ML20203H505
| ML20203H505 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 12/12/1997 |
| From: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| To: | Collins S NRC (Affiliation Not Assigned) |
| Shared Package | |
| ML20203H482 | List: |
| References | |
| NUDOCS 9803030248 | |
| Download: ML20203H505 (13) | |
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December 12,1997 Samuel Collins l Director Office of Nuclear Reactor Regulation Nuclear Rc;;ulatory Commission 11555 Rockville Pike Rockville, Af arylano 20812 Re: Docket Numbers 50 206,50 361 and 50 362 Resolution Of Restructuring Issues . San Onofre Nuclear Generating ,
Station Units 1,2, and 3
Dear hir. Collins:
This letter provides an updato to my letter of November 12,1996 to hir. Frank J. hiiraglia, Jr., regarding restructuring issues as they affect the San Onofre Nuclear Generating Station (SONGS). In particular, my November 12 letter concluded that creation and operation of the ISO will not alter the technical bases under which Edison roccived its operating licenses for the SONGS units and therefore does not require NRC consent. On October 30,1997, the Federal Energy .
Regulatory Commission (FERC) granted a request to transfer Operational Control of the California utilities' transmission facilities to the Independent System Operator (ISO)in compliance with California Public Utilities Commission (CPUC) orders and state law codified in Assembly Bill 1890. Although the conclusion of my November 12 letter is unchanged, this ictter provides an update in light of the resolution by Ae FERC October 30 order ofissues surrounding the creation and operational authority of the ISO.
The FERC October 30 order approved the ISO's Transmission Control Agreement (TCA) and tariff with no modifications to sections concerning NBC operating licenses or public health and safety. Under the TCA, Edison will continue to own and maintain its present transmission system. However, Edison will transfer Operational Control ofits transmission system to the ISO in accordance with the TCA and the ISO tarifT. The TCA defines " Operational Control" as The rignts of the ISO under the (TCA) and the ISO tarifT to direct participating (Transmission Owners) how to operate their transmiesion lines and facilities and other I 9003030240 900217 Ps)R ADOCK 05000206 P PDR P.O. Box 800 2244 Walnut Grove Ave. Rosemead, California 91770 (626) 302 1695 Fax (626) 302-4737
S:ma:1 Collins Director Pag) 2 December 12,1997 electric plant affecting the reliability of those lines and facilities for the purpose of affording comparable non discriminatory transmission access and meeting Applicable Reliability Criteria.
With the assumption of Operational Control on January 1,1998, the ISO becomes exclush'ely responsible to procure resources necessary to s tisfy Applicable Reliability Criteria.
Most importantly, the TCA provides, in Section 5.1.3, Duty of Caro, that The ISO shall have the exclusive right and responsibility to exercise Operational Control over the ISO Controlled Grid, subject to and in accordance with Applicable Reliability Criteria and the operating criteria
. established by the NRC operating licenses for nuclear generating units as provided in Appendix E pursuant to Section 6.4.2.
In my November 12 letter, Edison indicated that:
In preparation for the transfer of control of the transmission system to the ISO, Edison will ensure that the essential plant's specific requirements for the off site transmission system at SONGS are firmly established between Edison and the ISO, To this end, Edison is preparing a definition of the specific technical and regulatory requirements that SONGS has for the off site power system, including (1) capacity to support the anticipated operational occurrences and design basis accident mitigation, (2) requirements for line availability, for voltage, frequency, and notification tu the SONGS control room when specific impaired or degraded grid conditions exist, (3) performance of system stability studies, and (4) the maintenance of off site power supply operability requirements, The specific technical and regulatory requirements for SONGS are defined in the TCA at Sections 5.1.3 and in Appendix E,l/ which contains "the operating criteria established by the NRC operating licenses for nuclear generating units." The FERC l' See Attachment 1 to this letter.
S:muel Collins
- Dircetor Psp 3 '
Decemher 12,1997 October 30 order accepted the definition of the technical and ren ,alatory ,
requirements for SONGS in the TCA. As a result, as I said in my November 12 letter, "our requirements for the off site transmission system will continue to be met " We will continue to meet this commitment and operate within our approved licensing basis.
