Letter Sequence Request |
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MONTHYEARML0335602182003-12-16016 December 2003
Submittal of Application for Order and Conforming Administrative Amendments for License Transfer
Project stage: Request
ML0400801202004-01-15015 January 2004
Notice of Consideration of Approval of Transfer of Facility Operating License and Conforming Amendment, and Opportunity for a Hearing
Project stage: Other
ML0402102022004-02-0505 February 2004
R. E. Ginna Nuclear Power Plant, Withholding from Public Disclosure, Confidential Addendum Which Contains Sensitive Financial Information Concerning Projected Revenues & Operating Expenses of Constellation Generation Group, LLC
Project stage: Other
ML0406308552004-02-27027 February 2004
R. E. Ginna Nuclear Power Plant, Supplemental Information to Support Application for Order and Conforming Administrative Amendments for License Transfer
Project stage: Request
ML0409301942004-03-26026 March 2004
R. E. Ginna - Supplemental Information to the 12/16/03 License Transfer Application
Project stage: Request
ML0408209962004-04-14014 April 2004
R. E. Ginna Nuclear Power Plant, Request for Withholding Information, Rochester Gas and Electric Corporation and Constellation Generation Group, LLC
Project stage: Withholding Request Acceptance
ML0412800872004-04-30030 April 2004
R. E. Ginna Nuclear Power Plant, License Transfer Supplement
Project stage: Request
ML0412804172004-04-30030 April 2004
Supplemental Information to Support the Application for Order and Conforming Administrative Amendments for License Transfer
Project stage: Request
ML0413305402004-05-28028 May 2004
FRN: General Notice R.E. Ginna Nuclear Power Plant- Order Approving Transfer of License from Rochester Gas and Electric Corporation to R.E. Ginna Nuclear Power Plant, LLC and Approving Conforming Amendments
Project stage: Other
ML0415603252004-06-0404 June 2004
R. E. Ginna, Order Modifying May 28, 2004, Order Approving Transfer of License from Rochester Gas and Electric Corporation (Rg&E) to R. E. Ginna Nuclear Power Plant, LLC (Ginna LLC) and Approving Conforming Amendment
Project stage: Other
ML0416702392004-06-10010 June 2004
R. E. Ginna, Amendment No. 12 to Indemnity Agreement No. B-38
Project stage: Other
ML0416002482004-06-10010 June 2004
R. E. Ginna, Amendment, Issuance of Conforming Amendment Re Transfer of License
Project stage: Approval
2004-03-26
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Text
Robert C. Mecredy R OW Always at YourService Vice President Nuclear Operations March 26, 2004 Mr. Robert L. Clark Office of Nuclear Regulatory Regulation U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001
Subject:
License Transfer Application R. E. Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Clark:
The purpose of this letter is to supplement our December 16, 2003 "Application for Order and Conforming Administrative Amendments for License Transfer", particularly with respect to Exhibit 12 of that submittal, the "Interconnection Agreement between Constellation Generation Group, LLC and Rochester Gas and Electric Corporation".
The supplementary information, as well as the questions discussed via telecon on March 3, 2004, is provided in Attachment 1.
Very truly yours, Robert C. Mecredy Attachment 1
-OD An equal opportunity employer 89 East Avenue I Rochester, NY 14649 tel (585) 546-2700 www.rge.com i oO q d An Energy East Company
cc:
Kenneth Kolaczyk, Sr. Resideni Inspector R.E. Ginna Nuclear Power Plant U.S. Nuclear Regulatory Commission 1503 Lake Road Ontario,NY 14519 Hubert J. Miller Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Daniel F. Stenger Ballard Spahr Andrews & Ingersoll, LLP 601 13' Street, N.W., Suite 1000 South Washington, DC 20005 Mr. James M. Petro Counsel for Constellation Energy Group 750 East Pratt Street, 5th Floor Legal Department Baltimore, MD 21201 James R. Curtiss Counsel for Constellation Energy Group at Winston & Strawn 1400 L Street, N.W.
Washington, DC 20005 Samuel Behrends, IV Counsel for Rochester Gas and Electric Corporation at LeBoeuf, Lamb, Greene and MacRae 1875 Connecticut Avenue, N.W.
