ML20198C452

Requests Issuance of in Furtherance Certification by 851115 in Order to Permit Financing of Ownership Interest of South Mississippi Electric Power Assoc in Pollution Control Facilities.Related Info Encl

ML20198C452
Person / Time
Site:	Grand Gulf
Issue date:	11/08/1985
From:	Knotts J BISHOP, COOK, PURCELL & REYNOLDS, MIDDLE SOUTH UTILITIES, INC., SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION
To:	Harold Denton Office of Nuclear Reactor Regulation
References
TAC-60044, NUDOCS 8511120096
Download: ML20198C452 (4)

Text

0 a h L AW OFFICE S OF BISHOP, LIBERMAN, COOK, PURCELL & REYNOLDS 1200 SEVENTEENTH STREET, N. W.

WASHING TON, 0. C, 2OO36 (202) S57-9800 IN NEW YORK TELEX 440$74 $NTLAW UI BIS M OP, LIB E RM A N & COOM T E LECO PIE R f202) 857-9846 I:55 AvENU E OF TH E AM ERf CAS NEW YOR m, N EW YORK 10016 I,ai2) 704- O BOO TELEK 222767 November 8, 1985 .R.TE w. OiR EC, O. AL (aCa)

Mr. Harold R. Denton Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Re: In the Matter of Mississippi Power & Light Company, Grand Gulf Nuclear Station, Unit 1, Docket No. 50-416.

Dear Mr. Denton:

As stated in my letter to you of October 30, 1985, Claiborne County, Mississippi plans to issue pollution control revenue bonds ("PCRB's") in November 1985, the proceeds from the sale of which will be used to finance the ownership interest of South Mississippi Electric Power Association ("SMEPA") in certain pollution control facilities at Grand Gulf Nuclear Station, Unit No. 1. Pursuant to subsequent discussions, this letter clarifies the scope of our request and supersedes my October 30, 1985 letter. In order to satisfy the pertinent requirements of the Internal Revenue Code and Internal Revenue Service regulations, Middle South Energy, Inc. ("MSE"), on behalf of SNEPA, requests that the NRC certify that certain of_the pollution control facilities being financed are in furtherance of the abatement or control of water pollution or atmospheric pollutants or contaminants.

The NRC has previously certified essentially these name Grand '

Gulf facilities (except for the environmental monitoring facility) financed by previous series of PCRB's (letter from Harold R. Denton with enclosures dated November 13, 1984 and letter from Edson G. Case, Jr. with enclosures dated December 21,

.1983, copies attached). In the main, the certification now being S%v 8511120 O*% 9

Mr.. Harold R. Denton November 8, 1985 Page 2 requested represents SMEPA's interest in facilities previously certified by NRC in 1983 and 1984 with respect to MSE's ownership interest.

We are enclosing for your use a form of in furtherance certification, with attached revised descriptions of the facilities. This format is consistent with that of your November 13, 1984 certification referred to above as well as other certifications issued by the NRC in recent years for other facilities. We are also enclosing a resolution adopted by the Board of Supervisors of Claiborne County, Mississippi on July 22, 1985 (issued September 25, 1985) declaring the intention of

'Claiborne County to issue these PCRB's. Finally, we enclose the findings of the Bureau of Pollution Control of the Mississippi Department of Natural Resources referred to in Section 1 of the Claiborne County Resolution. SMEPA plans to complete this transaction during the month of November, 1985. Accordingly, we request that you issue the In Furtherance certification by November 15, 1985 in order to permit the financing to proceed as scheduled. Please let us know if you require any further

.information.

cerely, L

dpseph B. Knotts, J::.

Counsel for Middle South Energy, Inc. Acting on behalf of South Mississippi Electric Power Association cc: E. Jakel, Esq.

Mr. L. Kintner Mr. L.F. Dale

. -m LIST OF ATTACHMENTS Attachment 1 - December 21, 1983 Certification Attachment 2 - November 13, 1984 Certification Attachment 3 - Form of in furtherance certification for November 1985 certification with Attachment

" General Description of Facilities" Attachment 4 - Resolution of Claiborne County, Mississippi to issue pollution control revenue bonds Attachment 5 - Finding by Bureau of Pollution Control, Mississippi Department of Natural Resources O

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c # 'o UNITED STATES '

E ] , Y ,% NUCLEAR REGULATORY COMMISSION 3, ._.;

i e WASHINGTON. D. C. C555 s' -...../ DEC 21 1983 1

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. Mr. Troy B. Conner, Jr.

j Conner & Wetterhahn, P.G. .

1747 Pennsylvania Avenue, N.W.

Washington, D.C. 20006

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In the Matter of MISSISSIPPI POWER AND LIGHT COMPANY (Grand Gulf Nuclear Station, Unit 1)

Docket No. 50-416 l

Dear Mr. Conner:

l In response to your letter of September 16, 1983, the NRC Staff has reviewed (1) the Resolution adceted on June 10, 1923, by the Board of Supertisors of Claiberne County, Mississippi, and (2) the Intarnal Revenue Service ruling of May 12, 1983, pertaining to the Grand Gulf Nuclear Station Project. We are satisfied that the portions of the Grand Gulf Nuclear Station, Unit 1, for which you have requested NRC certification are " pollution control facilities".

Accordingly, the attached certificate has been executed.

Copies of y' cur request and this response along with the IRS ruling of May 12, d

, 1953, and the June 20, 1953 Resolution adoptec by the Soard of Supervisors of Clairborne County, Mississippi,- will be available for inspection at the local public docucent recm (Hinds Junior College, George M. McLendon Library,

, Raymond, Mississippi) and at the Commission's Public Document Room at 1717 H l Street, N.W., Washingten, D.C. .

S ely, l f) % .. J-l Edson G. Case

/ Deputy Director Office of Nuclear Reactor Regulation

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Enclosure:

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As stated -

cc w/ enclosure:

Service List .

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J<h' Grand Gulf r i

Mr. J . P . M:G au g hy .

Vi ce President Nuclear Production 1

Mississippi Power & Light Company P. O. Box 1640 .