Although the creation ol'the ISO and issuance of the FERC October 30 Order does not change the facility or procedures as described in our Final Safety
- Analysis Report (FSAR), our requirements for blackstart of the offsite power grid i
will be met using different generating facilities than had been used in the past.
Neither the FSAR nor any other licensing basis documents specify the generating
, facilities used for blackstart capability. Therefore, the use of dif*erent blackstart ,
j facilities will not result in a change to the plant licensing basis.
Edison will update its procedures with respect to recovery of the offsite
- power grid following a loss of offrite power.10 CFR 50.63 establishes the !
- requirements for withstanding and recovery from station blackout eventa. In "
i accordance with Edison's commitments to the NRC, procedures are presently in i
, place for recovery of power in accordance with Section 4.2.2 of NUMARC 87 00, Guidelines and Technical Bases for NUMAltC Initiatives Addressing Station . _
Blackout at Light Water Reactors, and Section C 2 of NRC Regulatory Guide 1.155, Station Blackout. Currently these provisions nN incorporated in:(1) San Onofre Emergency Operating Instruction SO2312 8, Station Blackout,(2) Edison System Operating Bulletin No.1 A (Bulletin No.1-A), and (3) San Diego Gas & Electric Company's (SDG&E) Control Procedure No.1150 (Procedure No.1150).
Edison's Bulletin No.1 A establishes that the first priority for available power to restart the electrical system will be SONGS emergency auxiliary
, power associated with reactor safety. The power sources for SONGS restart -
identified in Edison's Bulletin No.1 A are: (1) system interconnections, (2) gas turbine peaking units on Edison's system, which have blackstart capability, _ _
(3) hydro units at Big Creek and Hoover Dam, which have blackstart c:.pability, 4 and (4) isolated fossil fired unita that remain in operation. Bulletin No.1 A j requires use of the blackstart unita for SONGS in the event they are needed.
- SDG&E's Procedure No.1150 establishes that SDG&E will egard f restoration of power to SONGS as the " highest priority"in its system restoration procedures. The SDG&E power sources for SONGS restart are identified in Procedure No.1150 as gas turbine peaking units. These power sources would be provided in addition to any available Edison power sources.
Because (1) Edison is divesting its oil and gas powered generating facilities, and (2) the ISO has not currently designated Edison's gas turbine peaking
Samuel Collins Director Page 4 December 12,1997 w units as must run, these units can no longer be available to provide bl e kstari b.i' capability, unless the ISO elects to obtain this capability through contact with the new owners. After January 1,1998, following creation of the ISO and divestiture of Edison's gas turbine peakin units, the ISO has indicated it will rely on SDG&E's local gas turbine peaking taats, which have been designated must run, to provide for nearby blackstart operation at SONGS. In accordance with tha provisions of the TCA, the ISO will continue to assign first priority to restoration of power to SONGS for a loss of power that affects the San Onofre switchyard. The ISO will enterinto contracts with awners of specific genciating facilities for blackstart capability.
Specifically, contracts will be in place for, amongst others, Edison's hydroelect:ic
(
units at Big Creek and Hoover Dam and SDG&E's gas turbine peaking units that (
o have been designated must run by the ISO.
Prior to January 1,1998, Edison will modify Bulletin No.1 A and other appropriate procedures, and SDG&E will modify Procedure No.1150 to reflect this change. ISO procedures will parallel the requirements of Bulletin No.1, 3 A and Procedure No.1150, as modified. Since SONGS will maintain multiple sources, including nearby sources, for restoring power in the event of a station blackout, Edison will continue to meet our commitments to the guidelines of NUMARC 87 00 and NRC Regulatory Guide 1.155. Edison will continue to monitor the blackstart capability maintai ied by the ISO to assure that it is meeting its commitment to provide suflicient bhtkstart capability.
Reintedly,in response to insights gained from the IPEEE, SONGS has recently installed additional capability to cope with a station blackout event at one unit. The ability to crrn (;:. the diesel generators from one SONGS unit to the other unit has been iestelM. The capability effectively means that any one of the 4 diesel generators onsite can support the shutdown loads at both units. The cross-tie modification is currently being reviewed by the NRC staff.
