ML20059L114

Forwards Requested Info Re Request for Enforcement Discretion Due to Electrical Power Supply Emergency

ML20059L114
Person / Time
Site:	Limerick
Issue date:	01/25/1994
From:	Helwig D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9402030187
Download: ML20059L114 (4)

Text

_

i David it. Halwl3 Vice Presnient -

Umerick Generating Station

~

PECO ENERGY

• = ne c-Umenck Generading Station

' PO Dex 2300

- Sanatoga, PA 19464 0920.

j l

215 3271200 DI 3000 10CFR2,' App. C January 25, 1994 Docket-Nos. 50-352 50-353 License Nos. NPF-39 NPF-85

f U.S.

Nuclear Regulatory Commission Attn: Document Control Msk l

Washington, DC'20555

SUBJECT:

Limerick Generating Station, Units 1 and.2-Requested Information Regarding a' Request for.

j Enforcement Discretion Due to an Electrical Power Supply Emergency

'l l

Attached is information' requested by the NRC Region I

-relative to the potential use of Enforcement Discretion (ED).

for.PECO Energy Company's (PECO's) Limerick Generating Station (LGS).

The request for ED was discussed and approved by the NRC during a teleconference conducted on January 20, 1994, at 1530 hours0.0177 days <br />0.425 hours <br />0.00253 weeks <br />5.82165e-4 months <br />, between'Mr. W.

D.

Lanning of the NRC Region I, Mr. C.

L.

Miller of NRR, and Mr.

D. R.

Helwig of PECO but was not utilized.

The ED was requested to permit not performing the Unit 1 and Unit 2 weekly Main Turbine Stop and Combined Intermediate Valve exercise Surveillance Tests, scheduled for January 21, 1994.

This request was made to minimize the potential for adversely affecting the electrical power grid during~the-ongoing electrical power supply emergency.

On January 22, 1994, the electrical power supply emergency was terminated and the surveillance tests were performed within.the Technical Specification time limits.

The ED_was not required to be implemented, and the NRC Region I was so' informed.-

Very PJ fcurs, DBN:cah Attachment cc:

T.

T.

Martin, Administrator, Region I, USNRC w/att N.

S.

Perry, USNRC Senior Resident Inspector, LGS w/att H.

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U.S. Nuclear Regulatory Commission January 26, 199'4 Document Control Desk Page' '2 -

bcc:

D. M.

Smith -

63C-3 w/ attachment R. W. Boyce -

GML5-1 a

J. A. Muntz SSB3"1 J.

L.

Kantner -

SSB2-4 J.

B.

Cotton -

53A 1 J,

G.

Hufnagel -

SMB3-1 C. A Mengers -

SSB4-3 J..Doering, Jr. -

63C-5 G.

A.

Hunger, Jr. -

62A-1 Secretary, NCB -

63C-7 PA DER BRP' Inspector -

SMB2-4 Commitment Coordinator -

62A-1 Correspondence Release. Point - SMB1-2 h

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-i Attachment

Page 1-of 2 Docket Nos. 50-352 A

50-353 Infornation Regarding A Request for Enforcement Discretion for Limerick Generating Station, Jnits 1 and 2-On January 20, 1994,. Enforcement Discretion (ED) was requested'

{

and granted during a teleconference..The ED would permit'not

. performing the Limerick Generating Station (LGS) Unit 1 and Unit 2 weekly Main Turbine Stop Valve and Combined Intermediate Valve Exercise Surveillance Test (ST) procedures scheduled to be performed on January 21, 1994.

The ED was'not required to.be

-implemented due to improved electricsal power supply. grid 3

conditions.

Below is the basis for the requested for ED.

t Technical Specifications (TS) that-Would he Violated

~

The AC TION of TS Section 3.3.8, Turbine overspeed Protection System, would be violated since. Surveillance. Requirement (SR) 4.3.8.2a would not be satisfied within-the' required time limit and the Tr ACTION'of' isolating the turbine would not be implemented within the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> required time limit.

circumstances Surroundinq the Situation Performance of SR 4.3.8.2a is implemented by ST procedures ST -

001-760-1(2s,." Main Turbine Stop and'CIV Valve Exercise Test,".

Li and is performed weekly.

During performance.'of-the. test, each of the four_-main turbine stop valves and the-six Combined Intermediate Valves.(CIVs) are individually stroked. closed-and 1

re-opened.

Performance of'the test increases the possibility of

- an inadvertent turbine trip and reactor SCRAM.

Additionally,.a reduction in generator output of approximately 10 MWa occurs during the-test.

~

+

The ST procedures were scheduled to be perfoamed on: Friday.

U January 21, 1994.

Due to the extremely cold weather and

.available generation capacity, a Maximum Emergency Generation :and

a. state of emergency for the state of Pennsylvania were declared

'on' January 19, 1994.

This condition was projected to stilliexist a~

when the ST procedures.were to be implemented.

The ED was i

requested to minimize the potential for adversely affecting the

electrical power grid stability.

safety Basis and'Sionificance e

.The-test'results for the-past year's performances'of'ST.

procedures ST-6-001-760-1.(2) were reviewed.

The results showedL no degradation of.the turbine overspeed protection system had 1

t

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e y

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l Attachment Page 2 of 2 Docket Nos. 50-352 3

50-353 occurred.

Additionally, there.were no turbine overspeed system-components' identified to be inoperable.

Therefore,'there is high' confidence that the turbine overspeed/ protection system was operable and that the next scheduled performance of.the ST

.i procedures was not necessary to ensure system reliability.

Not performing the scheduled ST procedures was determined to have very low impact on reliability and.therefore' low safety

~S significance.

Not performing the scheduled ST procedures during-the Maximum Emergency Generation condition reduced the probability of further power grid instability and therefore.

enhanced public safety.

Proposed compansatory Measures _

Since the impact on reliability and safety significance were

. determined to be very low, no compensatory measures-were deemed

- neces sa ry.

.Tusti fication of the Duration of the Noncompliance At the time of the ED request, the end of the electrical power supply emergency was not known.

The ED was requested'to not require performance of the ST procedures during the electric power-supply emergency and to have the tests performed during the i

next normally scheduled time period.

The ST procedures would then be performed within the next week..

' Basis for Conclusion of No Sionificant Safety Hazard or Adverse Environmental Consequences As previously discussed, there was high confidence that'the-turbine overspeed system was operable.and would have been capable of performing its design function if required.

Additionally, the 1

duration of the ED is short, limiting the amount of time between-the turbine overspeed' system testing.

Therefore, the request for ED did-not involve a significant increase in the probability or t

consequences-of an accident, nor created the possibility of a new.-

t or different kind of accident, nor involved a significant i

reduction in the margin of safety, nor would involve adverse.

environmental consequences.

.The above basis was reviewed by the LGS Plant operations Review j

Committee (PORC) on. January.20, 1994 at 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> ~and the PORC agreed with the above' conclusions.

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