Today, Feb. 2, 2015, the Nuclear Regulatory Commission (NRC) initiated a special inspection team at Pilgrim Nuclear Station to investigate the facility’s Jan. 27th shutdown due to winter storm Juno. Read more about the problems Pilgrim experienced due to Juno HERE.

See below for a request from Pilgrim Watch and the Duxbury Nuclear Advisory Committee sent to the NRC. It asks that Pilgrim remain closed until the NRC’s investigation is completed to determine the root and contributing causes of the recent events and their significance, and until all corrective actions for risk-significant issues have been completed.

Click HERE for a PDF of the Pilgrim Watch/Duxbury Nuclear Advisory Committee request. Click HERE for the NRC’s press release about the special inspection team HERE. In the press release, NRC Region I Administrator stated, “…we want to examine more closely the challenges that surfaced during the event, including safety system and equipment problems and the loss of the two off-site power lines.”

 

February 2, 2015

Chairman Burns
Raymond McKinley
US NRC
Via Email

Hello:

Pilgrim Watch and the Town of Duxbury Nuclear Advisory Committee request that Pilgrim remain closed until NRC has completed its investigation to determine the root and contributing causes of the recent events and their significance, and until all corrective actions for risk-significant issues have been completed.

Our request to keep Pilgrim closed during this period is supported by NRC’s January 26, 2015 Inspection Report that followed Pilgrim’s 2013 four scrams.[1] In the report, NRC found that Entergy had not completed corrective actions or performed proper causal analysis that the NRC previously directed it to complete and perform. The NRC concluded that Pilgrim will remain in the degraded category.

Entergy’s failures to do what it previously was directed to accomplish provides every reason for us (and the NRC) to believe that Entergy will be equally deficient in making a causal analysis and taking corrective actions on equipment issues that occurred in this storm – at least unless Entergy is sat on by the NRC. The public deserves to be given the information it needs to know that NRC’s analysis and corrective actions are completed with respect to safety significant equipment — before the reactor becomes operational. We have lost confidence in the company with its record of ignoring fixes and ignoring preventative maintenance.

Pilgrim Watch and the Town of Duxbury Nuclear Advisory Committee also have the following questions regarding events at Pilgrim Station relating to the recent Juno storm. Because NRC is sending a Special Investigation Team due to arrive February 2 to review the circumstances surrounding the January 27 unplanned reactor shutdown during the snow storm, we hope to receive answers to these questions reasonably soon.

Questions Regarding Events at Pilgrim Station Relating to Juno

The Preliminary Notification of Event or Unusual Occurrence – PNO-I-15-001 (January 29, 2015) said that Pilgrim experienced equipment issues while cooling down after the scram including:

  • The High Pressure Coolant Injection System had to be secured due to failure of the gland seal motor.
  • The station diesel air compressor failed to start.
  • One of four safety relief valves could not be operated manually from the control room.

1. Gland Seal Motor- preventative maintenance

  1. How often has that motor, and others, been checked by “meggering” to measure the resistance of the electrical insulation? When most recently?
  2. How often has that motor, and others at Pilgrim, been opened, inspected and cleaned? When most recently
  3. How often has the area around that motor, and others at Pilgrim, been cleaned? When most recently?

2. Station Diesel Air Compressor Failure to Start

  1. Please provide a description of the failure – its cause, significance, and fix – and a corrective action schedule.
  2. If a lack of preventative maintenance contributed to or in any way failed to prevent the failure, please explain.

3. One of Four Safety Relief Valves Could Not Be Operated Manually From Control Room

  1. Please provide an ML for a description of the failure – its cause, significance, fix – and a corrective action schedule.
  2. If a lack of preventative maintenance contributed to or in any way failed to prevent the failure, please explain.