Jackson, Mississippi 39205 cc: Robert S. McGehee, Esquire Wise, Carter, Child, Steen and Caraway P. O. Box 651 Jackscn, Mississippi 39205 Troy B. Conner, Jr. , Esquire Conner and Wetterhahn 1747 Pennsylvania Avenue, N. W. -

,Washington, D. C. 20006 Mr. J . F. 'Fa ger Senic- Vice P resident Middle South Energy, Inc. .

225 Barenr,e Street P. O. Box 6100 New Orleans, Louisiana 10161 Mr. Larry Dale Mississippi Power & Light Company

. P. O. Box 1640 Jackson, Mississippi 39205 Mr. R. W. Jackson, Project Engineer Grand Gulf Nuclear Staticn .

. Bechtel Pcwer Corporation 1

. Gaithersburg, Maryland 20760 ,

4 Mr. Alan G. Wagner i Resident Inspector Routt 2, Box 150 Pert Gibson, Mississippi 39150 4

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Docket No. 50-416 Grand' Gulf Nuclear Station, Unit 1 j , CERTIFICATE l

I, Edson G. Case, Deputy Director, Office of Nuclear Reactor Regulation of the Unitad States Nuclear Regulatory Co=nission, being duly authorized', certify as i

follcws:

(1) The Resolution adopted by the Boa'rd of Supervisors of Claiborne County, Mississippi, entitled " Resolution Authorizing the Filing of Petition with 4

the Mississippi Scard of Econcaic Development for Approval of the Issuance i, of Pollution Control Revenue Bonds in Principal Amount not to Exceed One j Hundred Million Dollars ($100,000,0C0) and for Related Purpcses" has been 1

i submitted to the NRC by counsel for Mississippi Pcwer and Light Company ,

l~ ("theApplicant"). The Resolution contains a project'descript' ion of Grand Gulf Nuclear Station (both Units 1 and 2).

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(2) The Resolution describes, among other things, the following systems in

• Grand Gulf Nuclear Station, Unit 1:

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c (a) The closed loop cooling water system; (5) The components of the radwaste and other waste systems-(including the Oily Waste and Chemical Waste systems); and (c) The Skyshine Shielding System.

(3) Applicant's ccunse.1 has requested that, the NRC certify that certain of

.the systems listed in paragraph (2) above, as designed, are in furtherance of the purpose of controlling water pollution and atmospheric pollutants, respectively.

Acting as a duly authorized representative of the NRC, I hereby certify that, the systems in Unit 1, enumerated in paragraph (2) above, as designed, are in furiherance of the purpose of controliing water pollution and atmospheric pollutants.

FOR [HE fiUCLEAR REGULATORY COPfilSSIO

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OQ / w EdsonG.Cgge Dated at Bethesda, Maryland #

this 21st day of December 1983

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[ 'o, UNITED STATES NUCLEAR REGULATORY COMMISSION

% j WASHINGTON. D. C. 20555

%, ...../ November 13, 1984 Docket No. 50-416 Mr. Joseph B. Knotts, Jr.

Counsel for Middle South Energy, Inc.

Bishop, Liberman, Cook, Purcell & Reynolds 1200 Seventeenth Street, N.W.

Washington, D.C. 20036

Subject:

Certification of Pollution Control Facilities for Grand Gulf Nuclear Station, Unit 1 Your letter dated November 2,1984, on behalf of Middle South Energy Inc. (MSE) requested that our office issue a Certification of Pollution Control Facilities for Grand Gulf Nuclear Station, Unit 1 for certain facilities described in Attachment 2 to that request.

The NPC staff has reviewed the November 2,1984, request. Based on that review, we are satisfied that the facilities for which you requested NRC certification are in furtherance of the purpose of abating or controlling atmospheric pollut-ants or contaminants or water pollutants resulting from the generation of electricity at the Grand Gulf Nuclear Station, Unit 1. Accordingly, the

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enclosed cdrtificate has been executed.

Copies of the November 2, 1984, request and the response will be available for inspection at the Commission's Public Document Room (1717 H Street, N.W.,

Washington, D.C. 20555) and at the Local Public Document Room (Hinds Jr. College, George M. McLendon Library, Raymond, Mississippi 39154).

Sincerely,

/

Harold R. Denton, Director Office of Nuclear Reactor Regulation i

Enclosure:

As stated l

cc: See next page l

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., Sa GRAND GULF Mr. J. B. Richard Senior Vice President, Nuclear Mississippi Power & Light Company P.O. Box 23054 Jackson, Mississippi 39205 cc: Robert B. McGehee, Esquire .The Honorable William J. Guste, Jr.

Wise, Carter, Child, Steen and Caraway Attorney General P.O. Box 651 Department of Justice Jackson, Mississippi 39205 State of Louisiana Baton Rouge, Louisiana 70804 Nicholas S. Reynolds, Esquire Bishop, Liberman, Cook, Purcell and Reynolds 1200 17th Street, N.W.

Washington, D. C. 20036 Mr. Ralph T. Lally Manager of Quality Middle South Energy, Inc. '

225 Baronne Street P.O. Box 61000 New Orleans, Louisiana 70161 Mr. La.rry Dale, Director Nuclear Licensing and Safety Mississippi Power & Light Company P.O. Box 23054 Jackson, Mississippi 39205 Mr. R. W. Jackson, Project Engineer Grand Gulf Nuclear Station Bechtel Power Corporation Gaithersburg, Maryland 20760 Mr. Alan G. Wagner Senior Resident Inspector Route 2, Box 399 Port Gibson, Mississippi 39150 James P. O'Reilly, Regional Admin.

U.S. Nuclear Regulatory Commission, Region II

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101 Marietta Street, N.V., Suite 2900 Atlanta, Georgia 30323 Mr. J. E. Cross, General Manager Grand Gulf Nuclear Station .

