UNITED STATES

NUCLEAR REGULATORY COMMISSION 

REGION I 

2100 RENAISSANCE BLVD., SUITE 100 

KING OF PRUSSIA, PA 19406-2713 

September 1, 2015 

Mr. John Dent, Site Vice President 

Entergy Nuclear Operations, Inc. 

Pilgrim Nuclear Power Station 

600 Rocky Hill Road 

Plymouth, MA 02360-5508 

SUBJECT: MID-CYCLE ASSESSMENT LETTER FOR PILGRIM NUCLEAR POWER 

STATION (REPORT 05000293/2015005) 

Dear Mr. Dent: 

On August 11, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed its mid-cycle 

performance review of Pilgrim Nuclear Power Station (Pilgrim). The NRC reviewed the most 

recent quarterly performance indicators (PIs) in addition to inspection results and enforcement 

actions from July 1, 2014, through June 30, 2015. This letter informs you of the NRC’s 

assessment of your facility during this period and its plans for future inspections at your facility. 

The NRC determined that the performance at Pilgrim has been in the Repetitive Degraded 

Cornerstone Column (Column 4) of the Reactor Oversight Process (ROP) Action Matrix since 

the beginning of the first quarter of 2015 following the final significance determination of a White 

finding under the Mitigating Systems Cornerstone referenced in a separate letter issued on 

September 1, 2015 (ADAMS Accession No. ML15230A217). Pilgrim was already in the 

Degraded Cornerstone Column (Column 3) of the ROP Action Matrix for more than five 

consecutive quarters as of January 1, 2015, due to two open White inputs under the Initiating 

Events Cornerstone. In Supplemental Inspection Report 05000293/2014008 (ML15026A069), 

dated January 26, 2015, the NRC noted that Pilgrim did not adequately evaluate the causes and 

take or plan timely corrective actions to address the issues associated with a high number of 

unplanned scrams which occurred in 2013. As a result, the two White inputs under the Initiating 

Events Cornerstone remained open for greater than five consecutive quarters and were in effect 

when the new White finding under the Mitigating Systems Cornerstone was identified in an exit 

meeting on March 20, 2015, as documented in Special Inspection Report 05000293/2015007 

(ML15147A412), dated May 27, 2015. The White inputs under the Initiating Events Cornerstone 

have subsequently been closed as of June 30, 2015, due to the successful completion of a 

follow-up inspection in accordance with Inspection Procedure (IP) 95002 as documented in 

Inspection Report 05000293/2015009 (ML15169A946) dated June 18, 2015. 

Notwithstanding the recent closure of the original White inputs, the duration of the original inputs 

combined with the repetitive nature of the new finding highlight persistent weaknesses in the 

Pilgrim Corrective Action Program (CAP) which have contributed to repeated unplanned scrams 

and equipment failures and are consistent with “repetitive degraded cornerstone” as defined in 

NRC Inspection Manual Chapter (IMC) 0305, “Operating Reactor Assessment Program.” 
J. Dent -2- 

As a result of Pilgrim’s entry into Column 4, in addition to ROP baseline inspections, the NRC 

plans to conduct 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.” Based on the persistent CAP 

weaknesses that resulted in Pilgrim’s entry into the repetitive degraded cornerstone, this 

supplemental inspection will be focused on the Pilgrim CAP and safety culture assessment 

(reference sections 02.02 and 02.07 through 02.09 of IP 95003). Given that the Action Matrix 

inputs which caused Pilgrim to enter the repetitive degraded cornerstone have each been 

determined to be of low to moderate safety significance, the NRC considered the focus of the 

supplemental inspection under the affected Strategic Performance Area of Reactor Safety. 

Based on the NRC’s evaluation of those inputs, the reactor safety portion of the supplemental 

inspection will focus on the key attributes of human performance, procedure quality, and 

equipment performance (reference sections 02.03c, 02.03d and 02.03e of IP 95003). 

