Neil Sheehan
Public Affairs Officer
Region I
As a new year kicks into gear, the NRC will be stepping up its oversight activities at the Pilgrim nuclear power plant. The start of a formalized review process is in line with our pledge last year to apply additional scrutiny amid performance concerns.
In September, the agency announced the finalization of an inspection finding for the Plymouth, Mass., facility. Classified as “White,” or of low to moderate safety significance, the finding 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.
We said at the time that the plant would be subjected to numerous hours of inspections above the normal level as a consequence of the change. While all of the specific details of the increased oversight are not yet in place, we’ve notified the plant’s owner, Entergy, that the inspection process would entail three phases.
Phase “A” of the 95003 process – that number refers to an inspection procedure for plants in Column 4 — is scheduled to occur this week. It will involve a review of various aspects of the plant’s corrective action program, with a specific focus on older items that were in need of attention. A plant’s corrective action program serves the vital purpose of ensuring problems are addressed in a timely manner, and we want to ensure items entered into it were, in fact, appropriately dispositioned.
The objective will be to determine if continued operation is acceptable and whether additional regulatory actions are required to arrest declining performance.
Current plans call for Phase “B” to be carried out during the week of April 4. During that phase, the NRC will evaluate the overall performance of the plant’s corrective action program since a problem identification and resolution inspection was completed there last August. In other words, this phase will be keyed to more recent corrective actions, particularly since the plant entered Column 4.
Each of those phases will be performed by three inspectors from the NRC’s Region I Office in King of Prussia, Pa.
Based on the results of those first two phases, the NRC will develop a plan for, and map out the scope of, Phase “C.” It will cover items not inspected during the first two phases and include an assessment of the plant’s safety culture and such areas as human performance, equipment reliability and procedure quality.
What’s more, the inspectors will review the work done as part of the plant’s performance improvement plan. That plan is due to be submitted to the NRC sometime in mid-2016.
This final phase will be the most comprehensive of the three and will seek to inform the agency’s decision on whether sufficient progress has been made to end the agency’s increased oversight of the facility. The timeframe for that review will be available later this year.
Another step will be the NRC’s issuance of a Confirmatory Action Letter to Pilgrim that will spell out actions needed for the plant to satisfy any remaining safety concerns. The agency will subsequently inspect the company’s follow-through on those commitments.
It should be noted that the NRC has not waited until now to increase its oversight at Pilgrim following the decision last September. The agency has already performed focused inspections at the plant, in such areas as operator performance, preparations for adverse weather, and problem identification and resolution.
In addition, the NRC has added a third Resident Inspector – there are normally two — assigned to Pilgrim since November.
Even though Entergy has announced that Pilgrim will be shutting down no later than June 2019, the NRC remains committed to our safety oversight, with these inspections helping to inform our determinations.
We also remain committed to communicating to the public regarding our oversight activities at Pilgrim as they advance. That information will be made available via this blog, our web site and in correspondence. Stay tuned.
U.S. NRC Blog 
It would be interesting to hear the commissioners address the
NRC Electrical Engineers’ Single Phase Fault 2.206 Petition
https://app.box.com/files/0/f/6776544878/1/f_55198436818
This episode may well begin to unravel the deep-seated dysfunction at the NRC. There seems to be a shortfall in competence, integrity, compliance, and transparency.
It is so engrained that the insiders do not even see it. “It’s what’s for dinner.”
It reminds me of the ways NRC handled the Peach Bottom Sleepy Hollow Slumber Party for Security Officers, the Davis-Besse Inspection Deferral, the Callaway Shutdown on Xenon, the Oconee-Jocassee Dam Vulnerability, the AIM Pipeline Non-existing Safety Analysis, and other issues raised out of the usual routes. (Which other ones pop to mind?)
Instead of using concerned individuals’ lack of expertise in the Byzantine Briar Patch to block the addressing of concerns, the NRC should have an Office of Dissenters Resources that helps concerned individuals through the briar patch.
There is a sad lack of leadership that is willing to stop the circle-the-wagons stiff-arming meetings and say, “What’s the right thing to do?”
Who know what could be achieved if the NRC put as much effort into solving safety problems as they put into proving that they are not problems?
The archive of official emails, meeting minutes, and memoranda should tell much of the story.
Who can get the collection of records released?
What has been the leadership involvement of senior staff, ACRS, and the commissioners?