P.O. Box 756 Port Gibson, Mississippi 39150 l

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y, UNITED STATES  ;

y .r. g NUCLEAR REGULATORY COMMISSION WA$HINGTON, D. C. 20555

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CERTIFICATE GRAND GULF NUCLEAR POWER STATION, UNIT 1 POLLUTION CONTROL FACILITIES The Nuclear Regulatory Comission hereby certifies as follows:

(a) that it has examined Exhibit A attached hereto which is entitled " General Description of the Facilities" and which describes certain facilities which have been constructed, are under construction or are to be constructed at the Grand Gulf Nuclear Power Station, Unit 1, a nuclear electric power generating plant located in Claiborne County, Mississippi, which plant is owned in part by Middle South Energy, Inc.

(b) that such facilities, as designed, are in' furtherance of the purpose of abating or controlling atmospheric pollutants or con-taminants or water pollutants resulting from the generation cf electricity at the Grand Gulf Nuclear Power Station, Unit 1.

FOR THE NUCLEAR REGULATORY COMMISSION

/h Harold R. Denton, Director Office of Nuclear Peactor Regulation Date: Nmom%r i t loca h

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- IXHIEIT A Licuid Waste Systems The, Liquid Maste Systems include the Reactor Water Cleanup System, dhe Liquid Radwaste System, a.".d the portion of the Radwaste Building (77.7% of the financeable cost) that is for liquid waste systems.

The Reactor Water Clernup System includes pudps, heat exchangers, filter demineralizers, strainers and tanks necessary to provide continuous purifying treatment of the reactor water.

The pcrtior of this systam that is financeable is the equipment

. required to collect the backwash liquid waste which would normally go to drains.

The Liquid Radwaste System includes three primary subsystems (equipment drains, floor drains, and che.f.ical waste processing) which are designed to control, collect, store, process, treat and dispose of low level radioactive liquid wastes. This system was designed according to governmental regulations to meet radioactivity pretection standards far in excess of standards necessary for safety.

A hypothetica1' Alternate System has,been designed which would still

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easily meet all safety standards. This Alternate System is far less expensive to construct than the existing system. The portion of the Liquid Radwaste System that is financeable is the incremental portion of the existing system's cost that is above the total cost of the Alternate System.

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Gaseous Waste Systems The Gaseous Waste Systems include the Turbine Building ventilation System and the portion of the Radwaste Building allo-cated to gaseous waste.

The Turbine Building Ventilation System consists of haating, ven,tilation, and cooling systems' designed to provide an environment

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with controll.ed temperature and humidity. The portion of this system that is included in the financeable cost is the exhaust collection and exhaust ductwork, exhaust filters, fans and radia-tion monitors. .

The portion of the Radwaste Building (S.0% of the financeab1e cost) that..is for gaseous waste contains. systems that treat and -

. dispose od radioactive gaseous wastes that are generated in the Radwaste Building. -

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f Solid Waste Systems The Solid Waste Systems include?the spent resin regenerative portions of the Makeup Water Treatment System and the Condensate Cleanup ystem, and parts of the Radwaste Building.

The function of the Makeup Water Treatment System is to provide demineralized water for the plant. The portion of this 7

system that is included in the financeable cost is the spent resin 1

regeneration equipment. This equipment consists of 1cid tanks, caustic tank, acid and caustic transfer pumps, caticis and anions tank waste

• piping to drains, caustic dilution water heater tank and sulfuric acid day tank.

4 Equipment has been added to regenerate spent demineralizer resins that would otherwise be discarded as solid radioactive waste. The equipment including tanks, pumps, and valves, is financeable as solid waste equipment. This equipment is found in the condensate cleanup system and the solid waste por' tion of the liquid radwaste system.

The portion of the Radwaste Building (14.3% of the financeable cost) that is for solid waste contains systems.that collect, store, package, and prepare radioactive solid waste for disposal.

Spent resin is unusable and of no value. The company does

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not expect to sell, or to be able to sell, spent resin at any price.

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Spent Fuel Storace Facility I

Spent nuclear fuel and fuel assemblies are stored and disposed of in the Spent Fuel Storage Facility. Due to curreht industry and regulatory conditions, spent nuclear fuel is a solid waste with no current value or use. Only that portion of the fuel handling system used for spent fuel storage is included in the scope of the exempt facilities. .

The portions of this sys te: that are. included in the financeable cost are the spent fuel pool, 1.ners, high density fuel storage racks in the spent fuel pool and the additional spe.7.t fuel pool cooling and cleaning capacity required for the spent fuel pool. ,

Also, included in the financeable co.st of the Spent Fuel Storage Facility is that portion of the auxiliary building that is dedicated to spent fuel storage and handling.' The areas of the building that are included consist of the spent fuel platform and 150 ton crane, spent fuel pool, spent fuel transfer canal, shipping cask pool, cask,,washdown area, and spent fuel cask handling area. The rail-road car fuel cask loading bay 'and equipment are also included as well as the railroad spur into the fuel building because they are z .

also dedicated to spent fuel' h'andling and d.isposa1. ,

The company does not expect to sell, or to be able to sell, spent nuclear fuel and fuel assemblies at any price.

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Enercy Service Center Sanitary System -

4 The Sanitary System consists 'of : facilities for the Energy Services Center that are designed to treat and dispose of sewage.

It is siNed to serve 350 persons with a load criterion of 33,947 gallons per day.

The portion of this system that is financeable consists of p

, all sanitary waste piping in the- Energy Services Center and the sanitary waste pipe from the Center to the Treatment P' ant. The Sanitary Waste Treatment Plant itself is not included n the ,

financeable cost because it he.5 been in service for more than a year. -

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CERTIFICATE GR ND GULF NUCLEAR POWER STATION, UNIT 1 Pollution Control Facilities The Nuclear Regulatory Commission hereby certifies as follows:

(a) that it has examined Exhibit A attached hereto which is entitled " General Description of the Facilities" and which describes certain facilities which have been constructed, are under construction or are to be constructed at the Grand Gulf Nuclear Power Station, Unit 1, a nuclear electric power generating plant located in Claiborne County, Mississippi, which plant is owned in part by Middle South Energy, Inc., and in part by South F}ississippi Electric Power Association.

