United States Nuclear Regulatory Commission - Protecting People and the Environment

Additional NRC Oversight at Pilgrim Nuclear Power Plant


Photograph of Pilgrim Nuclear Power PlantPilgrim Nuclear Power Station (Pilgrim), in Plymouth, Mass., is under increased oversight by the NRC. In September 2015, the agency announced the finalization of a "White" (low to moderate safety significance) inspection finding that stemmed from issues involving the plant's safety relief valves. Based on that enforcement action, in combination with two earlier "White" findings received by the plant, the NRC moved Pilgrim to Column 4 of the agency's Action Matrix, which dictates the agency's level of oversight at plants. The NRC embarked on a review process that entailed three phases and numerous hours of inspection to help to determine the breadth and depth of the safety, organizational, and programmatic issues that led to Column 4. Following the completion of the NRCs phased inspection, on August 2, 2017, the NRC issued a Confirmatory Action Letter that outlined the actions that Entergy was committed to complete to address these issues. The NRC is currently in the process of inspecting the adequacy and effectiveness of Entergy's completion of these actions.


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On September 1, 2015, the NRC moved Pilgrim to Column 4 (Repetitive Degraded Cornerstone) of the ROP Action Matrix retroactive to the first quarter of 2015.  The entry into Column 4 was caused by the issuance of an additional White finding in the Mitigating Systems Cornerstone after Pilgrim had been in Column 3 (Degraded Cornerstone) for more than five consecutive quarters. 

  • Pilgrim was moved to Column 3 in the fourth quarter of 2013 due to two White performance indicators in the Initiating Events Cornerstone.  Four scrams in 2013 caused Unplanned Scrams per 7000 Critical Hours and Unplanned Scrams with Complications, to cross the threshold from Green to White.

  • The additional White finding documented on September 1, 2015, in the Mitigating Systems Cornerstone was identified because Entergy did not take adequate corrective action to correct a significant condition adverse to quality associated with the Pilgrim "A" safety relief valve (SRV) in 2013, which resulted in a similar failure of the "C" SRV in January 2015.

Inspection Approach

In accordance with the NRC's Reactor Oversight Process, the NRC conducted a three-phased supplemental inspection in accordance with Inspection Procedure (IP) 95003, "Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs or One Red InputPhase 'A' was conducted during the week of January 16, 2016, and Phase 'B' was completed during the week of April 4, 2016.  Phase 'C', entailed three onsite weeks of inspection, which were completed on January 13, 2017.  A public exit meeting with the licensee was conducted on March 21, 2017, at the Plymouth Memorial Hall to discuss the preliminary results of the inspection.

Based on the plant's persistent corrective action program (CAP) weaknesses, the 95003 supplemental inspection focused on the Pilgrim CAP and safety culture assessment (reference sections 02.02 and 02.07 through 02.09 of IP 95003). Under the affected Strategic Performance Area of Reactor Safety of the Reactor Oversight Program, NRC supplemental inspections at Pilgrim focused on the key attributes of human performance, procedure quality and equipment performance.

The NRC used baseline inspections to sample and assess the other key attributes within the Reactor Safety area: design, configuration control and emergency response. These baseline inspections will confirm that performance within these attributes remains acceptable. If concerns are identified, the inspection approach for these areas may be re-evaluated.

The NRC's Region I office is conducting quarterly performance assessments of Pilgrim while they are in Column 4.  The NRC has also increased the number of baseline inspection activities performed at Pilgrim and conducted targeted Problem Identification and Resolution samples focused in the areas of previous performance issues.  Insights from these inspections and the results of the quarterly assessments have and will continue to support our assessment of Pilgrim performance.

The Phase 'A' and 'B' inspections were conducted in accordance with IP 95003, Section 02.02, and served as partial completion of this portion of the IP.  Phase 'A' reviewed various aspects of the plant's CAP to determine whether continued operation of Pilgrim was acceptable and whether additional regulatory actions were necessary to arrest declining plant performance.  Phase 'B' looked at overall corrective action program performance since the last problem identification and resolution inspection completed in August 2015.  It focused on progress in improving the plant's performance in the area of corrective actions.  The results of the A and B phases, along with insights from recent baseline and team inspections, informed the final scope for the Phase 'C' inspection, which completed the remaining requirements of the IP 95003 inspection procedure, providing an in-depth, independent review of what led to the decline in plant performance.

In addition to the NRC's review through the IP 95003 inspection, Entergy was required to identify the causes that led to Pilgrim's performance being placed in Column 4 and implement corrective actions needed to address the identified performance concerns and underlying problems.  Their plan to do so was detailed in Pilgrim's Recovery Plan.  Following completion of the IP 95003 inspection, the NRC reviewed Pilgrim's Recovery Plan to determine whether the proposed causes and corrective actions are sufficient to fix the underlying problems.  On August 2, 2017, the NRC issued a Confirmatory Action Letter (CAL) to document the licensee's commitments.

The Confirmatory Action Letter includes 156 individual action items grouped under 11 Area Action Plans.  The 11 Area Action Plans cover the following performance areas:  The NRC is currently in the process of inspecting the adequacy and effectiveness of Entergy's completion of these actions.  The inspection plan includes five quarterly Confirmatory action Letter Follow-up Inspections.  As of the end of the second quarter of 2018, two of the five inspections are complete and NRC staff has inspected completion of 43 of the 156 individual items and three of the Area Action Plans.  The NRC staff closed 41 individual items and two of the area action plans as a result of the inspections.  The details of the inspection results are documented in the following reports:  2017010 and 2018010.  Items and area action plans that were reviewed but not closed during these two inspections will be inspected again during future CAL follow-up inspections.

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Assessment:

The U.S. Nuclear Regulatory Commission completed its 2018 first quarter performance review of the Pilgrim Nuclear Power Station, reviewing performance indicators (PIs), inspection results, and enforcement actions from April 1, 2017 through March 31, 2018. The NRC concluded that overall performance at the facility preserved public health and safety.

Based on review of the current inspection record and consideration of the criteria to transition a site to Column 5, the NRC staff concluded the criteria were not met by Pilgrim during this period. There were no escalated violations, no loss of confidence in the Entergy's ability to maintain and operate the facility in accordance within the design basis, and no pattern of failure of Entergy's management controls to effectively address previous significant concerns to prevent recurrence since the end of cycle assessment.

As of the end of the first quarter of 2018, the NRC staff assessment is that Pilgrim should remain in Column 4 because Entergy has not yet fully demonstrated the effectiveness of the implementation of their Recovery Plan in achieving sustained performance improvement.  Many CAL items remain open and have not been independently verified as effective by the NRC.  Therefore. Entergy has not demonstrated sustained improvement warranting transition of Pilgrim out of Column 4. As of the end of the first quarter about 26% of the CAL action items were completed and closed out by the NRC staff.

No additional regulatory actions were recommended beyond those required by the Action Matrix for a plant in Column 4. The NRC will continue with the planned CAL inspections and enhanced oversight activities including quarterly reviews of the site performance with senior regional management and more frequent management site visits to monitor for additional potential performance decline. Should there be indications of degrading performance, we will take additional regulatory actions as needed, including additional supplemental inspections, a demand for information, or issuance of an order, up to and including a plant shutdown order.

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Page Last Reviewed/Updated Monday, August 27, 2018