ML20199E856

Partially Released Commission Paper Recommending Issuance of Order to Permit Proposed Sale & Leaseback Transaction for Refinancing Util Interest in Unit 1

ML20199E856
Person / Time
Site:	Palo Verde, 05000000
Issue date:	11/22/1985
From:	Plaine H NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:
Shared Package
ML20199E476	List: IA-85-826, Partially Released Commission Paper Recommending NRC Response to co-owner Petition for Exemption from License Fee for Withdrawn CP Be in Form of Order.Draft Order Encl ML20199E472 ML20199E856 ML20199E864
References
FOIA-85-826, TASK-AIA, TASK-SE SECY-85-367A, SECY-85-367A-01, SECY-85-367A-1, NUDOCS 8603270462
Download: ML20199E856 (23)

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ADJUDICATORY ISSUE (Affirmation)

November 22, 1985 SECY-85-367A For: The Commissioners .

From: Herzel H. E. Plaine General Counsel -  !

Subject:

PUBLIC SERVICE COMPANY 0F NEW MEXICO'S PROPOSED SALE AND LEASEBACK TRANSACTION FOR REFINANCING ITS INTEREST IN PALO-VERDE 1 Facility:' Palo Verde Nuclear Generating Station (Unit 1)

Prior History: SECY-85-350 and SECY-85-367

Purpose:

f Summary:

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Contact:

Marjorie Nordlinger, OGC x41493 8603270462 860206 PDR FOIA RADER85-826 PDR 1 I

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. J Discussion: In its papers, the staff has described the proposed sale and leaseback arrangement. Public notice of the pendency of the matter, a description of the proposal, and an opportunity for comment and hearing were provided on

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November 5, 1985. 50 Fed. Reg. 45955 (Attachment 1). That notice asserted w.,_ , - -

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. 3 that grant of the application would not require preparation of an environmental impact statement or appraisal under NEPA, and that any license amendment that might be required would involve no significant hazards determination.

Accordingly,.the posture of this matter is such that the license may be amended l5 ,

as necessary by the staf.f at the Commission's direction, if the Commission wishes to grant'the application.1 OGC has worked closely with ELD in considering this matter. On one occa-sion OGC, along with the cognizant ELD attorney, met at length with representa-tives of the proponents of the applica-tion for the purpose of probing the 1

We express no view regarding the effect of the arrangement on taxpayers, consumers, and utility investors.

We regard these matters as within the province of other Federal and state agencies.

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4 arrangements. Our interest was to ascertain whether the arrangement might have any adverse effect on safety, antitrust, or other matters within NRC's I

regulatory responsibility.

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Attachments:

1. Federal Register Notice

2. Draft order I

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19 Commissioners' comments should'be provided directly to'the Office of the Secretary by c.o.b. Monday, December 2, 1985.

Commission Staff Office comments, if any, should be submitted to the Commissioners NLT Wednesday, November 27, 1985, with an-information copy to the Office of the Secretary. If the paper is of such a nature that it requires additional time for analytical review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.

Affirmation will be scheduled as soon as possible after receipt of Commissioners' votes.

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Federal Register / Vcl. 50. No. 214 / Tuesday. N vimber 5.1985 / N:tices o]. . .

, , 45955 i radiological releases will not be greater NRC Form 212."Quesfications Acme Notice of the Office of than previously determined nor does the investigation. Professioner; Otse - Management and Budget revtew of ~ -

! proposed exseption otherwise affect Review ofInformation Cocoction information collection.

radiological plant effluents, or any Activities -

"p XpmumsA suesssaav:h Nuclear Regulatory

f, dow Acescv

Nuclear Regulatory Commission has recently submitted to nonradiological plant effluents and has Commission. the Of5ce of Managent and Budget no other environmentalimpact. Acme Nodca d the OfRce g . (M for W the hng proposal

! Therefore. & Commission concludes Management and Budget revi6w of for the coUection of information under information couecdos. the provisions of the Paperwork a

that there are no significant radiological Reduction Act(44 U.S.C. Chapter 35).

, w nonradiological enwonmental suessaany:b Nuclear Regulatory impacts associated with the proposed 1. Type of submission. new, revision.

