ML041280087

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R. E. Ginna Nuclear Power Plant, License Transfer Supplement
ML041280087
Person / Time
Site: Ginna Constellation icon.png
Issue date: 04/30/2004
From: Mecredy R
Rochester Gas & Electric Corp
To: Clark R
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML041280087 (2)


Text

Robert C. Mecredy R E.-

Always at Your Service Vice President Nuclear Operations April 30,2004 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 Supplement 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. In particular, we wish to discuss the protocol being developed in our 'Substation Operating Agreement between Constellation Energy Group/Ginna Nuclear Station and Energy East/Rochester Gas and Electric".

Within that document, currently drafted with an anticipated approval date of May 15, 2004, protocol exists for the Transmission System Operator (TSO) to communicate with the generation facility concerning information related to grid conditions (lines out of service, degraded voltage conditions, unusual energy demands, reactive power equipment issues, etc.) that could compromise the ability of the offsite power system to support the generating station demands (e.g., could not support post-trip load requirements).

This information is provided by the TSO to the generating facility control room, where an assessment of potentially affected operating conditions and future activities is conducted. Both deterministic methods (Technical Specifications) and probabilistic methods (risk monitor) are used to provide guidance to the control room personnel who, in concert with Planning, Engineering, and Maintenance, make a determination of allowable configurations for operations, testing, and maintenance. Also, implementation procedures associated with 10 CFR 50.65(a)(4) require a risk review prior to electively removing loss of offsite power (LOOP) and Station Blackout (SBO) mitigation equipment from service. This review can be accomplished via the risk monitor and/or qualitatively. This protocol will help maintain communications between the TSO and the generating facility such that risk-significant LOOP and SBO mitigating systems are not unnecessarily or unknowingly taken our of service under more vulnerable grid conditions.

As a clarification to our March 26, 2004 response, Item 2, the Maintenance Rule scope boundary for offsite power is defined at the breakers 52/76702 and 52/75112 for offsite circuits 767 and 751, respectively.

These breakers are located in the Ginna Station switchyard and are controlled by the Ginna Station control room. However, the Ginna Maintenance Rule process is defined such that any failure upstream of those breakers is evaluated for functional failure determination, and unavailability hours are tracked. If monitoring criteria are exceeded, an evaluation is performed to determine if it was a maintenance preventable functional failure requiring (a)(2) to (a)(1) transition. The issue of direct ownership or control of that equipment is not relevant to the determination. Required preventive maintenance is currently performed by RG&E on all switchyard equipment affecting Maintenance Rule functions, and agreements to continue this maintenance will be placed in effect following ownership transition.

An equal opportunity employer 89 East Avenue I Rochester, NY 14649 tel (585) 546-2700 www.rge.com a I 00 I 0t O An Energy East Company

Page 2 April 29,2004 License Transfer Supplement Another issue of conforming interest is the effects of the August 14, 2003 Northeast Blackout on the operation and design of Ginna Station. During that event, Ginna Station did not lose offste power, but because of the voltage fluctuations on the grid, properly and conservatively transferred the safeguards buses to diesel generator power. Some lessons-leamed on optimizing plant operation in response to the trip were incorporated into the plant, using our Corrective Action process. However, no specific changes related to plant response to grid conditions, other than strengthening the protocol as discussed above, have been determined to be necessary at Ginna Station.

I declare under penalty of perjury under the laws of the United States of America that I am authorized by Rochester Gas and Electric Corporation to submit this documentation and that the foregoing is true and correct.

very y yours, Executed on April 30, 2004 Robert C. Mecredy Mr. Robert L. Clark (Mail Stop 0-8-C2)

Project Directorate I Division of Licensing Project Management Office of Nuclear Regulatory Regulation U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 U.S. NRC Ginna Senior Resident Inspector Regional Administer, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406