EXHIBIT NO. 99-1
United States
NUCLEAR REGULATORY COMMISSION
REGION 1
475 Allendale Road
King of Prussia, Pennsylvania 19406-1415
September 30, 1999
Mr. John H. Mueller
Chief Nuclear Officer
Niagara Mohawk Power Corporation
Nine Mile Point Nuclear Station
Operations Building, 2nd Floor
P.O. Box 63
Lycoming, NY 13093
SUBJECT: MID-CYCLE PLANT PERFORMANCE REVIEW - NINE MILE POINT
NUCLEAR STATION
Dear Mr. Mueller:
On September 16, 1999, the NRC staff completed the mid-cycle Plant Performance
Review (PPR) of your Nine Mile Point Nuclear Station. The staff conducted
these reviews for all operating nuclear power plants to integrate performance
information and to plan for inspection activities at your facility over the
next six months. Normally, the focus of the mid-cycle PPR would be limited to
identifying changes in performance over the last six months, and to allocate
inspection resources accordingly. However, since we plan to conduct a public
meeting to discuss performance following this review, we also have included
assessment results from the review process in this letter. At the public
meeting, we will discuss performance insights from both this letter and our
April 9, 1999 letter which forwarded the results of the last full PPR.
Four automatic reactor shutdowns (scrams) occurred since the full PPR. Unit 1
completed its Cycle 15 refueling outage in June 1999 and operated at full power
until July 23, when the unit scrammed while performing post-maintenance testing
on the turbine control mechanical pressure regulator. On August 1, during plant
start-up, the unit scrammed because of electronic noise on several intermediate
range neutron monitors. Following repairs, the unit was returned to service and
remained at full power through the end of this period. Unit 2 scrammed on
April 24 due to a failure of a relay in the generator protection circuit, and
again on June 24 due to a failure in the master feedwater control circuit. Both
of these scrams involved coincident equipment malfunctions which complicated
plant shutdown and recovery efforts. Unit 2 was briefly returned to power
following the June 24 scram and then shut down on July 3 to troubleshoot reactor
core isolation cooling (RCIC) system problems. Following repairs, the unit was
returned to power operation on July 23, 1999, and remained at full power through
the end of the period.
During the full PPR assessment, we noted that operator control of plant
evolutions was safe and conservative. Human performance and work control were
improving, but problems in these areas required continued management attention.
Since the full PPR, operator performance remained safe and conservative.
However, we observed additional performance problems in several areas. A number
of longstanding equipment reliability and material condition problems challenged
plant operations. While operator response to these challenges was adequate,
some operator performance deficiencies were noted. In addition, shortcomings in
maintenance procedures, planning and work control, and the implementation of
engineering support require your continued attention. A number of these
problems were indicative of weaknesses in management oversight and the
corrective action program. Plant support functions in the areas of radiological
controls, chemistry, security, and emergency preparedness continued to be
effective.
Major plant evolutions were effectively managed and operator performance during
routine evolutions and plant transients was safe and conservative. However, the
equipment performance problems experienced during recent plant transients
challenged the operators and exposed weaknesses in the areas of teamwork,
communications, and procedure usage. The limited scope of post-trip reviews and
human performance evaluations delayed thorough identification of these
weaknesses.
Some of the recent operator challenges caused by equipment degradation resulted
from deficiencies in the maintenance area. Specifically, deficiencies in
maintenance procedures, work planning and scheduling, and work control reduced
the overall effectiveness of the maintenance program. In addition, there were
instances where poor communications and maintenance work practices adversely
impacted equipment performance, most notably with maintenance performed to
address containment isolation check valve position indication problems. The
station performed several effective self-assessments which identified these
maintenance program shortcomings. However, corrective actions, to date, have
yet to yield significant results.
Engineering performance was mixed since the full PPR. Technical evaluations
and oversight of the Unit 1 core shroud repairs were well performed. However,
weaknesses in engineering support led to repeat failures and reduced reliability
of some important plant systems. The most notable example was the poorly
coordinated engineering effort associated with RCIC system maintenance.
Additional attention is warranted to address several other deficiencies in the
engineering area, such as, incomplete modification packages, untimely
modification field installations, and discrepancies in the Inservice Inspection
and Inservice Testing programs.
As reflected in the results of the full PPR, radiation protection and
radioactive waste/material management programs were well implemented. Security
and safeguards programs were executed in a manner that protected public health
and safety. Emergency preparedness program requirements were effectively
exercised during a drill and during an actual fire at an adjacent nuclear
facility. Housekeeping practices continued to be appropriate and the
corrective action program was effectively implemented in the plant support
area.
As noted above, performance declined in several areas. Accordingly, we plan to
conduct additional inspections beyond the core inspection program over the next
six months to better understand the causes contributing to the decline.
Enclosure 1 contains a historical listing of plant issues, referred to as the
Plant Issues Matrix (PIM), that were considered during this PPR process to
arrive at an integrated review of licensee performance trends. The PIM
includes items summarized from inspection reports or other docketed
correspondence between the NRC and Nine Mile Point Units 1 & 2 from October 1,
1998 to September 30, 1999. As noted above, greater emphasis was placed on
those issues identified in the past six months during this performance review.
The NRC does not attempt to document all aspects of licensee programs and
performance that may be functioning appropriately. Rather, the NRC only
documents issues that the NRC believes warrant management attention or
represent noteworthy aspects of performance.
This letter advises you of our plans for future inspection activities at your
facility so that you will have an opportunity to prepare for these inspections.
It will also allow you to provide us with feedback on any planned inspections
which may conflict with plant activities. Enclosure 2 details our inspection
plan through March 2000 to coincide with the scheduled implementation of the
revised reactor oversight process in April 2000. The rationale or basis for
each inspection outside the core inspection program is discussed above so that
you are aware of the reason for emphasis in these program areas. Resident
inspections are not listed due to their ongoing and continuous nature.
If circumstances arise which cause us to change this inspection plan, we will
contact you to discuss the change as soon as possible. Please contact Michele
G. Evans at 610-337-5224 with any questions.
Sincerely,
Original Signed by:
Richard V. Crlenjak, Deputy Director
Division of Reactor Projects
Docket Nos. 50-220, 50-410
License Nos. DPR-63, NPF-69
Enclosures:
1. Plant Issues Matrix
2. Inspection Plan