The Cape Cod Times recently reported* on a security violation at the Pilgrim nuclear plant: one employee entering a secure area facilitated “tailgating” by a second employee who had forgotten his badge. He didn’t want to go to Security to obtain clearance for entry because that would make him late for work.
The NRC determined the pair were deliberately taking a shortcut but were not attempting to do something malicious. The NRC investigation also revealed that other personnel, including security, had utilized the same shortcut in the past to allow workers to exit the plant. The result of the investigation was a Level IV violation for the plant.
Of course, the plant’s enemies are on this like a duck on a June bug, calling the incident alarming and further evidence for immediate shutdown of the plant. Entergy, the plant’s owner, is characterized as indifferent to such activities.
The article’s high point was reporting that the employee who buzzed in his fellow worker told investigators “he did not know he was not allowed to do that”.
Our Perspective
The incident itself was a smallish deal, not a big one. But it does score a twofer because it reflects on both safety culture and security culture. Whichever category it goes in, the incident is a symptom of a poorly managed plant and a culture that has long tolerated shortcuts. It is one more drop in the bucket as Pilgrim shuffles** toward the exit.
This case raises many questions: What kind of training, including refresher training, does staff receive about security procedures? What kind of oversight, reminders, reinforcement and role modeling do they get from their supervisors and higher-level managers? Why was the second employee reluctant to take the time to follow the correct procedure? Would he have been disciplined, or even fired, for being late? We would hope Pilgrim management doesn’t put everyone who forgets his badge in the stocks, or worse.
Bottom line: Feel bad for the people who have to work in the Pilgrim environment, be glad it’s not you or your workplace.
** In this instance, “shuffle” has both its familiar meaning of “dragging one's feet” and a less-used definition of “avoid a responsibility or obligation.” Google dictionary retrieved July 27, 2017.
A couple of recent reports address the nuclear safety culture (NSC) problems at Pilgrim and Watts Bar. This post summarizes the reports and provides our perspective on their content. Spoiler alert: there is not much new in this news.
Pilgrim
The NRC issued their report* on phase C of their IP 95003 inspection at Pilgrim. This is the phase where the NRC conducts its own assessment of the plant’s NSC. The overall finding in the cover letter is: “The NRC determined that programs and processes at PNPS [Pilgrim] adequately support nuclear safety and that PNPS should remain in Column 4.” However, the letter goes on to detail a host of deficiencies. The relative good news is that Pilgrim’s NSC shortcomings weren’t sufficiently serious or interesting to merit mention in the cover letter.
But the NRC had plenty to say about NSC in the main report. Highlights include the finding that NSC is a “fundamental problem” at Pilgrim. NSC gradually deteriorated over time and “actions to balance competing priorities, manage problems, and prioritize workload resulted in reduced safety margins.” Staffing reduction initiatives exacerbated plant performance problems. Personnel were challenged to exhibit standards and expectations in conservative decision-making, work practices, and procedure use and adherence. Contributing factors to performance shortcomings include lack of effective benchmarking of industry standards and the plant’s planned 2019 permanent shutdown. The NRC also noted weaknesses in the Executive Review Board, Employee Concerns Program and the Nuclear Safety Culture Monitoring Panel. (pp. 8-10)
Watts Bar
In April the TVA inspector general (IG) issued a report** castigating TVA management for allowing a chilled work environment (CWE) to continue to exist at Watts Bar. The IG report’s findings included: TVA's analyses and its response to the NRC’s CWE letter were incomplete and inadequate; TVA's planned corrective actions are unlikely to have long-term effectiveness; precursors of the CWE went unrecognized by management; and management has inappropriately influenced the outcome of analyses and investigations pertaining to Watts Bar NSC/SCWE issues. Staff stress, fear and trust issues also exist.
In response, TVA management pointed out the corrective actions that were taken or are underway since the first draft of the IG report was issued. Additionally, TVA management “has expressly acknowledged management's role in creating the condition and its responsibility for correcting it."