As described in the objectives section of IP 95003, the results of the supplemental inspection 

will: 1) provide the NRC with additional information to be used in deciding whether the continued 

operation of the facility is acceptable and whether additional regulatory actions are necessary to 

arrest declining licensee/plant performance; 2) provide an independent assessment of the 

extent of risk-significant issues to aid in the determination of whether an unacceptable margin of 

safety or security exists; 3) independently assess the adequacy of the programs and processes 

used by the licensee to identify, evaluate, and correct performance issues; 4) independently 

evaluate the adequacy of programs and processes in the affected strategic performance areas; 

5) provide insight into the overall root and contributing causes of identified performance 

deficiencies; and 6) evaluate the licensee’s third-party safety culture assessment and conduct a 

graded assessment of the licensee’s safety culture based on the results of the evaluation. The 

NRC will plan this inspection activity when you provide written notification of your readiness for 

the inspection. 

In the interim, prior to the completion of IP 95003, IMC 0305 provides a number of regulatory 

tools to ensure increased oversight to monitor for any additional performance decline. For 

instance, the NRC will hold quarterly performance reviews regarding Pilgrim with a particular 

focus on monitoring for additional performance decline. If NRC identifies the need for additional 

regulatory actions, our plans will be communicated to you by letter. The NRC will also engage 

Entergy Nuclear Operations, Inc. (Entergy) with more frequent site visits, and the Commission 

may call for Entergy to discuss its performance improvement plan at a public meeting within the 

next six months. The NRC may take additional regulatory actions as warranted, including 

additional supplemental inspections, a demand for information, or issuance of an order, up to 

and including a plant shutdown. 

From July 1, 2014, through June 30, 2015, the NRC issued three Severity Level IV traditional 

enforcement violations to Pilgrim associated with impeding the regulatory process. Therefore, 

the NRC plans to conduct IP 92723, “Follow-up Inspection for Three or more Severity Level IV 

Traditional Enforcement Violations in the Same Area in a 12 Month Period,” to follow up on 

these violations. 

In addition to the inspections noted above, the NRC plans to conduct Temporary Instruction 

(TI) 2515/190, “Inspection of the Licensee’s Proposed Interim Actions as a Result of the Nearterm Task Force Recommendation 2.1 Flooding Reevaluation,” and TI 2515/191, “Inspection of 
J. Dent -3- 

the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and 

Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans.” 

The enclosed inspection plan lists the inspections scheduled through June 30, 2017. Routine 

inspections performed by resident inspectors are not included in the inspection plan. The 

inspections listed during the second half of the inspection plan are tentative and may be revised 

at the end-of-cycle performance review. The NRC provides the inspection plan to allow for the 

resolution of any scheduling conflicts and personnel availability issues. The NRC will contact 

you as soon as possible to discuss changes to the inspection plan should circumstances 

warrant any changes. This inspection plan does not include security-related inspections, which 

will be sent via separate, non-publicly available correspondence. 

In response to the accident at Fukushima, the Commission issued Order EA-12-049, “Order 

Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-DesignBasis External Events,” which requires licensees to develop, implement, and maintain guidance 

and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling 

capabilities following a beyond-design-basis external event. Additionally, the Commission 

issued Order EA-12-051, “Order Modifying Licenses with Regard to Reliable Spent Fuel Pool 

Instrumentation,” which requires licensees to have a reliable means of remotely monitoring 

wide-range spent fuel pool levels to support effective prioritization of event mitigation and 

recovery actions in the event of a beyond-design-basis external event. The NRC is conducting 

audits of licensee efforts towards compliance with these Orders. The onsite portion of the audit 

has been completed at Pilgrim, and the information gathered will aid staff in development of the 

Final Safety Evaluation for the site. Entergy’s Final Compliance letters (ML15202A415, 

ML15209A606) were submitted, and subsequent to issuance of the NRC’s Final Safety 

Evaluations, the NRC staff will confirm through inspections the full implementation of the orders 

mentioned above by performing TI 2515/191, “Inspection of the Implementation of Mitigation 

Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness 

Communication/Staffing/Multi-Unit Dose Assessment Plans.” 

