Nuclear Regulatory Commission Column 4 Recovery

Entergy Corporation & Pilgrim Nuclear Power Station

Case Study

Defined Need

Entergy Corporation engaged Marathon Consulting Group (MCG) to lead a project to prepare the station for a successful NRC 95003 inspection. Over the course of 2013 to 2015, Pilgrim suffered a series of equipment failures resulting in multiple notices of violations. Pilgrim also failed several inspections for individual issues in that time span. It was very important to accurately estimate the cost of the project, as that estimate was integral to the decision of continuing to operate or cease station operations.

Regulatory recoveries are expensive propositions. Performing the diagnostic portion of the effort requires many thousands of hours of assessment, multiple root and apparent cause analyses, and implementation of an improvement plan, in addition to any technical/equipment repairs or design changes. Column 4 recoveries can cost a site and corporation upwards of $100 million


  • MCG led the senior Entergy and station management teams to lay out a complete but frugal project plan.
  • MCG developed an innovative tool for performing Comparative Analysis to previous column 4 recoveries.
  • MCG used lessons learned to streamline the entire process.
  • MCG developed a significant event and regulatory timeline/storyline earlier in the process, to better illustrate performance and align the plant staff and team.
  • MCG built the Project Plan, Work Breakdown Structure, Schedule backbone, and financial tracking tools.
  • MCG recommended and screened vendors for assessment work with Pilgrim
  • MCG built and issued the weekly project progress report and recovery performance indicators.
  • MCG briefed the staff on the 95003 inspection module and the Marathon/Entergy procedures used to implement the process.
  • MCG led each of the phases of the project.
  • MCG guided the station through the inspection phase.
  • MCG staffed the critical recovery positions post inspection for subject matter experts and mentors supporting performance improvement and behavior change.


Following completion of the action, numerous improvements resulted:

  • The Pilgrim overall recovery was conducted for half the cost of the previous recovery (less that $50 million).
  • The assessment and cause analysis phases were accomplished within 0.5% of the original estimates.
  • Although the 95003 inspection was slightly abbreviated, the reduction in cost using the comparative analysis technique significantly reduced assessment efforts (5,000-7,000 assessment hours saved) and ensured a thorough review of overall station performance.
  • Pilgrim is well on track to exit Column 4 at the end of 2018, as expected.
  • The results of mentoring and use of subject matter experts resulted in significant improvements in both technical performance but more importantly the improvement in behaviors supporting a strong nuclear safety culture. These changes have been recognized by corporate oversight, the Institute of Nuclear Power Operations (INPO) and the regulator.
  • During the recovery Pilgrim moved from INPO 3 to INPO 2 and was removed from increased INPO oversight (Policy Note 14).