(b) that such facilities, as designed, are

- in furtherance of the purpose of abating or

. controlling atmospheric pollutants or contaminants

_- water pollutants resulting from the generation

- of electricity at the Grand Gulf Nuclear Power Station, Unit 1.

For the Nuclear Regulatory Commission By:

Office of Nuclear Reactor Regulation Dated at this the day of , 1985.

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EXHIBIT A General Description of the Facilities Liquid Waste Systems A. Portion of Reactor Water Cleanup System which collects backwash liquid waste which would nomally go to drains, and which includes pumps, heat exchangers, filter demineralizers, strainers and tanks necessary to provide continuous purifying treatment of the reactor water.

B. Portion of the Liquid Radwaste System which includes three primary subsystems (equipment drains, floor drains and chemical waste processing) which are designed to control, collect, store, process, treat and dispose of low-level radioactive liquid wastes.

C. Portion of Auxiliary Building allocable to liquid waste systems.

D. Portion of Radwaste Building allocable to liquid waste systems.

Gaseous Waste Systems A. Gaseous Radwaste Management System designed to control air pollution, consisting of an Off-gas System, a Radwaste Building Filter System, an Auxiliary Building Filter System and a containment Building Filter System. Includes

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exhaust filters, fans, ducts, radiation monitors and related facilities to collect, filter and discharge exhaust air.

,, B. Portion of the Off-Gas Building, the Radwaste.

Building and the Auxiliary Building allocable to the Gaseous Radwaste Management System.

C. Portion of the Turbine Building Ventilation System f consisting of the exhaust collection and exhaust ductwork, exhaust filters, fans and radiation monitors.

D. Sky-shine Shielding System consisting of structures

designed to control air pollution by limiting offsite emissions

of direct radiation from the Plant.

l Sewage and Solid Waste Systems A. Portion of Radwaste Building allocable to solid waste systems that collect, store, package, and prepare radioactive solid waste and solidified liquid waste for offsite

, shipment and permanent disposal.

B. Spent fuel storage and handling facilities ,

consisting of portion of cm t of spent fuel transfer canal, spent fuel pool, liners and high-density fuel storage racks in the spent fuel pool, additional spent fuel pool cooling and cleaning capacity, spent fuel platform, shipping cask pool, spent fuel cask handling area, cask washdown area, 150-ton crane, spent fuel

cask loading bay and equipment and railroad spur from Auxiliary I

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c Building to main track, and related portion of Auxiliary Building a .

allocable to spent fuel storage and handling facilities.

C. Interim Radwaste Handling Facility, including a metal building and its associated equipment, to collect, store,

' package, and prepare solid low-level radioactive waste, consisting of radwaste and solidified liquid waste, for shipment-

-off-site.

Environmental Monitoring Facility f A. Environmental Monitoring Facility, which gathers biological, soil, air and water samples from points both close to and more distant from the Plant, and subjects them to analyses,

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l l and includes the Environmental Surveillance Facility, consisting of office and laboratory space used for sample preparation and 4 analysis, sample storage, and hazardous waste processing, which-monitors, analyzes and evaluates the peformance of the air and '

water pollution control facilities and solid waste disposal

facilities.

B. Salt Deposition Analyses, consisting of the costs incurred-for laboratory facilities to take samples and statistically analyze samples taken from the area around the cooling tower to determine environmental releases.

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The following resolution was presented in writing, read and discussed:

RESOLUTION AUTHORIZING THE FILING OF PETITION WITH THE MISSISSIPPI BOARD OF ECONOMIC DEVELOPMENT FOR APPROVAL OF THE ISSUANCE OF POLLUTION CONTROL REVENUE BONDS IN PRINCIPAL AMOUNT NOT TO EXCEED SEVENTY-FIVE MILLION DOLLARS (S75,000,000) AND FOR RELATED PURPOSES.

WHEREAS, the Board of Supervisors of Claiborne County, Mississippi (the " Governing Body") acting for and on behalf of said -County (the " Issuer"), does hereby find, determine and

. adjudicate as follows:

1. The Issuer is a public body corporate and politic and a political subdivision of the State of Mississippi, duly organized and existing under the Constitution and laws of the State of Mississippi, and a' " municipality" as defined in Sections 49-17-101 through 49-17-123, Mississippi Code of 1972 (the "Act").

2. The Issuer is authorized by the Act to acquire, purchase and construct pollution control facilities as defined in the Act, including related sewage and solid waste disposal facilities, to issue bonds for the purpose of def raying the cost of such facilities, and to enter into contracts for the lease and/or sale of such facilities to an " industry" as defined in the Act.

3. Pursuant to its authority under the Act, the Issuer on <

April 10, 1974 adopted a Resolution (the " Resolution"), intended to constitute official action as contemplated in the Internal Revenue Code of 1954, as amended (the " Code"), whereunder the Issuer agreed to issue its pollution control revenue bonds in the principal amount not to exceed $500,000,000 and to use the proceeds from the sale of said bonds for the acquisition and construction of certain pollution control facilities to be used for the ' elimination, mitigation and/or prevention o f 'a i r and water pollution (the " Project) to be located at the Grand Gulf Nuclear Station located within the Issuer about six to seven miles Northwest of Port Gibson in District 2, Claiborne County, Mississippi, situated in Sections, 1, 2, 3, 4, 5, 6 and 32, 12441310f

8, 11, 12 and 30, Township 12' North, Range 1 East and Section 7, Township 12 North, Range 2 East;

4. The Resolution authorized the sale or lease of the

- Project to Mississippi Power & Light Company, a . Mississippi corporation ("MP&L") and its successors or assigns;

5. Pursuant to a Sales Agreement dated as of June 21,.1974, becween MP&L and Middle South Energy, Inc. ("MSE"), and a Bill of Sale dated as of June 25, 1974, between MP&L and MSE, MP&L agreed to and did convey, transfer, sell and assign to MSE all of MP&L's, right, title, and interest in the Project.