In conclusion, the creation of the ISO and issuance of the FERC October 30 Oroer do not change the SONGS licensing basis. We will continue to meet applicable operability requirements and we will continue to meet our commitments for restorat' m of off site power to SONGS. We will continue to i
Samuel 0311 ins Director Pege5 December 12,1997-i monitor blackstart capability insofar as SONGS off site power is concerned. Future notification of developments will be provided in accordance with NRC regulations and Nuclear Energy Institute commitment change guidance.
I Sincerely,
/ -
Harold B. Ray CASsbw:LW9732ho.174 cc: Jeffrey Tranen, California Independent System Operator l Terry Winters, California Independent System Operator Kellin Fluckiger, California Independent System Operator l'
1 i
ATTACHAENT 1 Appendix E To Transmission Control Agreement t sm
Trcnsmissi:n Centrcl Agreement Original Sheet No,193 SONGS 2&3 REQUIREMENTS FOR OFFSITE POWER SUPPLY OPERABILITY a
, OVERVIEW The preferred source of electrical power for SONGS electrical loads (safety-related and nonsafety-related) is the ogsisepowr supply or 230 kV grid. The offsite power supply is sometimes referred to as thepreferredpawr supply in the regulatory documents. ,
The basic requirement for the offsite power supply is that it provides su,(ficicar capacity a capability to safely shut down the reactor and to mitigate certain specified accident scenario When this condition is met, the offsite power supply is considered Operable with respect SONGS Operating License and Technical Specifications, it i a maa y condition of the Operating License that the offsite power supply be Operable at all times. If the offsite p for an offline unit, to suspend activities as required by the S Technical Specifications. The offsite power system is considered Inoperable ifit is deg the point that it does not have the capabihty to supply electrical loads needed to safely the reactor and to mitigate the effects of an accident at SONGS. This lew.1 of degradatio caused by an die offsite power system, or any condition which renders the offsite power unavailable to safely shutdown the units or to supply emergency electrical loads. ,
In specific terms, the offsite power supply voltage (at the SONGS switchyard) must the range of 218 kV to 238 kV under all normal and plant accident (i.e emergency sh trip) conditions. Otherwise the offsite power supply is considered Inoperable Since acc impair the operability of the offsite power system. Therefo
( (i.e., the urd. *eakers open), the SONGS switchyard voltage must recover to and be
( at or above 218 kV wrthm 2.5 seconds following the trip. If this condition cannot be met, th the offsite power supply is considered Inoperable, and action must be taken to shut do p
operating SONGS unit (s). Even though these requiremems apply at all times, this conditi
- pnmarily of concern when one SONGS unit is online and the other unit offline. If both SON units are online and one unit trips (due to an accident or otherwise), the non-tripped u provide local vohage support to the SONGS switchyard, and 230 kV system voltag '
within the required range in cases where one SONGS unit is online and one unit offlin ,
effsite power supply must be sufficiemly robust to survive 2 aip of the online unit and m
. SONGS voltag: requirements in the post-trip condition. A dual unit trip is not the condition since a plant accident is not postulated sunurtaneous with a dual unit trip.
System Operating procedures and programs shall be in place to ensure that variou I
operating conditions (generating unit outages, line outages, svstem loads, spinnin ,
I Page 1 of 7 I .
Transmissbn C:ntrcl Agreement i Original Sheet No.194 including multiple contingency events, are evaluated ,
e orand understoo potentially Control degraded Room for Operability grid conditions are recosmzed, assessed an determination.
The SONGS switchyard is made up of the SCE switchyard .
ess and th to both the SCE switchyard and the SDG&E switchyard k ~
(
h SPECIFIC REQUIREMENTS Note:
This section identifies the operational requirements wer supply.
for the SONGS These requiremenu are part of the SONGS design basis and licensin these requiressests may render the offsite power supply .
laoperable a ure to meet th us requiring the insmediately coannualcated to SCE and the SONGS Con g determlaation. Changes la the operation of the transmission network thatoo requiremenu require prior approval by SCE.
'S conflict wttb these 4 1.
