ML20249A388
| ML20249A388 | |
| Person / Time | |
|---|---|
| Issue date: | 06/06/1998 |
| From: | Calvo J NRC (Affiliation Not Assigned) |
| To: | Penstone M CANADA |
| References | |
| NUDOCS 9806160382 | |
| Download: ML20249A388 (5) | |
Text
Ccmmercial OpeisdonsI Ontario Hydro 65 Kelftid Street l'
Rexdale, Ontaris M9W 5A3
Dear Mr. Penstone:
i We have completed our review of the North American Electric Reliability Council (NERC) l draft standard entitled, " Policy 10 - Interconnected Operations Services," that was written under your leadership as Interconnected Operations Services implementation Task Force Chairman. Our staff began efforts in January of 1997, to better understand the complexities of electric industry deregulation and its potentialimpact on grid reliability and the availability of offsite power to nuclear power pl6nts in order t' inform and advise NRC o
senior management. We have consulted with the cognirent representatives of Department of Energy, Federal Energy Regulatory Commission, Secretary of Energy Advisory Board Task Force on Electric System Reliability, Nuclear Energy Institute and individual electric utilities on these issues in fact, on February 18,1997, we had the opportunity to speak with Mr. David Nevius and other NERC staff regarding the special concerns of the Nuclear Regulatory Commission (NRC) on bulk power system reliability or grid reliability. In the spirit of the open exchange of ideas and information which we have had with many of the stakeholder in this area we would like to share our comments on the subject document.
As you read our enclosed comments I would urge you and other members of your Task Force to carefully consloor both the unique regulatory constraints and the strategic energy i
resource associated with the operation of nuclear power plants. We offer for your consideration recommendations regarding the role and responsibilities of the Operating Authorities with respect to nuclear power plants which we feel are necessary to assure reliable grid operation. Nuclear power plants have specific and unique design and safe operational requirements that the Operating Authorities and regional reliability coordinator must be aware of and act in a manner to ensure that the grid meets needed reliability
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requirements. If you have any questions on this matter please feel free to contact me or Ronaldo Jenkins of my staff et (301) 415 2985.
Sincerely, Jose A. Calvo, Chief Electrical Engineering Branch I.
Division of Engineering
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Office of Nuclear Reector Regulation i
Enclosure:
O Comments Provided to the interconnected Operations implementation Task Force 9
cc: David R. Nevius, NERC
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Brendan Kirby, P. E., Oak Ridge National Laboratory IO 4, Gus C. Laines, Nuclear Regulatory Commission
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DATE 06/6 /98 06/8/98 06/f/98 06/4/98 i
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- June. 6,1998 Mr. Michael D. Penstone, Section Head Commercial Operations Ontario Hydro 65 Keifield Street Rexdale, Ontario M9W 5A3
Dear Mr. Penstone:
We have completed our review of the North American Electric Reliability Council (NERC) draft standard entitled, " Policy 10 - Interconnected Operations Services," that was written under your leadership as interconnected Operations Services implementation Task Force Chairman. Our staff began efforts in January of 1997, to better understand the complexities of electric industry deregulation and its potential impact on grid reliability and the availability of offsite power to nuclear power plants in order to inform and advise NRC senior management. We have consulted with the cognizant representatives of Department of Energy, Federal Energy Negulatory Comm!ssion, Secretary of Energy Advisory Board Task Force on Electric System Reliability, Nuclear Energy Institute and individual electric utilities on these issues. In fact, en February 18,1997, we had the opportunity to speak with Mr. David Nevius and other NERC staff regarding the special concerns of the Nuclear Regulatory Commission (NRC) on bulk power system reliability or grid reliability. In the.
spirit of the open exchange of ideas and information which we have had with many of the stakeholder in this area we would like to share our comments on the subject document.
- As you read our enclosed comments I would urge you and other members of your Task Force to carefully consider both the unique regulatory constraints and the strategic energy resource associated with the operation of nuclear power plants. We offer for your consideration recommendations regarding the role snd responsibilities of the Operating Authorities with respect to nuclear power plants which we feel are necessary to assure reliable grid operation. Nuclear power plants have specific and unique design and safe operational requirements that the Operating Authorities and regional reliability coordinator must be aware of and act in a manner to ensure that the grid meets needed reliability requirements. if you have any questions on this matter please feel free to contact me or Ronaldo Jenkins of my staff at (301) 415-2985.
