United States Nuclear Regulatory Commission - Protecting People and the Environment

Frequently Asked Questions About Increased Oversight at Pilgrim Nuclear Power Plant

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Why is Pilgrim in Column 4 of the Action Matrix?

In addition to the "White" finding under the Mitigating Systems Cornerstone, which was identified in the first quarter of 2015, Pilgrim was already in the Degraded Cornerstone Column of the Reactor Oversight Process (ROP) Action Matrix for more than five consecutive quarters as of Jan. 1, 2015, due to two open "White" inputs under the Initiating Events Cornerstone.  These "White" inputs involved the failure to address, in a timely manner, the causes of the multiple unplanned shutdowns that occurred in 2013.  The coincidence of the longstanding Degraded Initiating Events Cornerstone negative inputs and the new "White" finding under the Mitigating Systems Cornerstone constitute a Repetitive Degraded Cornerstone as defined in Inspection Manual Chapter 0305.  As a result, the NRC determined that the performance at Pilgrim nuclear power plant has been in the Repetitive Degraded Cornerstone Column of the ROP Action Matrix since the beginning of the first quarter of 2015.  Therefore, in addition to ROP baseline inspections, the NRC conducted a supplemental inspection in accordance with Inspection Procedure 95003, "Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs or One Red Input."

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Does entry into Column 4 mean Pilgrim is unsafe?

In addition to the "White" finding under the Mitigating Systems Cornerstone, which was identified in the first quarter of 2015, Pilgrim was already in the Degraded No, the specific issues that drove Pilgrim to Column 4 were of low to moderate safety significance.  However, Pilgrim did not resolve the issues associated with the Initiating Events Cornerstone in a timely manner.  Prior to the resolution of these issues, the "White" finding associated with the Mitigating Systems cornerstone was identified.  It indicated the need for additional NRC oversight in order to arrest a further decline in performance.  The increased NRC oversight, inspection and assessment provided by Column 4 allows the NRC to closely monitor for indications of unacceptable performance.  If at any time NRC determines that performance has declined to an unacceptable level, then NRC will take additional regulatory action, up to and including the issuance of a shutdown order.

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What is the underlying cause of the performance problems at Pilgrim?

Pilgrim has exhibited weaknesses in the Corrective Action Program in terms of identifying, evaluating and completing corrective actions in a timely manner. As a result, Pilgrim has experienced equipment problems that have led to unplanned scrams/shutdowns and challenges to safety-related equipment. Some issues are repetitive in nature, such as loss of off-site power events and Safety Relief Valve failures. The NRC is conducted a three-phase diagnostic Supplemental Inspection in accordance with Inspection Procedure 95003. This inspection went beyond what we normally look at in the baseline inspection program and allowed the NRC to better assess Pilgrim's Corrective Action Program (CAP) and to obtain a better understanding of the depth and breadth of the safety, organizational, and performance issues at the site. For Pilgrim this inspection was conducted in three Phases, A through C. Phase A and B were completed in January and April of 2016 respectively. The onsite portion of Phase C was completed on January 13, 2017. The inspection report was issued on May 10, 2017, and documented the results of the inspection, including a discussion of what the inspection team determined to be the most significant contributors to Pilgrim's poor performance.

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What will the NRC be doing to ensure that Pilgrim remains safe to operate while these problems are addressed?

The NRC completed the IP 95003 inspection in three phases A, B, and C. The focus of the first two phases (A, B) was to insure that performance at Pilgrim was not continuing to degrade by taking a closure look at recent Pilgrim CAP performance. The results of these inspections determined that Pilgrim remained safe. Phase C completed the full diagnostic inspection of the causes for the degraded performance. Prior to the completion of Phase C, the baseline inspection program and IMC 0305 provided a number of regulatory tools to ensure increased oversight to monitor for any additional performance decline and to verify that the plant continues to operate safely. For instance, the NRC increased baseline (routine) inspection sampling over and above our normal sampling in some areas, i.e. problem identification and resolution. In addition, the NRC is completing quarterly performance reviews regarding Pilgrim that focus on monitoring for additional performance decline. If any of these activities identify the need for additional regulatory actions, our plans will be communicated by letter publicly. The NRC has also engaged Entergy with more frequent site visits, and Entergy was called upon to present its performance improvement plan to the Commission at a public meeting in June 2016. At any time if there are indications of degrading performance the NRC may take additional regulatory actions if warranted, including additional supplemental inspections, a demand for information, or issuance of an order, up to and including a plant shutdown.

