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 from 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, Pilgrim moved 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. Following the completion of the NRCs phased inspection, the NRC issued a Confirmatory Action Letter outlining the actions that the licensee will be expected to complete before they can be moved out of Column 4. The NRC is currently in the process of inspecting tohe adequacy and effectiveness of Entergy's completion of these actions.


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Pilgrim moved into Column 4 of the Action Matrix on Sept. 1, 2015. The move was required due to two "White" inputs under the Initiating Events Cornerstone identified in 2013 that remained because the supplemental inspection had not been successfully completed and a "White" finding under the Mitigating Systems Cornerstone that was identified in May of 2015. The two "White" inputs under the Initiating Events Cornerstone were subsequently closed on June 30, 2015 (the end of the 2nd quarter), after successful completion of a supplemental inspection in accordance with Inspection Procedure (IP) 95002.

In response to pilgrim entering Column 4, the NRC conducted a supplemental inspection in accordance with Inspection Procedure (IP) 95003, "Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs or One Red Input," including a review of the corrective actions associated with the "White" finding under the Mitigating Systems cornerstone. One potentially greater-than-green violation emerging as a result of this inspection is still under evaluation.

On August 2, 2017, the NRC issued a Confirmatory Action Letter (CAL) addressing the corrective actions that will need to be completed by Pilgrim to address the issues that led to the plant's placement into Column 4 of the ROP Action Matrix. The NRC is currently in the process of performing a series of quarterly follow-up inspections to assess Entergy's progress in completing these corrective actions and whether the actions will support sustainable performance improvement. These inspections will support future performance assessments and will serve as the basis for determining when to close the CAL and whether the NRC can consider transitioning Pilgrim out of Column 4 of the ROP Action Matrix.

After successful closeout out of the CAL commitments, and once the NRC has concluded that Entergy is demonstrating sustained performance improvement at Pilgrim, the NRC will issue an assessment follow-up letter, and the Pilgrim will return to the Action Matrix column that is represented by applicable Action Matrix inputs open at that time. Additionally, for a period of up to two years after the initial findings have been closed out, the regional offices may use some actions that are consistent with Column 3 or 4 of the Action Matrix in order to ensure the appropriate level of NRC oversight of licensee improvement initiatives.

The increased oversight, inspection, and assessment for a plant in Column 4 allow the NRC to closely monitor for indications of unacceptable performance. Our current assessment of Pilgrim performance is that the plant continues to operate safely. If at any time NRC determines that performance has declined to an unacceptable level, the NRC will take additional regulatory action up to and including the issuance of a shutdown order

For more information on the status of the NRC's inspections and reviews at Pilgrim, see the Communications tab.

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 Input." Phase '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 identify the causes that led to Pilgrim performance being placed in Column 4 and implement corrective actions needed to address the identified performance concerns. 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. The NRC thereafter issued a Confirmatory Action Letter (CAL) to document the licensee's commitments.

The NRC is now in the process of performing a series of quarterly follow-up inspections to assess Entergy's progress in completing the corrective actions listed in the CAL and to determine whether the actions will support sustainable performance improvement.

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Assessment:

The U.S. Nuclear Regulatory Commission has completed its 2017 end-of-cycle performance review of the Pilgrim Nuclear Power Station, reviewing performance indicators (PIs), inspection results, and enforcement actions from January 1, 2017 through December 31, 2017 (ML18058A025). The NRC concluded that overall performance at the facility preserved public health and safety.

Performance at Pilgrim remains in Column 4, or the Multiple/Repetitive Degraded Cornerstone Column, of the NRC's Reactor Oversight Process (ROP) Action Matrix in Inspection Manual Chapter (IMC) 0305, "Operating Reactor Assessment Program. (See Background.) While the plant remains in Column 4, the NRC will continuously assess Pilgrim's performance to evaluate the need for additional regulatory action, up to and including moving the plant to the Unacceptable Performance Column (Column 5), and issuing a shutdown order. To date, our inspection and assessment have determined that Pilgrim continues to operate safely, and at this time additional regulatory action beyond Column 4 is not required.

Completed Activities:

The NRC completed an Inspection Procedure (IP) 95003 inspection, as required for all Column 4 plants. The inspection was conducted in three phases ('A' through 'C') (ML15352A128). The Phase 'A' and 'B' inspections were completed in January and April of 2016, respectively (ML16060A018 and ML16144A027).  These inspections reviewed aspects of the Pilgrim corrective action program and determined that Pilgrim continued to operate safely, that continued operation was acceptable, and that additional regulatory action was not required.  The Phase 'C' inspection team completed three weeks of on-site inspection on Jan. 13, 2017, a public exit meeting was held on March 21, 2017, and the inspection report issued on May 10, 2017 (ML17129A217).

On August 2, 2017, the NRC issued a Confirmatory Action Letter (CAL) addressing the corrective actions that will need to be completed before the NRC will consider transitioning Pilgrim out of Column 4 of the ROP Action Matrix (ML17214A088).  The NRC is currently in the process of performing a series of quarterly follow-up team inspections to assess Entergy's progress in completing these corrective actions.  The first of these inspections was completed in December 2017, and an associated report was issued on February 1, 2018 (ML18032A463).

Planned Activities:

The second quarterly CAL follow-up inspection is currently in progress, and the NRC expects to issue the associated inspection report in May 2018. Three additional inspections are currently planned for 2018. Once these inspections are completed, additional follow-up inspections may be scheduled, if needed, until the NRC has determined that all actions listed in the CAL have been adequately and effectively completed.

We also continue to conduct quarterly reviews of the site performance with senior regional management and more frequent management site visits to monitor for additional 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 Wednesday, April 11, 2018