ML16315A301

Region I Response Letter to M. Lampert 10-04-16 Email

ML16315A301
Person / Time
Site:	Pilgrim
Issue date:	11/09/2016
From:	Ray Lorson Division of Reactor Safety I
To:	Lampert M Pilgrim Watch
Lorson R
References
Download: ML16315A301 (3)

Text

M. Lampert UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PA 19406-2713 November 9, 2016 Ms. Mary Lampert Pilgrim Watch 148 Washington Street Duxbury, MA 02332

Dear Ms. Lampert:

As the designated manager for the upcoming team inspection at Pilgrim Station, I am responding to your October 4, 2016, and October 26, 2016, emails to Messrs. William Dean and Daniel Dorman regarding that inspection. The emails included the following requests: 1) that the inspection focus on some recent events that were cited in your letter in order to identify the underlying problems that led to these events and to ensure that inspection activities are not limited to a review of condition reports; 2) that the inspection team assess worker attitiudes by asking specific questions regarding their coworkers potential reactions to various situations; 3) that we provide assurance that the upcoming inspection takes a hard look at Pilgrims safety culture with the results reflected in our final evaluation; and, 4) that an independent inspector, not bound by a confidentiality agreement, accompany the NRC team.

First, let me assure you that we are fully commited to performing this inspection with the highest standards and quality. To that end, we have assembled a capable, diverse, and independent team of NRC inspectors from across the agency and will ensure that they have all of the necessary tools and resources. The team is experienced, knowledegeable, and dedicated, and I am confident in their ability to successfully complete this inspection.

As you may be aware, our baseline inspection program examines the licensees response to events on an ongoing basis including the events cited in your letter. The purpose of the upcoming inspection is to examine more deeply the licensees programs to independently assess the root causes of the declining performance that resulted in Pilgrim being placed in Column 4 of the NRC Action Matrix for a Repetitive Degraded Cornerstone, to assess the adequacy of the licensees recovery plan to achieve sustained performance improvement, and to determine what further regulatory actions may be warranted. Our sample selections are intended to provide a sound basis for in-depth assessment of past problems and the licensees actions to improve future performance in diverse areas such as human performance, equipment reliability, and procedural adequacy. The teams activities may examine some of the events you listed, but will extend well beyond looking at condition reports and will include activities such as in-plant observations, personnel interviews, and document reviews.

With respect to assessing workers attitudes and the sites safety culture, we have qualifed experts on the team specifically dedicated to this task. They will be following the process outlined in NRC Inspection Procedure 95003.02, which can be found at http://www.nrc.gov/docs/ML1409/ML14090A072.pdf. As part of the review, they will examine other formal culture assessments, including assessments performed by experts external to and

M. Lampert independent from Entergy. In addition, our inspectors in this area will lead focus group discussions, observe activities, and interview plant workers. We will have full access to plant workers to ask questions or discuss items of interest.

Finally, we share your interest in ensuring the independence of this inspection team. In particular, a majority of the inspectors on this team are from outside of Region I and have not had any recent experience with the oversight of Pilgrim. We also have a memorandum of understanding with the Commonwealth of Massasschusetts that allows the State to provide a representative to observe this effort. We will continue to frequently communicate throughout the inspection to ensure that the state observer is aware of our plans and activities. Its important to note that the state observer is welcome to communicate any insights or observations to the team leader throughout the inspection. However, prior to issuance of the final report, the information is pre-decisional and we ask that state observers, like our own inspectors, refrain from discussing inspection details. Once the final report is issued, the state observer is free to disclose any issue or insight developed during the inspection I would like to reiterate that we share your goal that this inspection be of the highest quality and provide a thorough, independent examination of the licensees performance and improvement plans. I trust that our plans and approach for conducting this inspection satisfies the overall objectives for the issues that you raised. However, if you have additional questions or concerns regarding this issue, please feel free to contact me at 610-337-5128.

Sincerely,

/RA/

Raymond K. Lorson, Director Division of Reactor Safety

ML16315A301 SUNSI Review Non-Sensitive Publicly Available Sensitive Non-Publicly Available OFFICE RI/DRP RI/DRP RI/DRS NAME LCline ABurritt RLorson DATE 11/08/16 11/08/16 11/9/16