I Nine transmission lines into the SONGS switchyard ny increase are normally in SCE. (Reference 7)or decrease in the number oflines into the S val of
'SCE. At least two independent ottransmission cation to l between the transmission network (grid) androm times. (References'1, 2, 3, 4, 7, 8)
SONGS SDG&E) switchyard v ce at a!!
2.
With both San Onofre units offline, the SONGS a e of offsite power s providing 152 MW and % MVAR to San Onofre for normal ope down the units dwing accident conditions. (References 9,10) -
3.
218 kV. In the event ofa system distuttance w t
218 kV, including the trip of a SONGS unit, the grid vohage shall recover above within 2.5 seconds. (References 9,10,12,13) o 218 kV or Page 2 of 7
t 1 Transmissicn Control Agrscm:nt Original Sheet No.195
- 4. The following initiating events shall not result in the loss of grid stability or availability:
- a. The loss of a San Onofre Unit (with the other unit already offli .e).
- b. The loss of any generating urit on the SCE and SDG&E grids.
- c. The loss of any major transmission circuit or intertie on the SCE and SDG&E grids
- d. The loss of any large load or block oflos.d (e.g., due to a bus r,ection outage) on the SCE and SDG&E grids.
(References 2,3,4, 8) ,
- 5. The maximum grid voltage at the SONGS switchyard shall be maintained at or below 238 kV (References 10, i1) .
y/
A,
- 6. The normal operating voltage of the SONGS switchyard shall be maintained at 230 kV.
The SONGS switchyard voltage shall not exceed 232 kV unless required to preserve f transmission network integrity. (References 10,11,18)
M 7. Currently, in the event of an outage of any of the following transmission lines with one SONGS unit on-line, one SONGS unit offline, and with the system threshold load .
exceeding the specified MW limit the SONGS requirements for offsite power will not be met. The SONGS Control Room will de :lare the offsite power system inoperable (in anticipation oflosing the second SONGS unit), and the on-line unit will have to be shut down within 12 to 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:
Case Transmission Line Outage Threshold Load (MW) 1 Lugo--Serrano and Mira Loma--Serrano 500 kV Lines 13.600 2 Lugo--Mara lama 2 and 3 500 kV Lines 13.600
- 3 Impenal Val %-Miguel 500 kV Line and 12.600 1
Impenal Valle+Roata 130 kV Line or Palo Verde-Nonh Gila 500 kV Line -
or ,
North Gila-Impenal Valley 500 kV Line 4
Elks-Johanna and Elhs-Sannago 230 kV Lines 11.600 Palo Verde-Devers 500 kV Line 13.600 Note: The threshold load (MW) above is based on the omise unit la operating Modes 1 through 4 06 MW. 48 MVAR) and the omhae unit is operating Mode 106 MW 48 MVAR).
e Page 3 of 7
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W .
Transtnissi:n Centrcl Agreement.
Original Sheet No.196 Systems studies shall be performed and updated based on changing grid conditions (load growth, etc.) to identify critical conditions, such as the five cases above, that could render the offsite power supply Inoperable. The offsite power system is considered inoperable if it is degraded to the point that it does not have the capability to proside electrical support to safe shutdown loads and to mitigate the effects of an accident at SONGS. This level of degradation can be caused by an unstable offsite power system. or any condition which renders the offsite power supply unavailable for safe shutdown and emergency purposes.
,~
Procedures and programs shall be in effect to ensure that the SONGS Control Room is immediately noti 5ed of such conditions. Grid conditions that are more severe with respect to SONGS switchyard voltage, or are otherwise unanalyzed, render the offsite power
- supply Inoperable. The SONGS Control Room shall be immediately notified of such
^
conditions. Auditable records ofcurrent system studies shall be made available to SCE as 3
needed to demonstrate compliance with regulatory requirements. Study results, including revisions and updates, shall be formally transmitted to SCE, Study results and conclusions 1.
shall be asesM at least annually and updated, if needed, base'd on changing grid f'
, conditions. Results of the annual assessments shall bc' formally transmitted to SCE.
(References 1,2,19,21) '
7 System studies sha!! consider the interconnections between SCE, SDG&E, and other utilities in the Westem Systems Coordinating Council (WSCC) region. (Reference 7) 8.