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What will the NRC be doing to ensure that Pilgrim remains safe to operate while these problems are addressed?

On Sept. 1, 2015, the NRC issued a "White" finding and Notice of Violation to Pilgrim because Entergy had not adequately addressed a significant equipment problem that caused a failure of one of the plant's Safety Relief Valves in February 2013 and then resulted in a similar failure in January 2015.  This issue combined with a failure to adequately address the causes of multiple reactor shutdowns at Pilgrim in 2013 were indications of degrading performance that moved the plant into Column 4 (the "Repetitive Degraded Cornerstone" Column) of the NRC Action Matrix. 

Based on our rigorous oversight and assessment program, the NRC determined that Pilgrim continues to operate safely. The issues that moved Pilgrim into Column 4 were of low to moderate safety significance; and the increased oversight, inspection, and assessment directed by the assessment process for a plant in Column 4 now allows us to closely monitor for indications of unacceptable performance that would require the plant to be moved to Column 5.  If at any time it is determined that performance at Pilgrim has declined to an unacceptable level with respect to public safety, the NRC will not hesitate to take additional regulatory action up to and including the issuance of a shutdown order.

In accordance with Inspection Manual Chapter 0305, Section 10.02e the following items establish the NRC current basis for not moving Pilgrim to Column 5 and issuing a shutdown order:

  1. Since Pilgrim's entry into Column 4, there have been no additional escalated enforcement violations, and the IP 95003 inspection team identified only one potential greater than Green finding.

  2. Since entry into Column 4, there have not been multiple safety significant examples where the licensee was determined to be outside of its design basis.  The inspection record has not identified multiple significant performance issues in design and configuration control and has, therefore, concluded there has been adequate performsance in design and configuration control at Pilgrim.

  3. There has not been a pattern of failure of licensee management controls to effectively address previous safety significant findings to prevent recurrence.

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How many other plants have been under this level of increased oversight?

Nine since the inception of the Reactor Oversight Process:

  1. Indian Point 2000-2002
  2. Oconee 2002
  3. Cooper 2002-2004
  4. Point Beach 2003-2006
  5. Perry 2004-2007
  6. Palo Verde 2006-2009
  7. Fort Calhoun 2011
  8. Browns Ferry 2011-2014
  9. Arkansas Nuclear One 2014-2015

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What corrective actions has Entergy taken to address the loss of offsite power events that have occurred at Pilgrim during winter storms in recent years?

To mitigate the potential for a repeat of previous winter storm events at Pilgrim, the plant has revised procedures to direct operators to place the plant in a safe condition based on impending and in progress weather conditions.  The revisions direct operators to take action based on criteria that considers information provided by National Weather Service forecasts and available through the plant's meteorological towers when the weather event is in progress.  The information used includes:  winter storm and blizzard watches and warnings, forecasted and actual sustained wind speed and direction, and forecasted and actual snowfall rates.

The actions directed by the procedure based on these criteria, in the most severe cases include plant shutdown and cooldown.  Other actions include plant walk downs, pre-emptive power reductions, topping off diesel fuel tanks, manually starting and loading emergency diesel generators and staging additional personnel and emergency response equipment.  For the most severe cases, like Winter Storm Juno, the intent of the directed action is to reduce the risk of core damage due to a loss of offsite power by reducing the plant's heat load before the loss of offsite power occurs.  Therefore, when weather conditions indicate that the probability of loss of offsite power is high based on the procedure's specified criteria, the procedure changes now direct shutting the plant down and immediately placing the shutdown cooling system in service to cool down to <200  F.  Cooling the plant down to <200  F significantly reduces the cooling demand on the plants safety equipment and significantly increases the amount of time that the plant can remain safe without off-site power.

