NRC Oversight at Pilgrim Plant Entering a New Phase

Neil Sheehan
Public Affairs Officer
Region I

One phase down but more to go. We’re referring here to the multiple steps involved in the NRC’s heightened oversight of the Pilgrim nuclear power plant.

pilgIn January, an NRC team completed Phase “A” of the multi-step inspection process required for plants that end up in Column 4 of the agency’s Action Matrix. Pilgrim received that designation last September based on earlier performance issues.

This first inspection examined various aspects of the Plymouth, Mass., plant’s corrective action program, which is in place to ensure that problems, once identified, are fixed on a timely basis according to their safety importance.

Our report on that review noted the identification on one inspection finding of very low safety significance involving a failure to adequately correct water leakage from the core spray system. Otherwise, the inspectors determined that there were no longstanding risk-significant issues in the program that were not addressed or assigned appropriate corrective actions and due dates.

Beginning today, the Phase “B” review will get under way at the facility. This inspection will focus additional attention on the corrective action program but with emphasis on its effectiveness more recently, specifically since the plant began undergoing increased scrutiny last summer.

As was the case with the first phase, the results will be documented in a report due out within 45 days after the assessment has been formally concluded, or exited.

The most comprehensive phase of this process (known in NRC terms as a 95003 inspection) will take place later this year or in early 2017. It will zero in on areas that will include human performance, equipment reliability and the quality of plant procedures, as well as the site’s safety culture, or the willingness of employees to freely and openly raise safety concerns. The corrective action program will also receive another look.

In the meantime, the NRC will be updating the public on Pilgrim’s performance during 2015 at a meeting scheduled for Wednesday, April 13, in Plymouth. We’ll also be taking questions, including those pertaining to our additional oversight of the plant. Further details will be available soon in a meeting notice to be posted on the agency’s website.

More information on NRC oversight activities at Pilgrim can be found on our webpage devoted to the subject.

Author: Moderator

Public Affairs Officer for the U.S. Nuclear Regulatory Commission

20 thoughts on “NRC Oversight at Pilgrim Plant Entering a New Phase”

  1. There has been a shocking collapse in the NEISO market. We haven’t seen it go deep in the residential rates yet. There is zero chance Pilgrim is profitable. I’ll bet you 30% of the electric power producers in NE aren’t profitable either. The NEISO is under investigation for corrupt and unfair rates. How can we have a stable electric system with this? This is the snap-back for collusion to keep rates high for years.
    http://www.iso-ne.com/static-assets/documents/2016/04/2016_03_monthly_market_report.pdf
    Operations Report
    March 2016
    Market Analysis and Settlements
    APRIL 11, 2016
    Day-ahead and real-time LMPs at the New England Hub averaged $20.63/MWh and $17.20/MWh, respectively, during March 2016. Day-ahead and real-time prices at the Hub and in the Load Zones averaged 30-38% lower than February 2016 averages. In the aggregate, March 2016 day-ahead and real-time LMPs were approximately 69% lower during March 2016 than during March 2015. Average natural gas prices were 76% below the prior year’s average prices, while residual fuel prices were down 48% from a year ago.

  2. Nuclear Plant is becoming one of the most trusted sources of electricity these days. Also it plays an important role in huge and mass power generation. But the Government should ensure it is completely safe and protected against any hazards or mishappenings.

  3. • Insufficient Transparency

    An inescapable fact is that harmful conditions were not discovered earlier because they were not sufficiently transparent at the times they were not discovered . Harmful conditions were not discovered earlier because they were not sufficiently transparent to any of the people who missed the opportunities for discovering them .

    Observation: Transparency makes it easy to see what’s wrong.

    Observation: Transparency makes it hard to conceal what’s wrong.

    “Transparency is the best deodorant.”-Unknown (for now)

    Observation: Those who keep their cards too close to the vest forget what is in their hand.

    Observation: Transparency is the mortal enemy of deception, fraud, waste, incompetence, cronyism, wrongdoing, and sometimes even stupidity.

  4. Mr. Adams: Our webpage devoted to our increased oversight activities at Pilgrim explains what will happen going forward. Essentially, the plant’s change in status triggered a review governed by Inspection Procedure 95003. I won’t try to summarize all of the steps involved here; they are detailed on the webpage. But suffice it to say, Pilgrim will continue to receive additional scrutiny until that process has been completed.