Sincerely,.
g.qc i
Jose A. Calvo, Chief E;ectrical Engineering Branch Division of Engineering-
. Office of Nuclear Reactor Regulation 4
Enclosure:
Comments Provided to the Interconnected Operations Services implementation Task Force ec: David R. Nevius,' NERC Brendan Kirby, P. E., Oak Ridge National Laboratory Gus C. Laines, Nuclear Regulatory Commission
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NUCLEAR REdiJdTERYlDMMh3SION 6
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l COMMENTS PROVIDED TO THE INTERCONNECTED OPERATIONS SERVICES l
l_M'* LAMENTATION TASK FORCE DIRECTED TO THE ROLES Alt D RESPONSIBILITIES OF THE OPERATING AUTHORITIES WITH RESPECT TO NUCLEAR POWER PLANT OPERATION INTRODUCTION We acknowledge the Interconnected Operations Services (IOS) Task Force's efforts to organize the implementation of Operating Authorities (OAs) which encompasses independent System Operators (ISOs),105 suppliers, and transmission customere that address reliability requirements. Our primary concern is in assuring the adequacy and reliability of the offsite power supply to nuclear power plants. Safe nuclear plant emergency shutdown requires a source of power capable of maintaining acceptable static and dynamic voltage and frequency levels while supplying varying amounts of both real and reactive power. The preferred source of such safe shutdown power is the offsite electric power system, or regions grid. Since accident sequences initiated by loss of offsite power are important contributors to risk for most plants, the reliability of the offsite electric
- transmission network is important to nuclear power plant safety.
Historically, nuclear plant owners have also frequently been the operators of the host control area and had full responsibility and authority over activities that could impact transmission reliability. This has provided a natural connection between the nuclear plants' offsite power requirements and the transmission system activities necessary to assure the reliability of that supply.
Many features of the ISO concept are attractive and may increase the security of nuclear plant offsite power supply. The large geographic scope, especially when coupled with even broader oversight by regional reliability coordinators, has the potential to reduce the vulnerability of offsite power supply degradation that might result from system disturbances or commercial transactions occurring outside the geographic boundary of the traditional control area operator.
We are concerned, however, that mechanisms must be in place to assure that the ISOs or OAs and regional reliability coordinators are aware of the unique power supply requirements of each nuclear plant. Continued operation of the nuclear plants necessitates that these requirements be formally integrated into the operations and planning of the IOSs/OAs and regional reliability coordinators.
ENCLOSURE
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.We recommend that the Task Force acknowledge the importance of assuring the reliability and adequacy of the offsite power supply to nuclear plants and that nuclear plants often have unique reliability requirements concerning the supply of offsite power, and that these requirements must be addressed by ISOs, regional reliability coordinators, and NERC. While nothing in the Policy 10 standard precludes this, we feel that it is important that it be l
explicitly stated.
BACKGROUND In 1996, two electrical grid disturbances on the Western Grid, one in July and a seco'nd more severe event in August, caused numerous plants to trip, including several nuclear units. Although no nuclear plant lost all offsite power, such events do have the potential to incrosse the dependance on the backup onsite power system and to challenge plant safety systems more than originally intended when the plant was licensed.
The impending deregulation of the electric power industry may impact grid reliability and thus, in turn affect the availability of offsite power to nuclear power plants. Safe nuclear plant operation requires a source of power capable of maintaining voltage and frequency within acceptable limits uniquely defined for each nuclear plant. The preferred power source for safe plant operation is the offelte electric power system, or grid.
Information gathered from NRC staff visits to many of the Nation's load dispatch centers indicates considerabia variability in terms of capabilities and regional vulnerabilities to transient conditions. Overall, we note that it is an exceptional nuclear power plant configuration which is not interdependent with other generating plants in order to maintain its voltage requirements.
A nuclear plant may develop detailed protocols with their local ISO /OAs However,if that nuclear plant is located near the boundary between two or more ISOs/OAs then a broader recognition of nuclear plant operating criteria must be established. A regional reliability i
coordinator who can provide control over severalISOs/OAs must be in place to ensure reliability of the grid for nuclear plants. A case study of NERC disturbance No.10 in 1997, shows how important this concept can become. This disturbance came very close to resulting in three regions of NERC separating and going into independent islanded operation on June 11,1997. Had this avant evolved fully it might have resulted in a large scale blackout that could have impacted potentially some 12 nuclear plants in 7 states.
CALIFORNIA 150 The following key aspects of the relationships between the California ISO and resident nuclear power plants are reflected in their ISO Tariff and Transmission Control Agreement:
i Recognition of nuclear plant operating criteria established under NRC licenses.
e Priority to restoring offsite power to nuclear power plants as specified under design-basis and licensing requirements.
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Pr:mulgtti:n tnd maintenance of ISO cperating proc:dures to maintain vcitage and fr quency r quirem:nts at nuclear power plants.
We consider the California ISO arrangements with respect to its support of the safety requirements for the state's nuclear power plants to be an appropriate model going forward under deregulation. We recommend that any future ISO /OAs arrangement support the integrated planning and implementation of energy dispatch schemes which maintain the design basis requirements for the offsite power (i.e., highly rollable) for all nuclear power plants.
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