Since Winter Storm Juno, the plant has also implemented a temporary modification to increase the reliability of switchyard components during severe winter weather.  The modification was intended to minimize the potential for flashover events like the one that occurred during Winter Storm Juno.  The modification provides two portable generators and power packs that supply power to nine heat lamps positioned around key breakers and transformers in the switchyard.  These heat lamps are used to warm the bushings associated with this equipment, which prevents snow packing and ice accumulation on the bushings that led to flashover during Winter Storm Juno.  Although there is no prior history of use for this type of equipment at other nuclear power plants in this country, there is operating history from at least one fossil plant in western Pennsylvania that indicates some success with this method.  In addition the performance of the lamps during this past winter's (2016) storms indicates that they are capable of reducing the likelihood of snow packing and ice accumulation on the bushings.

None of the specific actions completed by Entergy to address these concerns, including the new shutdown criteria, were directed by NRC requirements; however, in accordance with NRC regulations, Entergy was required to take corrective action to address the problems that occurred during Winter Storm Juno in 2015.  The NRC reviewed and inspected Entergy's switchyard modifications and operating procedure changes and determined that they adequately addressed the concerns identified during Winter Storm Juno.  The actions taken reduce the probability of a loss of offsite power and significantly reduce the risk of core damage if a loss of offsite power occurs.  This, combined with the fact that the plant is designed to cope with the duration of a typical station blackout event for the associated geographic area, ensure that the plant remains safe for these types of events.

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In recent months, Pilgrim has experienced several weather-related unplanned shutdowns, continued issues associated with the switchyard, and a scram in January 2018. How can the NRC continue to conclude that Pilgrim is operating safely?

On-site NRC inspectors have performed reviews of Pilgrim operational performance during recent weather-related events, and through our assessment to date, we have concluded that the site took appropriate actions in response to predicted and actual weather conditions during these events.  These actions were performed in accordance with plant procedures, which (as discussed above) were revised following the 2015 events related to Winter Storm Juno.

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The NRC keeps saying that Pilgrim is safe to operate even though there continues to be multiple Green findings and violations. What will it take to take for the NRC to shutdown Pilgrim?

Green inspection findings indicate a deficiency in licensee performance that has very low risk significance and therefore has little or no impact on safety.  At this point, the NRC has determined that these green findings do not represent unacceptable performance, and therefore, do not warrant Pilgrim's transition into Column 5.

The NRC determines its regulatory response in accordance with the Reactor Oversight Process Action Matrix.  When a plant is placed in the Unacceptable Performance Column (Column 5), continued plant operation is not permitted.  Unacceptable performance indicates that the NRC lacks reasonable assurance that the licensee can or will conduct its activities to ensure protection of public health and safety.  Examples of unacceptable performance that may result in a plant moving to Column 5 include: multiple escalated violations of the facility's license, technical specifications, or regulations; multiple safety-significant examples where the facility was determined to be outside of its design basis, or a pattern of failure of management controls to effectively address previous significant concerns. 

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The inspection reports keep stating that Entergy is entering these issues into their corrective action program for resolution. How can the NRC have confidence in Entergy's corrective action program to resolve these issues given the results of the last Problem Identification and Resolution inspection?

The NRC's 2017 biennial Problem Identification and Resolution inspection report noted the following, regarding Entergy's corrective action program (CAP):

"Entergy was generally effective in identifying, evaluating, and resolving problems. Entergy personnel were typically effective at identifying problems and entering them into the CAP at a low threshold. In general, Entergy prioritized and evaluated issues commensurate with the safety significance of the problems. Corrective actions were generally implemented in a timely manner."

The inspection team did note, in several cases, "that the level of detail associated with the documentation of issues being entered into the CAP was less than adequate and as a result challenged Pilgrim's ability to effectively classify and evaluate issues."  However, this observation does mean that the NRC has concluded that Entergy's Cap is ineffective.

A licensee's corrective action program would be considered ineffective if the NRC lost confidence in the ability of this program to maintain an appropriate level of safety by correcting adverse conditions.  This could be evidenced by significant fundamental weaknesses in most areas of the program (identification, evaluation, resolution), across multiple cornerstones of safety.  A corrective action program with significant fundamental weaknesses could manifest itself as a significant event at a station affecting the health and safety of the public, or multiple highly risk significant findings.