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRC’s 

“Rules of Practice,” a copy of this letter will be available electronically for public inspection in the 
J. Dent -4- 

NRC Public Document Room or from the Publicly Available Records component of NRC's 

Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible 

from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic 

Reading Room). 

Please contact Raymond McKinley at (610) 337-5150 with any questions you have regarding 

this letter. 

Sincerely, 

 /RA/ 

Daniel H. Dorman 

Regional Administrator

Docket No. 50-293 

License No. DPR-35 

Enclosure: 

Pilgrim Inspection/Activity Plan 

cc w/encl: Distribution via ListServ 
J. Dent -4- 

NRC Public Document Room or from the Publicly Available Records component of NRC's 

Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible 

from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic 

Reading Room). 

Please contact Raymond McKinley at (610) 337-5150 with any questions you have regarding 

this letter. 

Sincerely, 

 /RA/ 

Daniel H. Dorman 

Regional Administrator

Docket No. 50-293 

License No. DPR-35 

Enclosure: 

Pilgrim Inspection/Activity Plan 

cc w/encl: Distribution via ListServ 

DISTRIBUTION: (via email) 

DDorman, RA 

DLew, DRA 

MScott, DRP 

JColaccino, DRP 

RLorson, DRS 

GSuber, DRS 

RMcKinley, DRP 

SShaffer, DRP 

EDiPaolo, DRP 

JDeBoer, DRP 

MHenrion, DRP 

ECarfang, DRP, SRI 

BScrabeck, DRP, RI 

TGreer, DRP, AA 

KMorganButler, RI OEDO 

RidsNrrPMPilgrim Resource 

RidsNrrDorlLPL1-1 Resource 

ROPReports Resource 

DRS Branch Chiefs (6) 

DScrenci, PAO 

NSheehan, PAO 

NMcNamara, SLO 

DTifft, SLO 

ROPassessment Resource 

RidsNrrDirslpab Resource 

DOCUMENT NAME: S:\ROP Assessment Meetings\ROP-16 Mid-Cycle Review\Branch 5\Pilgrim\RI Mid-Cycle Letter Pilgrim Final.docx 

 ADAMS Accession No. ML15243A259 

 SUNSI Review  Non-Sensitive 

 Sensitive 

 Publicly Available 

 Non-Publicly Available 

OFFICE R1/DRP R1/DRP R1/DRP R1/ORA 

NAME EDiPaolo/EMD via 

email RMcKinley/RRM MScott/MLS via email DDorman/DHD 

DATE 8/18/15 8/18/15 8/20/15 9/1/15 

OFFICIAL RECORD COPY 
Page 1 of 2

08/19/2015 12:59:57Report 22

Unit

Number

Planned Dates

Start End Inspection Activity Title

Pilgrim

Inspection / Activity Plan

07/01/2015 - 06/30/2017

71124 - RADIOACTIVE EFFLUENT CONTROL RETS 

1 06/29/2015 07/02/2015 IP 71124.05 Radiation Monitoring Instrumentation1 06/29/2015 07/02/2015 IP 71124.06 Radioactive Gaseous and Liquid Effluent Treatment

7111111B - REQUAL INSP W/ P/F RESULTS 

1 09/14/2015 09/18/2015 IP 7111111B Licensed Operator Requalification Program

71124 - REMP 

1 07/20/2015 07/23/2015 IP 71124.07 Radiological Environmental Monitoring Program

71152B - PI&R - BIENNIAL 

1 08/03/2015 08/07/2015 IP 71152B Problem Identification and Resolution1 08/17/2015 08/21/2015 IP 71152B Problem Identification and Resolution