4. Switchyard – Loss of 345-KV power lines

  1. What caused the loss of offsite power?
  2. Was it due to arcing in Pilgrim’s switchyard, as opined by NRC’s Neil Sheehan?[2] We understand that arcing occurs when electricity jumps from the transmission line to nearby metal; and that storm conditions, particularly in a plant adjacent to wind-driven salt water, can cause arcing.
  3. Is this event the result of or in any way related to Entergy’s failure to complete required corrective actions following the February 8, 2013 scram during a winter storm; or is it simply another example of Entergy’s failure to perform preventative maintenance to determine, e.g., when to replace insulators? The NRC January 26, 2015 Report [3] said that:

Specifically, for the scram which occurred on February 8, 2013, during a winter storm, Entergy did not complete an action to send a faulted component for failure analysis in accordance with CAP procedure requirements. This prevented the inspectors from verifying that Entergy understood the material condition of the main switchyard transformer insulators and that the material condition and supporting preventative maintenance tasks were sufficient. The intent of this testing is to assist in determining a replacement strategy for insulators and is used to determine the condition of the insulator exterior glazing which is effective against contamination from coastal salt, fog, and/or mist conditions. Additionally, inspectors identified that Entergy had failed to complete one of the effectiveness reviews for this RCE in accordance with their CAP requirements.

5. 3rd Point Feedwater Heater-overdue

We understand that this heater was purchased in 1999 and that tubes of the heater have worn out. It was scheduled to be replaced during a previous refueling outage but replacement was deferred.

  1. Is this yet another example of Entergy deferring maintenance until the component breaks?
  2. What is the safety significance of deferring replacement?
  3. Why would this not be a good time to replace it while the reactor is down?

6. Outstanding Question- Entergy’s Waterways Project

Pilgrim’s Waterways Project is in response to EA-12-049 that requires additional mitigation requirements in the event of beyond-design basis external event. The required mitigation in this case it to be able to provide supplemental coolant water to prevent a meltdown. Pilgrim Watch’s January 30, 2015 email to NRC (Attachment) showed that Entergy’s plan to provide supplemental water has little to no probability of working. Juno conclusively proved that it would not work – it’s a joke.

  1. PW asked NRC on January 30 whether either Entergy or NRC actually tested the plan during the height of the blizzard – a bad storm, but not unlike many other storms in the past, certainly not the worst, and certainly not more severe that storms predicted to occur here in the future. We want to know if NRC has asked Entergy to go back to the drawing board and come up with a real plan to get supplemental water when it is needed to prevent a meltdown. If not, why not? Please provide documentation.

Conclusion

Pilgrim Watch and The Town of Duxbury’s request for delaying restart rely on the fact that the testing and inspection regimes at Pilgrim as well as the NRC’s oversight efforts have been demonstrated to be lacking the past two years. Why, for example, didn’t those efforts discover the impairments that allowed a safety relief valve to malfunction, the HPCI system to fail while running, the standby diesel generator to fail to start, etc?

The unplanned scrams at Pilgrim the past two years show that testing and inspection by the owner or oversight by the NRC is not catching these glitches. Instead, it’s more trial and error (emphasis on error) that it surfacing these problems. Hence, what assurance does the NRC and the public have that these latest overlooked problems are the only ones at Pilgrim?

If Pilgrim faced a larger challenge, would more existing safety problems missed by testing and inspecting cause disaster? In other words, if the handful of safety glitches were the only problems afflicting Pilgrim, a shutdown likely would not be warranted. But more likely than not, they represent an unknown number of other safety glitches that put the people of the area at elevated and undue risk. Rather than waiting for the big one, the NRC should take steps to flush out those other problems as well as compel the deficiencies in Entergy’s so-called testing and inspection regimes that seem unable to find problems.

Thank you again for your attention.

Respectfully,

Mary Lampert, Pilgrim Watch/Duxbury Nuclear Advisory Committee
148 Washington Street, Duxbury, MA 02332
Tel. 781.934.0389, Email: mary.lampert@comcast.net

Rebecca Chin, Duxbury Nuclear Advisory Committee
Deerpath Trail North, Duxbury 02332
Tel. 781.837.0009, Email:rebeccajchin@hotmail.com

See PDF version to read the attachment