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 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 five quarterly follow-up team inspections to assess Entergy's progress in completing these corrective actions.  The first four inspections have been completed and the results documented in the referenced CAL Follow-Up Inspection Reports: ML18032A463, ML18164A224, ML18282A039, and ML18305A834.  These inspections closed 117 of the 156 CAL items.

Planned Activities:

The fifth and final planned quarterly CAL follow-up inspection is currently scheduled for December 2018.  The current scope will review the implementation and effectiveness of all remaining open CAL actions, The NRC expects to issue the associated inspection report in early March 2019.  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.  Once all CAL actions are confirmed completed through NRC inspection, we will consider transitioning Pilgrim out of Column 4 of the ROP Action Matrix in accordance with Inspection Manual Chapter 0305.

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 Monday, November 26, 2018