Our Perspective
This is merely a continuation of a couple of sad stories we’ve been reporting on for a long time. Click on the Entergy, Pilgrim, TVA or Watts Bar labels to get our earlier reports.
The finding that Pilgrim did not adequately benchmark against industry standards is appalling. Entergy operates a fleet of nuclear plants and they don’t know what industry standards are? Whatever. Entergy is closing all the plants they purchased outside their service territory, hopefully to increase their attention on their utility-owned plants (where Arkansas Nuclear One remains a work in progress).
We applaud the TVA IG for shining a light on the agency’s NSC issues. In response to the IG report, TVA management put out a typical mea culpa accompanied by claims that their current corrective actions will fix the CWE and other NSC problems. Well, their prior actions were ineffective and these actions will also probably fall short. It doesn’t really matter. TVA is too big to fail, both politically and economically, and their nuclear program will likely continue to plod along forever.
In the last few years, nuclear plant owners have shut down or scheduled for shutdown 17 units totaling over 14,000 MW. Over half of these units had (or have) nuclear safety culture (NSC) issues sufficiently noteworthy to warrant mention here on Safetymatters. We are not saying that NSC issues alone have led to the permanent shutdown of any plant, but such issues often accompany poor decision-making that can hasten a plant’s demise. Following is a roll call of the deceased or endangered plants.
Plants with NSC issues
NSC issues provide windows into organizational behavior; the sizes of issues range from isolated problems to systemic weaknesses.
FitzPatrick
This one doesn’t exactly belong on the list. Entergy scheduled it for shutdown in Jan. 2017 but instead it will likely be purchased by a white knight, Exelon, in a transaction brokered by the governor of New York. With respect to NSC, in 2012 FitzPatrick received a Confirmatory Order (CO) after the NRC discovered violations, the majority of which were willful, related to adherence to site radiation protection procedures.
Fort Calhoun
This plant shut down on Oct. 24, 2016. According to the owner, the reason was “market conditions.” It’s hard for a plant to be economically viable when it was shut down for over two years because of scheduled maintenance, flooding, a fire and various safety violations. The plant kept moving down the NRC Action Matrix which meant more inspections and a third-party NSC assessment. A serious cultural issue was how the plant staff’s perception of the Corrective Action Program (CAP) had evolved to view the CAP as a work management system rather than the principal way for the plant to identify and fix its problems. Click on the Fort Calhoun label to pull up our related posts.
Indian Point 2 and 3
Units 2 and 3 are scheduled to shut down in 2020 and 2021, respectively. As the surrounding population grew, the political pressure to shut them down also increased. A long history of technical and regulatory issues did not inspire confidence. In NSC space, they had problems with making incomplete or false statements to the NRC, a cardinal sin for a regulated entity. The plant received a Notice of Violation (NOV) in 2015 for providing information about a licensed operator's medical condition that was not complete and accurate; they received a NOV in 2014 because a chemistry manager falsified test results. Our May 12, 2014 post on the latter event is a reader favorite.
Palisades
This plant had a long history of technical and NSC issues. It is scheduled for shutdown on Oct. 1, 2018. In 2015 Palisades received a NOV because it provided information to the NRC that was not complete and accurate; in 2014 it received a CO because a security manager assigned a person to a role for which he was not qualified; in 2012 it received a CO after an operator left the control room without permission and without performing a turnover to another operator. Click on the Palisades label to pull up our related posts.
Pilgrim
This plant is scheduled for shutdown on May 31, 2019. It worked its way to column 4 of the Action Matrix in Sept. 2015 and is currently undergoing an IP 95003 inspection, including an in-depth evaluation of the plant’s CAP and an independent assessment of the plant’s NSC. In 2013, Pilgrim received a NOV because it provided information to the NRC that was not complete and accurate; in 2005 it received a NOV after an on-duty supervisor was observed sleeping in the control room.