6. Pursuant to a Joint Construction, Acquisition and Ownership Agreement dated as of May 1, 1980, between MSE and the South Mississippi Electric Power Association, a Mississippi corporation and an " industry" as, defined in the Act ("SMEPA"),

SMEPA obtained a 10% undivided ownership interest in the Project by advancing 100% of the construction costs of the Project each month until such payments, plus an allowance for funds used during construction, equalled 10% of the total cost of the Plant; such payments equalled lot, computed on such basis, on June 15, 1981.

7. By resolution of the Governing Body adopted on December 20, 1984, the -Issuer (i) declared affirmed that all of the provisions of the resolution adopted by this Board of Supervisors on April 10, 1974 with respect to the issuance by Claiborne County of pollution control revenue bonds in a principal amount not to exceed 5500,000,000 for the purpose of paying the cost of constructing and installing pollution control facilitie.s and related sewage and solid waste disposal facilities for use in connection with the Plant are to be and-remain effective without regard to the ownership interest, of MP&L in or to the Plant; (ii) affirmed that its resolution adopted on April 10, 1974 was intended to . constitute and be official action by the Issuer within the meaning of the Internal Revenue Code of 195,4 and the regulations promulgated thereunder with respect to the issuance ,

of bonds to . finance the sewage and solid waste disposal and

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pollution control facilities comprising the Project, without regard to whether the Project may be owned by MF&L or by any combination of responsible o-ners's; (iii) elected'to treat the separate interest of SMEPA in the Project (the "SMEPA Project")

as a carryforward project under the Internal Revenue Code of 1954 and the Regulations promulgated thereunder (the " Code") and the Governor.'s Executive Order No. 529, dated as of October 1, 1984, (iv) elected to carry forward $31,400,000 of any excess private activity bonding authority amount available for the calendar year

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1984 with respect to the SMEPA Project and made application to the Mississippi Board of Economic Development (the " Board") for a carryforward allocation in the amount of $31,400,000.

8. By resolution of the Governing Body on December 20, 1985, the Issuer hereby determined,to issue, pursuant to the Act, one or more issues or series of bonds, in an aggregate principal amount to be agreed to by the Issuer and SMEPA up to $75,000,000, to finance a portion of SMEPA's costs of acquiring an undivided interest.in the Project, including financing and other incidental

. Costs.

9. The Issuer received a Notice of Carryforward Allocation from the Board for SMEPA's undivided interest in the Project in th'e amount of $31,400,000 dated December 31, 1984.

10. By resolution of the Governing Body adopted on February 6, 1985, the Issuer elected to carry forward an additional

$10,100,000 amount with respect to SMEPA's undivided interest in the Project and made application to the Board for an additional carryforward allocation of $10,100,000.

11. The Issuer received a Notice of Carryforward Allocation from the Board for SMEPA's undivided interest in the Project in

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the amount of $10,100,000, dated February 9, 1985. ,

12. Because of the particular nature of such lacilities comprising the Project, it would not have been in the public interest and would have less effectively achieved the purposes of

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the Act to have entered into contracts for the acquisition, purchase, construction and/or installation of facilities 12441310f

contemplated by the Act upon the basis of pub.ic bidding pursuant tc advertisement; public bidding on the Project pursuant to a

advertisement was dispensed with pursuant to resolutions of the i Governing Body duly adopted in connection with the financing of 1

MSE's interest in the Project on June 20, 1983 and October 3, 4 1984, and approvals granted by the Board on September 1, 1983 and i

October'5, 1984.

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13. By letter addressed to the Governing Body, SMEPA has i estimated that the cost of the pollution control facilities comprising that part of the Project to be financed by the Bonds hereinafter referred will be not in excess of Seventy-Five Million Dollars (575,000,000) and has concurred in the finding of [

the Governing Body that because of the particular nature of the i Project it would not have been in,the public interest and would have less effectively achieved the purposes of the Act to have entered into contracts for the acquisition, purchase, construction and/or installation of facilities contemplated by

' the Act ,upon the basis of public bidding pursuant to advertisement, which letter is in lines, words and figures as follows:

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1244;310f

SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION 4

HIGHWAY 4s NORTH # PO BOK isas a H ATTIESBURG MS 3940s I TEtEPHONE(son)ses sos 3 ,

4 July 21, 1985 4

t Board of Supervisors of Claiborne County Port Gibson, Mississippi 39150

' Gentlemen:

Pursuant to Title 49, Chapter 17, Mississippi Code of 1972 (the "Act"), you have agreed to assist South Mississippi Electric Power Association in finan-j cing the acquisition and construction of its 10% undivided interest in certain pollution control f acilities located at the Grand Gulf Nuclear Plant in Claiborne County, Mississippi (the " Project") more particularly described in Exhibit "A" attached to and made a part of this letter, having an estimated cost of seventy-rive Million Dollars ($75,000,000), including net interest during construction, an " insubstantial portion" factor of less than los and expenses relating to the issuance and sale of the bonds.

Because of and the particular nature of the f acilities comprising the Project, it would not have been in the public interest and would have less effectively achieved the purposes of the Act to have entered into contracts for the acqui-sition, purchase, construction and/or installation of f acilities contemplated by the Act upon the basis of public bidding pursuant to advertisement, and we

' concur with your finding that public' bidding pursuant to advertisement was properly dispensed with.

Yours very truly, SOUTH MISSISSIPPI E1I.CTRIC POWER l ASSOCIATION By:  !

General Manager Title i

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EXHIBIT A Liquid Waste Systems A. Portion of Reactor Water Cleanup System which collects backwash liquid waste which would normally go to drains, and .

which includes pumps, heat exchangers, filter demineralizers, strainers and tanks necessary to provide continuous purifying treatment of the reactor water.

B. Portion of the Liquid Radwaste System which includes three primary subsystems (equipment d' rains, floor drains, and chemical waste processing) which are designed to control, collect, store, process, treat and dispose of low el radioactive liquid wastes.