    Neil Sheehan

  5. Rod,

    The dysfunctional parts of the culture persist through multiple management changeouts, but the good safety culture needs constant reinforcement.

  6. This discussion has strayed from the original blog post content. Further discussion will need to be posted to the Open Forum section.

  7. I note from the Reactor Oversight Process Action Matrix page that Pilgrim’s movement to column 4 resulted from a single White finding in Q3 of 2013, another in Q4 of 2013 and a third in Q1 of 2015. How long do findings continue to count towards “repetitive?” An awful lot changes at a power plant operating ~ 7000 hours per year over the course of 3 years.

  8. Neil:

    Thank you, but that does not actually answer my question. This might be an understanding between the regulator and the ever compliant industry, but how does it affect other people with a stake in the matter? Does the system improve safety? Does it help our necessary efforts to battle climate change? Does it improve performance to beat up operators to the point where they decide to give up and shut down?

    The NRC may be independent, but its job is to regulate “the Nation’s civilian use of radioactive materials to protect public health and safety, promote the common defense and security, and protect the environment.”

    Pushing nuclear plants into a shutdown decision based on a few events that had little or no impact on safety doesn’t help fulfill any of those mission areas.

    Nuclear energy regulation isn’t supposed to push for ever higher levels of polished cannon balls or improvements in clearing an ever-rising subjective performance bar that is already well above adequate protection.

  9. @steamshovel2002

    Sure, the public perception of nuclear is in the toilet. That is a big concern of mine, but part of the explanation for that polling result was the intense propaganda effort to tell people that they should be VERY afraid of nuclear because of Fukushima.

    That event did not release harmful quantities of radiation and did not harm a single member of the public. Despite all of the hyped stories of operator heroism — I’m not criticizing their professional dedication — even the operators were not in any danger if they simply followed a few precautions that are a part of their basic training programs.

    It’s no mystery to me why the public worries about nuclear because of the Fukushima Frenzy. It’s also not surprising that the same public comfortably continues to accept the hazards of hydrocarbons despite the dozens of fires and massive pollution releases at places like the Cosmo refinery in Chiba.

    That earthquake stimulated inferno burned for ten solid days before being brought under control. The only “coverage” I saw of it came as the background video being played as one of the network news readers described the “horrors” of the slowly developing situation at Fukushima Daiichi.

    When people are told that they should be afraid of something, some of them listen and seek additional layers of protection even when the source of the fear stories was inventing the risk.

    The nuclear industry and its regulator have not done a very good job of reminding the public how well the plants normally operate, how beneficial their clean power is compared to the functional alternatives, and how small the issues that have been blown out of proportion really are.

    [Moderator Note: Some verbiage was removed here to adhere to the comment policy.]

    I know you express pride in your accomplishments, but I see it quite differently. Destruction is so much easier than constructive engagement that leads to solid, measurable improvements.

    [Moderator Note: Some verbiage has been removed to adhere to blog comment policy.]

    Rod Adams
    Publisher, Atomic Insights

  10. Mr. Adams: Our current Reactor Oversight Process has been in place since the spring of 2000. It is well understood by plant owners what the corresponding level of NRC oversight will be if violations are identified and/or performance indicators are exceeded that result in a facility’s shift to a different column of the agency’s Action Matrix. Pilgrim moved to Column 4 of the Action Matrix last September based on several “white” inspection findings that had been identified.

    More information on NRC oversight activities at Pilgrim can be found on our webpage devoted to the subject.

    Neil Sheehan

  11. Rod,

    Basically in a 2013 2.06 I scripted the results of the 2015 Pilgrim Special inspection. I anticipated the final outcome of the defective 3 stage SRVS. Everything I said in the 2013 2.206 was proven in the 2015 special inspection. They first put in the 3 stage SRVs in 2011, within two weeks of first heatup, one began leaking. And they all leaked and leaked, misoperated, and down powered for the next 3 years over SRVs.

    The most damning event was on the approach Storm Juno- I was the first one in the USA who predicted a very infrequent LOOP on the approach of this Nor’easter, then the LOOP happened. Don’t even get me talking about the unreported loss and degradation of the meteorological towers over many years. The organizational deep instincts to not disclose the bad news or emediately fix the safety components. I’ll make the case Pilgrim’s LOOP rate is 17 times worst as the standard LOOP rate inputted into all risk calculation nationwide. The NRC prematurely released the special inspection (the day before the storm struck- ML15026A069), where they spent a lot of print in the inspection report explaining why the switchyard was not designed for the expected climate. The agency anticipated the certain approaching LOOP, the premature release was an attempt to mitigate the agency’s damage to their reputation when the LOOP occurred. So everyone essentially paper whipped the heck of this plant’s safety vulnerability, then failed to prevent the next LOOP.