San Onofre 2 and 3
These units ceased operations on Jan. 1, 2012. The proximate cause of death was management incompetence: management opted to replace the old steam generators (S/Gs) with a large, complex design that the vendor had never fabricated before. The new S/Gs were unacceptable in operation when tube leakage occurred due to excessive vibrations. NSC was never anything to write home about either: the plant was plagued for years by incidents, including willful violations, and employees claiming they feared retaliation if they reported or discussed such incidents.
Vermont Yankee
This plant shut down on Dec. 29, 2014 ostensibly for “economic reasons” but it had a vociferous group of critics calling for it to go. The plant evidenced a significant NSC issue in 2009 when plant staff parsed an information request to the point where they made statements that were “incomplete and misleading” to state regulators about tritium leakage from plant piping. Eleven employees, including the VP for operations, were subsequently put on leave or reprimanded. Click on the Vermont Yankee label to pull up our related posts.
Plant with no serious or interesting NSC issues
The following plants have not appeared on our NSC radar in the eight years we’ve been publishing Safetymatters. We have singled out a couple of them for extremely poor management decisions.
Crystal River basically committed suicide when they tried to create a major containment penetration on their own and ended up with a delaminating containment. It ceased operations on Sept. 26, 2009.
Kewaunee shut down on May 7, 2013 for economic reasons, viz., the plant owner apparently believed their initial 8-year PPA would be followed by equal or even higher prices in the electricity market. The owner was wrong.
Rounding out the list, Clinton is scheduled to shut down June 1, 2017; Diablo Canyon 1 and 2 will shut down in 2024 and 2025, respectively; Oyster Creek is scheduled to shut down on June 1, 2019; and Quad Cities 1 and 2 are scheduled to shut down on June 1, 2018 — all for business reasons.
Our Perspective
Bad economics (low natural gas prices, no economies of scale for small units) were the key drivers of these shutdown decisions but NSC issues and management incompetence played important supporting roles. NSC problems provide ammunition to zealous plant critics but, more importantly, also create questions about plant safety and viability in the minds of the larger public.
Entergy’s Pilgrim station has been in Column 4 of the Nuclear Regulatory Commission’s (NRC) Action Matrix since September 2015. Column 4 plants receive more numerous, extensive and intrusive NRC inspections than plants that receive baseline inspections. Pilgrim is in Column 4 primarily because its Corrective Action Program (CAP) is not effective, i.e., the CAP is not permanently fixing significant plant problems. Pilgrim’s latest inspection follows NRC Inspection Procedure (IP) 95003. As part of IP 95003 the NRC will assess the plant’s nuclear safety culture (NSC) to ascertain if a weak NSC is contributing to the plant’s inability or unwillingness to identify, specify, investigate and permanently fix problems.*
Our Perspective
Those are the facts. Now let’s pull on our really tight crankypants. Entergy is in a race with the Tennessee Valley Authority (TVA) to see which fleet operator can get into the most trouble with the NRC over NSC issues. We reviewed Entergy’s NSC problems at its different plants in our April 13, 2016 post. Subsequently, the NRC published its report on NSC issues at Entergy’s Arkansas Nuclear One (ANO) plant, which also was subject to an IP 95003 inspection. We reviewed the ANO inspection report on June 16, 2016. That’s all basically bad news. However, there is one bit of good news: Entergy recently offloaded one of its plants, FitzPatrick, to Exelon, a proven nuclear enterprise with a good track record.
Did we mention that Pilgrim is on the industrial equivalent of Death Row? Entergy has announced its plan to shut down the plant on May 31, 2019.** Local anti-nuclear activists want it shut down immediately.*** Pilgrim will certainly be under increased NRC scrutiny for the rest of its operating life. The agency says “Should there be indications of degrading performance, we will take additional regulatory actions as needed, . . . up to and including a plant shutdown order.”**** As readers know, the Safetymatters founders worked in the commercial nuclear industry and are generally supportive of it. But maybe it’s time to pull the plug at Pilgrim.
"Can't anybody here play this game?" — Casey Stengel (1890-1975)