C. Portion of Auxiliary Building allocable to liquid waste systems.

D. Portion of Radwaste Building allocable to liquid waste systems.

E. Chemical and waste storage basins, constructed of reinforced

• concrete with a two-foot curb around all sides, and surrounded by a chain link fence, used to collect and store, before shipment and disposal off-site, containerized non-radioactive liquid waste consisting of cleaning solvents, laboratory chemical wastes, oils, and similar liquid wastes.

T Circulating Water System, consisting of facilities for control af thermal pollution of the Mississippi River through the use of a closed-loop natural draft cooling tower, a pumphouse, blowdown and make-up water facilites, sodium hypochlorite and sulphuric acid removal systems, associated plumbing and electrical equipment, and related facilities, to provide cooling water to the condenser which in turn condenses exhaust steam discharged from the turbine.

G. Radial Well System, comprised of f acilities to provide additional makeup water to the circulating water system, including a large' reinforced concrete caisson, installed vertically, that extends into the alluvial sediments adjacent to

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i I' the Mississippi River. Cooling tcwer make-up water will be t

derived from the Mississippi by means of induced filtration and

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will enter. the caissons through horizontal screened pipes extending radially from the caisson into the alluvial sediments.

H. Site Runoff Waste Water Treatment System, consisting of i.

concrete canals, catch basins, culverts, manholes, piping, l chutes, and chute spillways ,that collect waste water and convey i

it to Sediment Basins A & B, and the earthen dams with concrete I weirs that form 'the perimeter of the Sediment Basins. These j basins remove suspended solids by a settling process - and also i provide for storage and monitoring of the waste water.

I. Olly Waste System which will collect nonradioactive oily i wastes from stablizing sumps in several buildings.

I J. Chemical Waste System which will collect,and neutralize chemical wastes contained in nonradioactive water from the make-up water treatment system and blow-down facilities.

4 caseous waste systems A. daseous Radwaste Management System designed to control i air pollution, consisting of an off-gas System, a Radwaste Building filter System, an Auxiliary Building Filter System and a y Containment Building Filter system. Includes exhaust filters, I fans, ducts, radiation monitors and related facilities to j

collect, filter and discharge exhaust air.

B. Portion of the Of f-Gas Building, the Radwaste Building j and the Auxiliary Building allocable to t :e Gaseous Radwaste Management System.

I C. Portion of the Turbine Building Ventilation System 1 . .

j consisting of heating, ventilation, and cooling systems designed j to provide an environment with controlled temperature and humidity. Included in the financeable cost is the ex;.aust ,

collection and exhaust ductwork, exhaust filters, fans and

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radiation monitors.

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j D. Sky-shine Shielding System consisting of structures i

j designed to control air pollution by limiting of f site emissions of direct radiation from the Plant.

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s Sewage and Solid Waste Systems A. Portion of Radwaste Building allocable to solid waste i systems that collect, store, package, and prepare radioactive i solid waste and solidified liquid waste for offsite shipment and permanent disposal.

B. Spent fuel storage and handling facilities consisting of portion of cost of spent fuel transfer canal, spent fuel pool, ,

liners and high ' density fuel storage racks in the spent fuel 1 -

pool, additional spent fuel pool cooling and cleaning capacity, i spent fuel platform, shipping cask pool, spent fuel cask handling i

area, cask washdown area, 150 ton crane, spent fuel cask loading i bay and equipment and railroad spur from Auxiliary Building to main track, and related portion of Auxiliary Building allocable i to spent fuel storage and handling facilities.

f C. Facilities for Energy' Services Center designed to treat l i and dispose of sewage which facilities consist of all sanitary

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j waste paping in Energy Services Center and sanitary waste pipe from Center to Treatment Plant.

D. Interim Radwaste Handling racility, including a metal l I

building and its associated equipment, to collect, store, package, and prepare solid low-level radioactive waste, i consisting of radwaste and solidified liquid waste, for shipment l

off-site.

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Environmental Monitorir.q raelitty i

A. Environmental Monitoring racility, which gathers biological, soil, air, and water samples from points both'close i

to and more distant from the Plant, and subjects them to I

t analyses, and includes the Environmental Surveillance racility, i

consisting of office and laboratory space used for sample preparation and analysis, sample storage, and hazardous waste

! processing, which monitors, analyses and evaluates, the )

I performance of the air and water pollution control faellities and f solid waste disposal facilities.

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l B. Salt Deposition Analyses, consisting of the costs ,

incurred for sample analyses and statistical analyses of sartples l taken from the area around the cooling tower .to determine environmental releases.

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, 14. One poliution control f acilities ccitprising tnat part I

of the Project to be financed, in whole or in part, by the bonds t hereinafter referred to are generally described l'n Exhibit A to 1

j the Letter of SMEPA referred to in paragraph 12 hereof.

i l' 15. A general summary of the terms and conditions of the proposed sale agreement between the Issuer and SMEPA (the

" Financing Agreement") is as follows:

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The Financing Agreement will provide that in order to defray j a portion of the cost of the Project, the Issuer will issue and i

j sell its Pollution Control Revenue Bonds (South Mississippi

! Electric Power Association Project), in . principal amount not to exceed Seventy-Five Million Dollars (575,000,000) (the " Bonds"):

f that the Issuer will acquire and sell its undivided interest in i

d this portion of the Project to SMEPA for sums of money sufficient j to provide for the payment of the principal of and interest and j redemption premium, if any, on t!5e Bonds as the same shall become

{ due, whether at stated maturity thereof or otherwise; and that i SMEPA will pay the cost of maintaining its undivided interest in the Project and keeping its interest therein properly insured.

i j 16. The Issuer proposes to issue its pollution, control i

revenue bonds in principal amount not to exceed Seventy-rive

) Million Dollars ($75,000,000) for the purpose of defrayirg a portion of the cost of acquiring an undivided . interest in the k Projects in order to provide security for the payment of the

