Replace the Pressurizer Manway and the Pressurizer Safety Relief Valves 0

71124.03 Radiation Work Permits (RWPs) 20251702 RF26 - Reactor Disassembly (to include all associated work activities) 0 71124.03 Radiation Work Permits (RWPs) 20251900 RF26 - Emergent Work - Minor Maintenance Activities 1

71124.03 Self-Assessments LO-WF3-2024-00063 In-Plant Airborne Radioactivity Control and Mitigation (IP 71124.03) 02/19/2025 71124.03 Work Orders 53015928_1 HVCMFAN0010 A - Obtain Charcoal Test Canister for Analysis 05/28/2024 71124.03 Work Orders 53017382_1 HVCMFAN0010 A - Leak Test HEPA Filters and Charcoal Absorber 05/29/2024 71124.03 Work Orders 53023258_1 HVCMFAN0010 B - Leak Test HEPA Filters and Charcoal Absorber 05/22/2024 71124.03 Work Orders 53023327_1 HVCMFAN0010 B - Obtain Charcoal Test Canister for Analysis 05/20/2024 71124.03 Work Orders 53025177_1 HVRMFAN0021 B - Leak Test HEPA Filters and Charcoal Absorber 05/28/2024 71124.03 Work Orders 53034403_1 SBVMFAN0001 A - Leak Test HEPA Filters and Charcoal Absorber 12/05/2024 71151 Miscellaneous W3F1-2025-0014 Annual Radioactive Effluent Release Report (ARERR) 2024 04/30/2025 71151 Miscellaneous W3Fl-2024-0031 NRC Performance Indicator (Pl) Data - 2nd Quarter 2024 07/18/2024 71151 Miscellaneous W3Fl-2024-0048 NRC Performance Indicator (Pl) Data - 3rd Quarter 2024 10/16/2024 71151 Miscellaneous W3Fl-2025-0005 NRC Performance Indicator (Pl) Data - 4th Quarter 2024 01/17/2025 71151 Procedures EN-FAP-OM-005 Nuclear Performance Indicator Program 18 71151 Procedures EN-LI-114 Regulatory Performance Indicator Process 22 71152A Corrective Action Documents CR-WF3-YYYY-NNNNN 2023-15311, 2025-00469, 2025-00472 71152A Miscellaneous PSA-WF3-01-SY WF3 PSA Model Systems Analysis Notebook 71152A Miscellaneous SD-EDG Emergency Diesel Generator System Description 71152A Procedures EN-DC-115 Engineering Change Process 15 71152A Procedures EN-LI-102 Corrective Action Program 54

30 Inspection Procedure Type Designation Description or Title Revision or Date 71152A Procedures EN-LI-118 Causal Analysis Process 34 71152A Procedures EN-MA-106 8

71152A Procedures OP-002-001 Auxiliary Component Cooling Water 320 71152S Corrective Action Documents CR-WF3-YYYY-NNNNN 2024, 00655, 2025-00951, 2025-01071, 2025-01090, 2025-01118, 2025-01137, 2025-01326, 2025-01407, 2025-01434, 2025-01539, 2025-02175, 2025-02272, 2025-02277, 2025-02280, 2025-02293, 2025-02294, 2025-02295, 2025-02300, 2025-02356, 2025-02404, 2025-02543, 2025-02544, 2025-02580, 2025-02997, 2025-03131, 2025-03165 71153 Corrective Action Documents CR-WF3-YYYY-NNNNN 2024-02523 71153 Procedures EN-FAP-OM-016 Performance Management Processes and Practices 12 71153 Procedures OP-009-003 Emergency Feedwater 313 71153 Procedures OP-903-014 Emergency Feedwater Flow Verification 318 71153 Procedures OP-903-014 Emergency Feedwater Flow Verification 319