    Basically two SRVs failed to open or shut on this LOOP,I think the NRC discover on two sequential LOOPs (2013 and 2015), Entergy failed to detect it and report on it. In the inspection with NRC looking over Pilgrim documents, they picked up the failed to operate when called. This all ruined the reputation of Entergy and the NRC.

    Basically throughout our history, the genesis of over-regulation has always emerged from regulatory embarrassment. The plant, sector or business going wild on us, damaging the reputation of the federal regulator and our perfectly beautiful government. Then the sector or plant begins a fight for survival…over regulation is always a part of survival.

    You guys better be careful with the most recent Gallup poll. It identified a historic decline of public approval with Nuclear Power. And the Republicans had the most precipitous decline of public approval compared to the Democrats.

  12. To the moderator:

    If you follow drbillcorcoran’s advice, that would be great. In addition you might answer a question stimulated by that response.

    If “the worst plant not getting a punitive inspection” still provides adequate protection to the public by not having any events that impose any risk of public harm or qualify specific violations of license conditions, is there an unwritten rule requiring the “worst” of a well-run and operated fleet to receive a financial penalty that is more severe than the actual dollar amount of a large fine?

    I realize that some people are not reassured by the word “adequate,” but the standards imposed to achieve that judgement by the NRC are quite high.

  13. To the Moderator,

    A good way to answer Rod’s excellent question would be to provide a chronological listing of the harmful events, NRC findings, and self-reported conditions adverse to quality safety at Pilgrim and at the worst plant not getting a punitive inspection.

    OBTW: It is an inescapable fact that an NRC Inspection is a way to impose additional costs and resource loads on a licensee without enforcement action. This is because the licensee bears the costs of the inspection and has to expend resources preparing for it and hosting the inspection team.

  14. Neil:

    Can you please help me understand what Pilgrim did to deserve this exceedingly expensive “penalty box” treatment? The answer may require you to work your way up the chain of command for an answer, but please try to do so.

    I realize that the NRC carefully avoids taking its imposed costs into consideration during decision making, but I still fail to understand how a small number of unrelated, minor issues add up to the need for heightened attention that causes a plant owner to spend tens of millions of dollars in extra contract labor and overtime.

    Is it that all the remaining plants in the US are performing so well that expectations of unattainable perfection have shifted even higher?

    Unless your organization is completely isolated from reality, I’m sure that you are aware of the following facts:

    – Even without the heightened attention from headquarters, every nuclear plant has at least two on site inspectors. No other industrial facility in the US has such close inspection by its regulator, even those with far more risk of harming the public.
    – Each of our operating nuclear power plants avoid the production of millions of tons of CO2 each year compared to the fossil fuel that would need to be consumed to replace their power output
    – Natural gas prices lower than any seen in the past 20 years as a result of a massive drilling campaign and an historically warm winter have reduced the sales price of the electricity nuclear plants produce.
    – That loss of revenue puts plants in a situation of tight profit margins or even financial losses.
    – Added costs that do not marginally improve safety may flip the plant into the loss column and result in pressure to close a facility that is still safely and reliably producing emission free electricity.
    – Closure decisions are permanent. The clean output will be lost for at least the 10-15 years required to plan and build a replacement facility.
    – That invariably makes it even harder to address climate change, which may be a distant threat, but it is quite real for those of us with children or grandchildren to protect.

    Rod Adams
    Publisher, Atomic Insights

  15. So how is the notoriously defective 2 stage SRVs doing at Pilgrim? Any showing signs of leakage yet…one only wonders what the setpoint lift inaccuracy will be?

    This is how Pilgrim should have went in 2013 with a SRV special investigation at Hatch today. Basically Hatch pulled a Pilgrim. They put new 3 stage SRVs and they didn’t even get though their first operational cycle without grave SRV reliability problems. Hatch has been jumping between defective and unreliable 2 and 3 stage SRVs like jumping grasshoppers.