Washington, DC 20009 Robert L. Clark (Mail Stop 0-8-C2)
Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852
Attachment 1
- 1) The license transfer application is stated to be based on Section 184 of the Atomic Energy Act of 1954, 10 CFR 50.80 and 50.90. Confirm that after the transfer of Ginna Nuclear Power Plant ownership to Ginna LLC which will result in the Rochester Gas and Electric Corporation owning and operating most of the high voltage switchyard, all the requirements of electric power systems to GDC 17 of Appendix A of 10 CFR 50 and loss of all alternating current power to 10 CFR 50.63 will be met consistent with the licensing basis.
RG&E is committed both to General Design Criteron 17 and 10 CFR 50.63. A description of our conformance is provided in UFSAR section 3.1.2.2.8 and Technical Specification B3.8.1, "AC Sources, Applicable Safety Analyses" for GDC 17, and in UFSAR section 8.1.4.4 for Station Blackout. Conformance with these requirements will be maintained following license transfer from RG&E to Ginna LLC.
- 2) The Appendix I, Substation Components, in Exhibit 12 of the submittal has been left blank. Provide information on the components to be included in this Appendix.
The NRC Maintenance, Rule 10 CFR 50.65, as implemented at Ginna Station does not include within its scope any components within Station 13A that will be owned by RG&E following the license transfer. The Maintenance Rule Scope boundary for offsite power is defined at the breakers 52/76702 and 52/75112 located onsite. The Maintenance Rule Scope boundary for the 115 KV output is defined at the output breakers/disconnect switches at Station 13A. All these components will be owned and maintained by Ginna LLC following the sale. Components at Station 13A that will be owned by Ginna LLC following the license transfer (as set forth in Appendix A to the Interconnect Agreement) will be maintained in accordance with the Ginna Station Preventative Maintenance program and will be consistent with good utility practices. Appendix I sets forth the substation components to be retained by the Transmission Owner that are covered by the NRC Maintenance Rule, per Interconnection Agreement section 10.6.2. The schedule in Appendix I correctly indicates "None", since the Transmission Owners will not retain ownership of facilities/components within the scope of the NRC Maintenance Rule.
Those components being transferred to Ginna LLC that are presently within Maintenance Rule will remain so; no changes to the Maintenance Rule scoping are being made.
- 3) Clause 9.6.3 in Exhibit 12, addresses voltage limits. Are there any procedures addressing the time period within which the transmission company has to inform the generating company about problems in the transmission systems that may require emergency measures to be initiated by the generating company?
The Interconnection Agreement, Article 13.2, states the Transmission Owner ("TO")
shall promptly notify Ginna LLC of emergency conditions on the TO interconnection or transmission system that may reasonably be expected to affect Ginna Station operations.
A 'Substation Operating Guidelines Procedure Agreement' is in development between RG&E (the Transmission Owner) and Ginna LLC. This procedure discusses the required notifications for problems in the transmission system, and requires the RGE Systems Operations Transmission Operator to notify Ginna Station 'as soon as possible' during adverse transmission system conditions. The 'as soon as possible' wording was selected, consistent with Article 13.2 of the Interconnection Agreement, to allow RG&E to respond to emergency situations immediately, with Ginna notification performed when the situation permits. There is no intent to specify a set time limit for notification.
Nevertheless, we will conform the "as soon as possible" language in the Substation Operating Guidelines Procedure Agreement to the "promptly" language of the Interconnection Agreement.
- 4) Identify whether procedures for high voltage switchyard control and maintenance have been written and implemented for "joint use facilities" and how these procedures compare with industry practices.
The term "joint use facilities" is defined in the Interconnection Agreement, Article 1. All substation 13A components shall be owned by Ginna LLC or RG&E, the Transmission Owner, in accordance with Article 10 of the Interconnection Agreement. The Transmission Owner shall maintain its facilities and components in a safe and reliable manner in accordance with Good Utility Practice and the Interconnection Agreement.
The RGE Energy System Operating Rules (ESOR) are currently in effect for high voltage switchyard control and maintenance. In accordance with the Interconnection Agreement, the ESOR shall be complied with for 'joint use facilities' (Substation 13A). The ESOR establishes the processes for control, isolation and restoration of electrical equipment and are consistent with standard industry practices.
- 5) Describe how the maintenance rule will be implemented for the high voltage switchyard following license transfer.
The components in Substation 13A impact Maintenance Rule compliance at Ginna in that the plant level performance is affected by the performance of Station 13A pipe cable, current transformers, potential transformers, breakers and disconnects, and the circuit 767 offsite power source is affected by transformer 6, its disconnect and the 767 regulator. As noted above, the existing Ginna Maintenance Rule scoping and implementation will not change as a result of the license transfer.