] principal of and interest and redemption premium, if any, on the I

. Bonds, the Issuer proposes to authorize the execution and

_ delivery of a Trust Indenture; the Bonds will be payable _ as to

! principal, interest and redemption premium (if any) solely out of

and secured by an irrevocable pledge of the revenue to be derived

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1 from the sale of an undivided interest in the Project, and any

other sums which may be received f rom or in connection with the l l

Project or which may otherwise be lawfully pledged or assigned or

, otherwise made available to the Trustee for such purposes; l payment of the principal of, interest and redemption premium, if t

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any, on the Bonds will be unconditionally guaranteed by National Rural Utilities Cooperative Finance Corporation ("CFC"); the i Bonds will be limited obligations of the Issuer, and shall never constitute an indebtedness of the Issuer within the meaning of any constitutional provision or statutory limitation of the State of Mississippi, and shall never constitute nor give rise to any pecuniary liability of the Issuer or a charge against its general credit or taxing power, not shall the Issuer be obligated to pay the principal of, 'or interest and redemption premium, if any, on any of the Bonds except from revenues to be derived from the sale of an undivided interest in the Project and any other sums which may be received from or in connection with the Project or which may otherwise be. lawfully pledged or assigned or otherwise made available to the Trustee for such purposes as aforesaid; the Bonds may be issued in one or more series and shall mature at such time or times as the Issuer and SMEPA may determine, not to exceed forty (40) years from their date; the Bonds shall be subject to such terms of redemption, shall be payable at such

. place or places, shall bear interest at such rate or rates not

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exceeding the maximum permissible cate applicable to the Bonds on the date of issuance as the Issuer and SMEPA shall agree upon, may contain such other provisions not inconsistent with the Act as the Issuer may determine, and shall be sold at public or private sale at such price and in such manner and at such time or from time to time as may be determined by the Issuer and SMEPA to be , mos t advantageous, all of which shall, be provided in the proceedings authorizing the issuance of the Bonds.

NOW, THEREFORE, BC ,lT RESOLVED BY THE BOARD OF SUPERVISORS

" OF CLAIBORNE COUNTY, MISSISSIPPI, AS FOLLOWS:

SECTION 1. That as required by the Act the Clerk' of the Governing Body is hereby directed to request a finding by the Bureau of Pollution Control of the Mississippi Department of Natural ' Resources that the pollution control facilities comprising the Project are necessary and that the design thereof

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will result'in the elimination, mitigation and/or prevention of air and water pollution, _and the Clerk is hereby authorized to

, . l 1 present such documents as may be required.

.SECTION 2. That the Clerk of the Governing Body be and is i'

hereby authorized to file with the Boa-d a certified copy of this

resolution, as and for the petition of the Issuer for approval of the pollution control facilities comprising the Project and approval to issue pollution control revenue bonds of the Issuer in principal amount not to exceed Seventy-Five Million Dollars i

($75,000,000), as described in the preamble hereof that said l

I petition be accompanied by a copy of the findings of the Bureau of Pollution Control of the Mississippi Department of Natural Resources in connection with the pollution centrol facilities comprising the Project and financial statements of SMEPA and CFC for the five (5) calendar years immediately preceding the date i hereof.

1 i SECTION 3. That the Board is requested to concur in and i

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^ a pp r ov'e t h,e finding by the Governing Body that, because of the

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particular nature of the facilities comprising the Project, it

! would not have been in the public interest and would have less effectively achieved the purposes of the Act to have entered into contracts for the acquisition, purchase, construction and/or

! installation of the facilities contemplated by the Act upon the 1'

basis of public bidding pursuant to advertisement and that public i

! bidding pursuant to advertisement was properly dispensed with.

! SECTION 4. That .all orders, resolutions or proceedings in j conflict with the provisions of this resolution shall be, and the same are hereby repealed, rescinded and set aside, but only to i

the extent of such conflict.

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{ ,The adoption of the above resolution was moved by Supervisor

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seconded by Supervisor M4mA d l f f' - Q t and was put to a roll call vote, the results of which were as follows:

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Supervisor Butler voted d Supervisor Eggleston voted d4y.

4 Supervisor Vaughan voted:

l Supervisor Burrell voted

! Supervisor Johnson voted: h I i

! Said resolution having received the approval of all members s

of the Board of Supervisors present, it was declared adopted by  ;

the Board of Supervisors of Claiborne County, Mississippi, on this the 22nd day'of July, 1985.

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1 tJ1vA-President A

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, , , , . . , _ - - - ,,.-~,m..s.-,..,yy.. .-y_%,.,_., ,v-r -w'-'--~~v-----'*v'e-er-ve'mem+--rr-=--~*+w-- -e~*--ww-r+---r*n- -v r +- - - - - -

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i i I, STELLA H. JENNINGS, Clerk of the Chancery Court I and Clerk of the Board of Supervisors, in and for.Claiborne i

County, Mississippi, do hereby certify that the above and foregoing is a,just, true and perfect copy of a Resolution of the said Board of Supervisors, made and entered on July 22,

! 1985 at the July term thereof, A. D. 1985, as the same appears of record in the Board of Supervisbrs' Minute Book No. ,

Page , _.

Given under my hand and official seal of said Board r I day of September, I

of Supervisors, at Port Gibson, this JJ j 1985.

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As M wd v ci. fax &

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, O. :cy, .

9:ts:: .s. E :: Y E *.* : : ?. a 'J : a . Ei.,i CI j

ra E,wreas c: se iwt.c Con:re. . O

. /@ @ @.'tj P.O. Ben 1C325  !. 2; k 5

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• sist .;acason. Mississicci 392C9 l ... _ 1

't , 1, / (601)961-5171 4 #

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August 13, 1985 i -

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Claiborne County Board of Supervisors Claiborne County Cmrthouse Port Gibson, Mississippi 39250 -'

1 South Mississippi Electric Pwer Association P.O. Box 1589 i[ Highway 49 North ,

j Hattiesburg, Mississippi 39401 ,

l, Gentlemen:

We have received the inforcation submitted by yoJ relating to the air and water

i. pollution control facilities and related sewage and solid waste disposal facilities which Middle South Energy, Inc. proposes to provide at Grand Gulf j

Nuclear Station in Claiborne County, Mississippi, which are described generally i

in the attachment hereto.