In the event ofloss of the SONGS offsite power supply:
Note: SONGS 2 and 3 are required by NRC regulanoes to be able to safely cope with a loss ef all l ( AC power (Stanos Blackout) for a maximum of four hours. The four hour coping duration is based i
on the apan=*= that at least one source of AC power (offsite trans-n== line or ossite diesel generator) will be restored to the blacked out unit withis the four hours to ensure the progfer functaceing of systems required for plast safety.
j a. Highest possible priority shall be given to restoring power to the SONGS swite.hyard.
i
- b. Should incoming lines to the S.ONGS cvit:hyard be damaged, highest priority shall be j
assigned to repair and restoration of at least one line imo the SONGS switchyard.
- c. Repair crews engagmg in power restoration activities for SONGS shall be given the highest priority for manpower, equipment, and materials.
- d. Formal programs and procedures shall be in place to effect items a, b, and c above. '
(References 14, 15,16, 17,26, 27)
Page 4 of 7
Tren:missiten Centrcl Agrocment
[
- y. Original Sheet No.197
- 9. Grid frequency shall be maintained at 60 Hertz (nominal). A trip ofone SONGS unit shall not cause the grid frequency to dip below 59.7 Henz. Tne following operations are 6 initiated for low system toquency conditions:
'V -
- a. At 59.3 Hertz, SCE system load shedding program is initia'ted.
NY b. At 58.2 Her:z. automatic separation of the SCE symem from the SDO&E system is initiated at the SONGS switchyard when either San Onofre unit is pre selected'to separate with the SDG&E system. .-
y
- c. At $8.0 Henz, manual separation of the SCE system from the SDG&E system is 4 initiated at the SONGS switchyard when either San Onofre unit is pre-selected to u separate with the SDG&E system.
y d. At 57.0 Henz, automatic separation of the SCE system from the SDG&E system is y.
3 initiated at the SONGS switchyard when no San Onofre unit is seixted to separate 2
with the SDG&E system.
i e 4
- e. At 56.8 Henz, manual separation of the SCE system from the SDG&E system in Y ~
inmated at the SONGS switchyard when no San Onofre unit is selected to separate j with the SDG&E system.
dIt 'Neee: The ebeve separation seapoints are provided forinforumanen esty. SCE and SD y
~, curvumely reviewing the $7 Bz separsese serpeist. This serpeest will likely be increased to ,
essere that syneen separaties occurs prior to a trip of the seclear mait(s), which also occurs at appresumetely $7 Es. SCE willintene the ISO st any chasses to the system separaties seapoias. ,
(References 7,20)
- 10. .
SCE and SDG&E Bulk Power Transmission System Reliability Criteria as described in the SONGS 2&3 Updated Final Safety Analysis Report shall be maintained. It is recognized that the SCE and SDG&E Bulk Power Transmission System Reliability Criteria as described in the SONGS 2&3 Updated Final Safety Analysis Repon may. be revised from time to time. In the event the reliabihty criteria art. revised, a system assessment and/or .
study (as described under specification 7) shall be performed to deternune if the revised ,
reliabihty entaria adversely impact grid reliability and availability as de6ned in this Wah Results of the assessment and/or study together with a copy of the revised rehabihty criteria shall be provided to SCE. Changes in grid operation based on the revised enteria and associated studies shall not be implemented without prior approval of '
! SCE. (Raference 7) 4 l 1.
- SCE and SDG&E transmission lines shall be patrolled annually t,o ensure that the physical and electrical integnty of transmission system components is maintamed (References 7, 22) i Page 5 of 7
)
N-Transmission Contr:I Agre mont
.. y .
Original bheet No.198
^ ,;; 12. 1.ine insulators, pole hardware terminals, and tower hardware terminals within the first C three rniles from the San Onofre switchyard shall be inspected annually and washed at least two times a year to reduce line outages that may result from flashovers due to possible y accumulated contamination. (References 7,22) j '
L 13.
Preventive maintenance, testing and calibration ofSONGS switchyard circuit breakers and protective relays shall be performed as follows:
@ SCE: 230 kV circuit breakers are overhauled every 300 normal operations or 25 kickouts, t Response time / trip testing is performed annually. Transmission line relays are tested A .