TRI FI - TRIENNIAL FIRE PROTECTION INSPECTION 

1 11/02/2015 11/06/2015 IP 7111105T Fire Protection [Triennial]1 11/16/2015 11/20/2015 IP 7111105T Fire Protection [Triennial]

71151 - RP CHEM PI VERIFY 

1 11/16/2015 11/19/2015 IP 71124.01 Radiological Hazard Assessment and Exposure Controls1 11/16/2015 11/19/2015 IP 71124.02 Occupational ALARA Planning and Controls1 11/16/2015 11/19/2015 IP 71151 Performance Indicator Verification

TI-191 - FUKUSHIMA LESSONS-LEARNED 

1 02/15/2016 02/19/2016 IP 2515/191 Inspection of Licensee's Responses to Order EA-12-049, EA-12-051 & EP Info Request March 12

71124 - 01 EXPOSURE CONTROL 

1 03/21/2016 03/24/2016 IP 71124.01 Radiological Hazard Assessment and Exposure Controls

71124 - 05 RAD MONITORING INSTRUMENTATION 

1 05/02/2016 05/06/2016 IP 71124.05 Radiation Monitoring Instrumentation

7111117T - PERMANANET PLANT MODIFICATIONS 

1 05/02/2016 05/06/2016 IP 7111117T Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications1 05/16/2016 05/20/2016 IP 7111117T Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications

7111107T - TRIENNIAL HEAT SINK 

1 07/18/2016 07/22/2016 IP 7111107T Heat Sink Performance

2/27EXM - PILGRIM INITIAL EXAM 

1 01/30/2017 02/05/2017 U01945 FY17-PILGRIM INITIAL OPERATOR LICENSING EXAM1 02/27/2017 03/03/2017 U01945 FY17-PILGRIM INITIAL OPERATOR LICENSING EXAM

EP - EP EXERCISE EVALUATION 

1 11/14/2016 11/18/2016 IP 7111401 Exercise Evaluation

This report does not include INPO and OUTAGE activities. This report shows only on-site and announced inspection procedures.
Page 2 of 2

08/19/2015 12:59:57Report 22

Unit

Number

Planned Dates

Start End Inspection Activity Title

Pilgrim

Inspection / Activity Plan

07/01/2015 - 06/30/2017

71124 - 71151 PI VERIFY 71124.01EXPCONT05RAD MON 

1 11/21/2016 11/25/2016 IP 71124.01 Radiological Hazard Assessment and Exposure Controls1 11/21/2016 11/25/2016 IP 71124.05 Radiation Monitoring Instrumentation1 11/21/2016 11/25/2016 IP 71151-OR01 Occupational Exposure Control Effectiveness1 11/21/2016 11/25/2016 IP 71151-PR01 RETS/ODCM Radiological Effluent Occurrences

7111108G - INSERVICE INSPECTION 

1 04/17/2017 04/21/2017 IP 7111108G Inservice Inspection Activities - BWR

71124 - 71124.01 RAD HAZARD AND 71124.02 ALARA 

1 04/24/2017 04/27/2017 IP 71124.01 Radiological Hazard Assessment and Exposure Controls1 04/24/2017 04/27/2017 IP 71124.02 Occupational ALARA Planning and Controls

71124.08 - RADWASTE 

1 06/05/2017 06/09/2017 IP 71124.08 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transporta

71124 - RAD HAZ- ALARA- AIRBORNE-DOSIMETRY 

1 06/19/2017 06/23/2017 IP 71124.01 Radiological Hazard Assessment and Exposure Controls1 06/19/2017 06/23/2017 IP 71124.02 Occupational ALARA Planning and Controls1 06/19/2017 06/23/2017 IP 71124.03 In-Plant Airborne Radioactivity Control and Mitigation1 06/19/2017 06/23/2017 IP 71124.04 Occupational Dose Assessment

This report does not include INPO and OUTAGE activities. This report shows only on-site and announced inspection procedures.