Based upon our review of the foregoing, we hereby certify that the proposed

- pollution control facilities and related sewage and solid waste disposal

' facilities are necessary and that the design and construction thereof will result in the elimination, mitigation, and/or prevention of air and water

, pollution.

i We further certify that the facilities, as designed, are in furtherance of the purpose of abating and controlling' atmospheric pollutants and contaminants or water pollution.

j This letter is not intended as an adjudication by the Mississippi Departrent of 4 Natural Resources, Bureau of Pollution Control, that the proposed facilities will in fact result in the required level of control.

I Very truly yours, ') - -

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Charles H. Chisolm i

Bureau Director j

i CHC:sr Attachrent j

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EXH'EIT A 4

Licuid Waste Svstems A.

Portion of Reactor Water Cleanup Sy' stem which collects backwash liquid waste which would normally go to drains, and which includes pumps, heat exchangers, filter demineralizers, strainets .and- tanks -necessary to provide continuous purifying treatment of the reactor water.

B.

Portion of the Liquid Radwaste System which includes three primary subsystems (equipment drains, floor drains, and chemical waste processing) which are designed to control, collect, store, process, treat and dispose of low-level radioactive liquid wastes.

C. Portion of Auxiliary Building allocable to liquid waste systems.

[ D.

Portion of Radwaste Building allocable to liquid waste systems.

E.

Chemical and waste storage basins, constructed of ainforced concrete with a two-foot curb around all sides, and surrounded oy a chain link fence, used to collect . and store, before shipment and disposal off-site, containerized non-radioactive liquid waste consisting of cleaning solvents, laboratory chemical wastes, oils, and similar liquid wastes.

F. Circulating Water System, consisting of facilities for control of thermal pollution of the Mississippi River through the use of a closed-loop natural draft cooling tower, a pumphouse,

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tiewdown and ma<e-up water ' a r i l l. t e s , s:dium nypc:..lc t : t e _ and I

sulphuri: acid removal systems, assceiate'd plumbing and electrical equipment, and related facilities,,to provide cooling water to the condenser which in turn condenses exhaust steam discharged from the turbine.

G. Radial Well System, comprised of facilities to provide additional makeup water to the circulating water system, including a large reinforced concrete caisson, installed vertically, that extends into the alluvial sediments adjacent to the Mississippi River. Cooling tower make-up water will be derived from the Mississippi by means of induced filtratica and will enter the caissons through horizontal screened pipes extending radially from the caisson into the alluvial sediments.

H. Site Runoff Waste Water Treatment System, consisting of concrete canals, catch basins, culverts, manholes, piping, chutes, and chute spillways that collect waste water and convey it to Sediment Basins A & B, and the earthesn dams with concrete weirs that form the perimeter of the Se<Jiment Basins. These i

basins remove suspended solids by a settling process and also provide for storage and monitoring of the waste water.

I.

Oily Waste System which will collect nonradioactive oily wastes from stablizing sumps in several buildings.

J.

Chemical Waste System which will collect and neutralize chemical wastes contained in nonradioactive water frem the make up water treatment system and blev-down f acilities.

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f Casecus Waste Svs:e s A.

i Caseous Radwaste Management System designed to centrol

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i air pollution, consisting of 'an off gas System, a Radwaste 5

Building Filter System, an Auxiliary Building Filter System and a ,

containment Building Filter system. Includes extraus t filters, fans, ducts, i radiation monitors and related facilities to collect, filter and discharge exhaust air.

r 3.

i Portion of the Of f-Cas Building, the Radwaste Building and the Auxiliary Building allocable to the Gaseous Radwaste

. Management System.

C.

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Portion of the Turbine Building Ventilation System 3

consisting of heating, ventilation, and cooling systems designed to provide an environment with controlled temperature and humidity.

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Included in the financeable cost is the exhaust +

i collection, and exhaust dvetwork, exhaust filters, fans and radiation monitors.

D.

Sky-shine Shielding System consisting of structures i designed r i

to control air pollution by limiting offsite emissions '

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• of direct radiation from the Plant.

J i Sewage and Solid Waste Systems j i A. i Portion of Radwaste Building allocable to solid waste i systems that collect, store, package, and prepare radioactive  !

solid waste and solidified liquid waste for offsite shipment and permanent disposal.

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Spent f uel storage and handling f acilities ::nsis:1..g f l

i portion of ecst of spent fuel transfer canal, spent fuel peel, i

, liners and high density fuel storage racks in the spent fuel i pool, additional spent fuel pool cooling and cleaning capacity, 3 spent 1 fuel platform, shipping cask pool, spent fuel cask handling I

area, cask washdown area, 150 ton crane, spen

• fuel cask leading '

bay and equipment and railroad spur f rom Auxiliary Building to l main track, 6 j

and related portion of Auxiliary,8uilding allocable to spent fuel storage and handling facilities.  ;

C.

Facilities for Energy Services Center , designed to treat and dispose of sewage which facilities consist of all sanitary ,

waste piping in Energy Services center and sanitary vaste pipe j _

i from Center to Treatment Plant. i D.

Interim Radwaste Handling racility, including a metal '

building and its associated equipment, to collect, store, '

package, and prepare

solid low-level radioactive waste,

! consisting of radwaste and solidified liquid waste, for shipment  ;

I 1 off-site.

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Environmental Monitoring racility  !

A. Environmental Monitoring I,

racility, which gathers 1

1 biological, soil, air, and water samples from points both close .

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i to and more distant from the Plant, and subjects them to l analyses, and includes the Environmental Surveillance racility,

! consisting j of. office and laboratory space used for sample l i preparation and analysis, sample storage, and hazardous waste j f

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tecessing, whien meniters, analyses a .d eva .a

es int performance of the air and water pollutlen centrol facilities and sclid waste disposal facilities.

B. Salt Deposition Analyses, censis tiing of the ecsts incurred for sample analyses and statistical analyses of samples ,

taken frem the area around the cooling ' tower to determine environmental releases.

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