, biannually. (References 7,24,25) u ,
L.ji SDG&E: 230 kV circuit breakers are overhauled every five years. Trip testing is '
performed annually. Transmission line relays are tested biannually. (Reference 7) ,
.p 14 Preventive maintenance and testing of SONGS switchyard batteries shall be performed per i.f .IEEE 450-1972.
Preventive maintenance and testing of SONGS switchyard battery K chargers and DC system components shall be performed annually. (Reference 7,23)
- i .
h
- 15. Updates to applicable portions of Section 8.0, Electric Power of the SONGS 2 & 3
- q. ' Updated Final Safety Analysis Report (UFSAR) shall be provided annually. These updates will be used by SCE to prepare a UFSAR change submittal to the NRC. SONGS is required by 10CFR50.71(c) to submit to the NRC periodic updates to the UFSAR.
REFERENCES
!) SONGS 2&3 Operaung License and Technical Speci6 cations. Secnon 3.8, Electrical Pont Sptems
- 2) 10CFR50 AWN A, General Design Criterion 17 (GDC 17), Electrical Power Systems
, 3) .NUREG 75/087. Standard Review Plan Revision 1, Secnon 8.2, Offsite Power System 1
- 4) NUREG 0800, Standard Revww Plan Revmon 2, Secnon 8.2, Offsite Power System
- 5) NUREG 0800. Standard Revie v Plan Revision 2, Branch Technical Posinon ICSB-11 (PSB), Stabil of Offsite Power Systems .
- 6) NUREG 0712, SONGS 2&3 Safety Evaluation Report, Secuan 8.0 Electne Power Sptems
, 7) SONGS 2 & 3 Updated Final Safety Analysis Report. Secuan 8.0, Elecmc Power
- 8) ANSI /IEEE Std. 765 1983 Preferred Power Supply for Nuclear Power Cs.i-s Stanons
. Page 6 of 7
)
- V 4
Transmission Control Agreement Original Sheet No.199
, 10) SONGS Desip Calculation E4C 090. Auxiliary System Voltage Regulacon
. 11) SONGS Desip Calculanon E4C-092, Short Circuit Stu&cs N.
,I , .
4, 14) 90051. SONGS Station Blackout Analyses 4
5..
9, 15) NUM RC 87 00 Guidelines and Technical Bases for NUMARC hunatives Addressing Station
]p Blackout at Light Water Reactors a; -
- 16) Letter from M. O. Medford (SCE) to the Document Control Desk (NRC), datd April 17.19891
.jM
Subject:
"Raponse to 10 CFR 50.63, ' Loss of all Alternanng Current Pmwr.' San Onofre Nuclear
% Generanns Station Units I,2 and 3" E
e
- 17) Letter from F. R. Nandy (SCE) to the N =-- i Control Desk (NRC), dated May 1,1990.
Subject:
" Supplemental Response to 10 CFR 50.63. ' Loss of All Ahernatag Current Power ' Station l
l Blackout (TAC No. 68599/600), San Onofre Nuclear Generatag Station Units 1,2. and 3"
[
- 18) System Operatag Bulletin 17 Appendix. System Voltage Control for San Onofre Nuclear Generaung l Stanon (Rev. May 1,1993)
- 20) System Operatag Bullenn 113, San Onofre 220 kV System Separanen (Rev. April 15. 1995)
- 21) Regulatory Guide 1.93, Availability of Electric Power Sources
- 22) SCE Division Order 40.35, Transnussion Line Rouune Patrol. taw _ Scheduling, and Record
- Keeping (Rev.10/87) i .
J ,23) SCE Division Order 60.20, Storage Banenes (Rev. 3/82) '
- 24) SCE Division Order 50.10, Predienve Mmbaer Circuit Breakers and Switches (Rev. 6/96)
- 25) SCE Divunen Order 50.20, Relay and Equipment Tests (Rev. 3/94)
- 26) Symmm Operates Bullenn I-A, Thermal Stanon Start-up and Power System Restorazion (Rev. August .
1.1995)
- 27) System Operadng BuDenn 254, E.wwy Orders--Tsn Onofre Nuclear C-.iing Station 220 kV.
(Rev. March 18.1996)
Page 7 of 7 i
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