Is there anyone willing to step up to the plate and keep this fiasco from being even more of an embarrassment?
The petition stated (in part):
“At Byron, a failure to design the electric power system’s protection scheme to sense the loss of a single phase between the transmission network and’ the onsite power distribution system resulted in unbalanced voltage, at both engineered safety features. (ESF) buses (degraded offsite power system), trip of several safety-related pieces of equipment and the unavailability of
the onsite electric power system.”
Some of the unanswered questions are:
What are the conditions, behaviors, actions, and inactions that resulted in this design failure?
What are the conditions, behaviors, actions, and inactions that resulted in this issue not being surfaced at the pre-license stage?
What are the conditions, behaviors, actions, and inactions that resulted in this issue not being resolved through the station corrective action program after it was first discovered?
Since the petition indicates that the probabilistic risk analysis (PRA) was grossly optimistic, what are the conditions, behaviors, actions, and inactions that resulted in the grossly optimistic PRA?
What are the other unanswered questions?
What can be done about it:
Individuals may contact their senators/ representatives to recommend Government Accountability Office (GAO) investigation of potential NRC internal noncompliance, bullying, fraud, waste, and mismanagement related to this episode.
Fully support your comment Bill
If you want safety, peace, or justice, then work for competency, integrity, and transparency.
Niel – Nice PR job (seriously) and glad to see the NRC is putting its best foot forward in disseminating the oversight process for a plant with multiple/repetitive degraded cornerstone and on its way to a voluntary shutdown. THIS IS a tough town, and a tough customer to please.
Work hard, you have got a tough job cut up for you!
Good luck and you are going to need it!
CaptD,
Do you have any links to the #SanOnofreGate ?
RE: the NRC has added a third Resident Inspector
It would be best if the NRC used inspectors from other Regions, since there would be much more “Inspecting” done without having to “fit in” with the local inspectors views of ongoing safety. If this had happened at San Onofre, #SanOnofreGate * would never have occurred.
I would also suggest that outside consultants also be tasked with surprise inspections of each NPP, Beckman Associates “Independent Consultants Inspection Report of what occurred at San Onofre was critical of not only the operator SCE’s questionable root cause but also of the Region IV NRC AIT Report (which is why it was not released to the public until after it was announced San Onofre was being decommissioned, which also conveniently stopped the investigations in the root cause of the destruction of the almost new Replacement Steam Generators (RSGs) due to In-Plane Fluid Elastic Instability (IPFEI). Happily, the root cause investigation of what happened at San Onofre is still being continued, it is just not being done/controlled by SCE or the NRC…
* The investigation into the multi-billion $ SCE-CPUC ripoff.
• Character
An inescapable fact is that the character of an industry is largely a reflection of the character of its regulators, and, of course, vice versa . Competence, integrity, compliance, and transparency or their lack seldom exist on only one side of an industry-regulatory interface .
• Elementary Failures
An inescapable fact is that the competent investigation of every harmful event reveals that the causation of the harm includes the failure to apply elementary principles of design , human factors , human behavior technology, engineering , science, operations, communications, administration , quality , regulatory compliance, and/or management. Often there is a contemptuous/ dismissive/ arrogant/ ignorant disregard for even needing to know what these elementary principles are, much less flowing them down to where they might need to be applied.
True, which is why the NRC needs to start prioritizing with the industry in such a way dysfunction is organised to closing down the old plants, getting the waste managed on a whole new level, and, if new nuclear plants are built they use recycled waste as fuel.
• Dysfunctional Priorities
An inescapable fact is that the competent investigation of every harmful event reveals that the causation of the harm includes the dysfunctional prioritization of something conflicting with safety by multiple individuals, entities, groups, and organizations. These include regulatory agencies, oversight agencies, trade organizations, professional societies, standards making bodies, labor organizations, industrial/commercial entities, investors, management, and individual contributors.
WILL comply.
Be hardcore nit pickers on steroids. They well comply. #fuqafukushima
• Mistaken Trust
An inescapable fact is that the competent investigation of every harmful event reveals that the causation of the harm includes the mistaken/ naïve/ unwarranted/ gullible/ imprudent trust in one or more erroneous/ untrustworthy assumptions, devices , procedures, processes, people, contractors , and/or conditions. The functional alternatives include monitoring, curiosity, skepticism, and the “questioning attitude.” “You get what you inspect; not what you expect.”-an old Navy proverb