    According to the very nice senior resident who spent all the time I needed with him, the NRC all but ruled out test stand damage. He is the guy going to collect all the component and industry information on the three stage SRV for the special inspection. I reminded him of a 2011 LER talking about, before one cycle was completed, after two shutdowns to repair leaking and defective 3 stage SRVs, they yanked the unreliable and unsafe 3 stage and replace it with the 2 stage. I get it with your guys, everything is always safe. I guess they operated for a few cycle with the old 2 stage, then reinstalled the unreliable and unsafe 3 stage, then some valves mysteriously failed the second (or third time). Pilgrim and Hatch have identical 2 and 3 stage SRVs.

    I was listening to my River Bend’s triple-header special inspection meeting the other day with Entergy talking about coming back to engineering rigor and organizational excellence…does the disgraceful testing and operational history of Hatch’s SRVs remind you of anything “Excellence”???

    Just saying, the NRC discovered SRV mis-operation in early 2015 leading to the Pilgrim downgrade over unreliable and unsafe 3 stage SRVs …basically the same as Hatch’s mis-operation today. Why the difference; Pilgrim yanked all their 3 stage SRVs during their 2015 special inspection (just like Hatch in 2011), why has Hatch Unit 1 been allowed to restart with their defective three stage SRVs after their valve failure? Why are Hatch 1 and 2 operating with defective 3 stage SRVs today?

    I though the NRC was going to put up a blog page about the problems with SRVs, PORVs and MSSVs reliability and testing issues for me. Believe me, we are wondering if Indian Point will submit a LER on MSSV testing failures this outage. That is a insider joke? The lack of current information notices about these important valves is very troubling. Don’t even get me laughing about the solution to this problem was to put in cheap stellite disc and platinum pilot disc coatings, but test failures only worsen with each new quick fix. . It just shows you of the lack of basic engineering understanding that is going on with these safety components.

    Look at how they are chasing their tails; uncoated 2 stage, then stellite pilot disc, then platinum coated pilot disc, then to the 3 stage (massive reliability problems), back to the 2 stage (massive reliability and safety issues), back to the 3 stage, then special inspection on valve failures. In Pilgrim’s case, stuck in the 2 stage until permanent shutdown.

    My blog: Junk Plant Hatch Unit 2 2015 SRV testing report

    http://steamshovel2002.blogspot.com/2016/04/junk-plant-hatch-unit-2-2015-srv.html

    Throwback Wednesday: What model SRV valves (either2 or 3 stage) was first put into these plants when new?

    Mike Mulligan
    Hinsdale, NH

  16. • Leadership and Chilling Effects

    An inescapable fact is that unless leaders reliably and relentlessly report nonconformities their leadership by example is creating a chilling effect.

    Observation: The way to succeed in any organization is to get your job done in the situation you are in, not to fix the organization and then get your job done. Thus, the upwardly mobile tend to put systemic corrective action on the back burner.

    Observation: Many nonconformities are, when surfaced, budget busters and schedule busters, hence they are bonus busters.

    Observation: One of the top principles of human behavioral technology is that people do what they see others do. This is especially compelling when the others are successful, admired, and it positions of authority.

    Observation: Leadership by example is a chilling effect when the leaders do not report the nonconformities that their subordinates know that they know about.

    Adage: “Those who get the picture take a picture.”

  17. • Perceived Benefit from Dysfunctionality

    An inescapable fact is that the causation of the persistence of the dysfunctionality of the generally accepted, ordinary, normal, and usual business practices of the organizations is that there is sufficient perceived benefit from them to deter their identification and correction .

    “When ignorance is bliss ‘tis folly to be wise.”-The Poet Thomas Gray

    Observation: Before the 2008 Financial Crisis it was an open secret that the bond rating agencies had severe conflicts of interest that were skewing their bond ratings.

  18. • Involvement of Business Practices

    An inescapable fact is that the causation of harm, including harmful conditions, behaviors, actions, and inactions, includes the dysfunctionality of the generally accepted, ordinary, normal, and usual business practices of the organizations involved, including oversight, auditing, and regulatory entities .

    Observation: When standard operating procedure is normalization of deviance the occurrence of disaster is not a random event.

    Observation: When something works it is used in more and more challenging applications until it is involved in disaster. This can be called “The Universalized Peter Principle .” The current dysfunctionally widespread use of antibiotics is a painful example .

  19. Oh, this one probably should just be shut down. These old plants really need to be closed for our safety.

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