At this point, the NRC does not consider Pilgrim's corrective action program to be ineffective.  Previous baseline inspections associated with the corrective action program and the 95003 inspection have determined the program remains generally effective.  However, the NRC will continue to closely monitor Pilgrim's corrective action program performance as it continues to perform baseline inspections and follow-up inspections associated with the Confirmatory Action Letter. 

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Is Pilgrim performance getting better?

We have determined through our inspection and assessment that Pilgrim remains safe to operate.  We have also determined, based on the results of the 95003 inspections, that Entergy's recovery plan, as adjusted to account for the weaknesses identified in the Phase C inspection report, should (if implemented properly) result in Pilgrim demonstrating sustainable performance improvement and exiting Column 4.  Pilgrim's progress in implementing their recovery plan is now being reviewed on a quarterly basis through Confirmatory Action Letter follow-up inspections and our quarterly assessment meetings.

Additionally, the most recent annual assessment letter issued by the NRC to Entergy stated that "the NRC [has] observed progress made by new site leadership through their reinforcement of site standards and expectations, and an overall improvement in the performance of licensed operators."  However, this letter did also note that a significant amount of work related to the performance recovery of Pilgrim remains.  We will continue to monitor Entergy's effectiveness in completing this work through our Confirmatory Action Letter follow-up inspections.

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Once Pilgrim completes the items listed the CAL, will they exit Column 4?

Not necessarily.  The NRC will perform follow-up inspections to verify Entergy's completion of the corrective actions listed in Enclosure 2 of the CAL, and to assess the effectiveness of the completion of these actions.  Only when the NRC concludes, based on these follow-up inspections, that the actions have been completed adequately, such that Entergy is demonstrating sustained performance improvement at Pilgrim, will the NRC consider allowing Pilgrim to transition out of Column 4.

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When will the CAL follow-up inspections be conducted?

The CAL follow-up inspections are being conducted on a quarterly basis.  The first two have been completed, and three additional inspections are currently scheduled for 2018.  We currently anticipate that these inspections will conclude by the end of 2018; however, additional follow-up inspections may be scheduled, if needed, until the NRC determines that Entergy has fulfilled all commitments listed in the CAL.

While the CAL follow-up inspections are in progress, what will the NRC be doing to ensure that Pilgrim remains safe to operate while these problems are addressed?

The completed IP 95003 inspection determined that Pilgrim remained safe.  Phase C of the 95003 Inspection also completed the full diagnostic inspection of the causes for the degraded performance and identified the most significant corrective actions that are required.  These items have been included in the CAL.

Prior to the completion and issuance of the CAL follow-up inspections, the baseline inspection program and IMC 0305 provide a number of regulatory tools to monitor for any additional performance decline and to verify that the plant continues to operate safely.  For instance, the NRC has increased baseline (routine) inspection sampling beyond our normal sampling in some areas (i.e. problem identification and resolution).  The NRC has also temporarily added another resident inspector full-time onsite to support additional inspection activities.  In addition, the NRC is completing quarterly performance reviews that focus on monitoring for additional performance decline.  The NRC has also engaged Entergy with more frequent site visits, and Entergy will continue to be required to present the status of its recovery plan to the Commission at an annual public meeting in June.

If at any time these activities reveal indications of degrading performance, the NRC may take additional regulatory actions, including additional supplemental inspections, a demand for information, or issuance of an order, up to and including a plant shutdown.

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If/when Pilgrim exits Column 4, what column will they be placed into the Action Matrix?

If the results from the CAL follow-up inspections lead the NRC to conclude that Pilgrim can exit Column 4 of the Action Matrix, Pilgrim will transition to the column that is represented by Action Matrix inputs applicable at that time, in accordance with IMC 0305. For example, if there were no greater-than-green inputs (i.e. findings, violations, or performance indicators) in the previous 12 month assessment period, Pilgrim would transition to Column 1 of the Action Matrix. However, if (for example) there were one or two white inputs in a strategic performance area, Pilgrim would transition from Column 4 to Column 2, until the associated IP 95001 inspection was completed.

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Page Last Reviewed/Updated Wednesday, April 11, 2018