Additional NRC Oversight at Pilgrim Nuclear Power Plant
The Pilgrim nuclear power plant, 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 has embarked on a review process that will entail three phases and numerous hours of inspection.
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. The NRC is also in the process of conducting 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.
Based on the results of the IP 95003 inspection, the EDO or designee, in conjunction with the RA and the Director, NRR, will decide whether additional NRC actions are warranted. At a minimum, the regional office will issue a Confirmatory Action Letter to document the licensee's commitments, as discussed in its performance improvement plan, and any other written or verbal commitments. The NRC will also conduct a public regulatory performance meeting with the licensee, which will be attended by the EDO or his designee.
After successful close out of the confirmatory action letter commitments and issuance of an assessment follow-up letter, the licensee will return to the Action Matrix column that is represented by applicable Action Matrix inputs. 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.
In accordance with the Reactor Oversight Process, the NRC plans to conduct a three-phased supplemental inspection in accordance with Inspection Procedure 95003, "Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs or One Red Input." Phase A of this inspection was conducted during the week of January 16. 2016, and Phase B was completed during the week of April 4, 2016. Phase 'C', which will take place over the course of several weeks, will commence in November 2016 and complete in January 2017.
Based on the persistent corrective action program (CAP) weaknesses, the 95003 supplemental inspection will focus 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 Process, the NRC will focus on the key attributes of human performance, procedure quality, and equipment performance.
The NRC will use 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, this inspection approach may be re-evaluated.
Region I is conducting quarterly performance assessments of Pilgrim while they are in Column 4. To support this activity and as an initial step to confirm that Pilgrim operations are safe and that their performance decline has been arrested, an additional Resident Inspector was placed onsite to support more samples in targeted areas, as well as more in-depth inspections. We are also conducting targeted Problem Identification and Resolution samples focused in the areas of previous performance issues. These inspection insights and the results of the quarterly assessments have been and will be used to shape each phase of the 95003 inspection.
The Phase 'A' and 'B' inspection each involved three inspectors from the NRC's Region I office. Both inspections were conducted in accordance with IP 95003, Section 02.02, and will serve as partial completion of this portion of the IP. Phase 'A' of this inspection reviewed various aspects of the plant's corrective action program to determine whether continued operation of Pilgrim is acceptable and whether additional regulatory actions are 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, focusing in particular on progress in improving the plant's performance in the area of corrective actions. The results of the "A" and "B" phases, as well as insights from recent baseline and team inspections, informed the final scope for the Phase "C" inspection currently in progress and which will complete the remaining requirements of the IP 95003 inspection procedure.
Assessment:
We have determined through our inspection and assessment through the Third Quarter of 2016 that Pilgrim performance is not degrading and the plant remains safe. Therefore, additional regulatory actions beyond those required for plants in Column 4 are not needed at this time. This is based on the results of our baseline and supplemental inspection completed through the Third Quarter of 2016 and recent plant operating history. There have been no risk-significant events, equipment failures or inspection findings since Pilgrim's entry into Column 4.
Our assessment of Entergy's progress in addressing the issues that resulted in Column 4 entry are pending our review of Entergy's performance improvement plan and our completion of Phase "C" of the 95003 inspection.
We 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.
Completed Activities:
As documented in the Pilgrim Third Quarter Integrated Inspection report (ML16319A206), the baseline inspections during this period included four "Green" Non-Cited Violations (NCV) of regulatory requirements.
The inspectors determined that Entergy did not adequately assess the operability of the "B" emergency diesel generator (EDG) while it was in a test configuration that would adversely affect the B EDG's ability to operate during a seismic event. The significance of the finding was very low because it was not a design or qualification deficiency and did not cause an actual loss of safety function. Entergy has issued a standing order to assess operability of equipment tested with cabinet doors open prior to performing work or declare the equipment being tested inoperable.
The inspectors identified a "Green" NCV because Entergy did not adequately demonstrate that the performance of the process radiation monitors (PRMs) was effectively controlled through performance of appropriate preventive maintenance. Specifically, Entergy did not identify and properly account for functional failures of four PRM subsystems in July 2014 and February, April, and July 2015; and did not recognize that the subsystems had exceeded their performance criteria and required a Maintenance Rule (a)(1) evaluation. Entergy entered the issue into the CAP, performed the Maintenance Rule (a)(1) evaluation, and placed them into (a)(1) where they will be monitored against specific goals.
The inspectors identified a "Green" NCV because Entergy did not implement preventive maintenance procedural requirements to periodically replace six high critical, normally energized Agastat EGP relays every 10 years. Entergy entered this issue into the plant's corrective action program (CAP), replaced all six relays, and performed an equipment apparent cause evaluation.
The inspectors also identified that Entergy did not perform a timely evaluation of the operability of primary containment isolation valves whose operation relied on the six normally energized Agastat EGP relays that were found to be installed beyond their recommended service life. The untimely evaluation delayed compensatory actions and potentially adversely affected the reliability of the valves to perform their safety function when required. The significance of the finding was very low because subsequent testing of the relays determined that they would have operated when required. As stated above, Entergy replaced the affected relays.
The report also documents that the inspectors reviewed Pilgrim's interim actions for Column 4 entry. According to the report, Entergy implemented initial actions by late January 2016 and additional interim actions in April 2016 through July 2016 based on site recovery team feedback identified during preparations for the IP 95003 inspection. The inspectors specifically reviewed Entergy actions in the quality of operability evaluations and functionality assessments and abnormal operating procedure quality. The inspectors also reviewed the status of site recovery performance indicators and metrics. The actions initiated in these areas are intended to address declining performance at the site until Entergy completes development and implementation of the formal comprehensive recovery plan.
- No significant performance deficiencies were identified regarding the timeliness or quality of the reviewed actions.
- Entergy interim actions in these areas focused on: improving guidance for procedure writing, establishing new procedure standards and revising abnormal operating procedures based on the new standards, providing mentors/subject matter experts in operability evaluation for operations department staff and developing templates and road maps in support of documenting better operability evaluations.
- Inspectors determined that the reviewed interim actions were adequate to prevent futher degradation of performance in these areas.
Planned Activities:
As discussed in a Notification of Inspection letter issued on Dec. 18, 2015, (ML15352A128) the Inspection Procedure 95003 inspection will be completed in three phases. Phases "A" and "B" are complete and documented in the two applicable standalone reports (ML16060A018 & ML16144A027). On Sept. 2, 2016, Entergy declared its readiness (ML16258A004) for the Phase "C" inspection and on Oct. 13, 2016, Region I formally announced the onsite dates for the Phase "C" inspection: Nov. 28 to Dec. 9, 2016, and Jan. 9 – 13, 2017 (ML16286A592).
Program Documents