Commission has recently submitted to or extension: Extension.

exemption.Since we have concluded the OfBee of Management and Budget that there is no measurable 2.h utle of b idormadon (OMB) for review the following proposal couection

" Qualifications Investigation. l

! environmentalimpact associated with for the conection ofinformation and=" ~ '

. the proposed exemption. any alternative the provisions of the Paperwork Clerical /Setarial".

3.The form number if applicable: NRC 8

such as literal compliance with section Reduction Act (44 U.S.C. Chapter 3g). Form 212A.

111.D.2(b)(iii) will eihr have no 1. Type of submission, new. revision 4. How often the coUection is environmentalimpact or greater or extension: Extension. required: When an applicant is environmental impact. The principal 2.N title of the information considered for employment.

alternative to b exemption would be to conection: QuallBeations Investigation. - 5.Who will be required or ja ked to

. require literal compliance with section Professional, riport: Previous supervisors aB'd III.D.2(b)(iii) of Appendix J 1010 CFR 3.b form number if applicable:NRC ' personel acquaintances.

Part sa This would r'equire Big Rock Form 212. 8. An estimate of the number of Point to leak. test the containment 4.How often the collection is ~ responses: 2.000. -

airlocks every 3 days.Such testing -voquired: when an applicant is -

7. An estimate of the total number of would not enhance the protection of the considered for employment. hoars needed to complete the environment. 5. Who wiu be required or asked to requirement or request: 500. -

mpwt Pmvious superviers and 8. Secdon 3504(h) Pub. I.96-511 does Ntarnative um ofRaourew:& Penon.al acqualatences.

proposed exemption involves no use of not a .

resources not previously considered. An ate n eamn W & Infamadon used k responses: 2000, determine qualifications and suitability 5ncies andh ConsM The 7. An estimate of the total cuanber of . of app!!cuate for employment with the NRC sta5 has reviewed the licensee a bours needed to complete the request as Namaad above4 h NRC NRC.

requirement or requeet: 300. .nn Copies of b submittal will staff did not consult any other agences 8. Secdon 3504(h) Pub. I.9H11 does r Panh not app 5 y g gg %g ,

copying for a fee at the NRC Public Finding of No SigniAcast Isopect & Ahetract Infonnanon used to Document Room.1717 H Street. N.W.,

determine qualifications and suitability The Commission has determined A of applicants for employment with NRC. W*shinst "' DC lo Prepare an environmentalimpect , g gg g Poe runThen neronesATions coerTACT:

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statement for the proposed exemption. Comments and questions should be be made avallable forinepection or directed to the OMB reviewer, Jefferson Based up a b fomgoing copying for a fee at the NRC Public environmt al assenment,we conclude pom B.Hiu (202)306-7340, Room.1717 H Street.NW, that the proposed action wiH not have a Washington. DC 20585. . NRC Clearance Of5cer R. Stephen significant effect on b quality of the ,,, ,y,,ugn ,,,,,,,,,,,,, go,,,,g,. Scott.(301) 4ez-45at human environment. Deted at setheeds. Mary'.and, this 2sth day Comments and queedoes should be For further details with respost to this directed to the OMB reviewer. [eNereos Fm d a Nuclear Regulatory Co==l==ca. s action. see request for exemptica dated B. HtH. (202) 306-7340.

September 15.1975 and supplannestal NRC C'*.arance OfBeer R. Stephen ""'I' I

submittals dated October la 1980 and Duweror. OfyIce ofAd=% l Scott. (301] 482-45e5.

. February 2.1964, which are weitable for Deted at Betheeds. Maryland, this 20th day I *#" * * ' " *"I l public inspection at the Commission's of October tees. emisescosa m eeea '

I Public Document Room.1717 H Street. For the Ndeer Reydatory ca.--

NW. Weshington. DC, and at North Pendda G.Neary.

l Central Michigan CoUege.1515 Hrivard (Deciest16e.3738 bl

% gyye,,fm Street. Petoskey. Michigan 4Feas. Artsons Pul Se Servlee Ca.;

l (FR Doc. m FUed 11% w 4 '

Deted at Se*aada Maryland, this 2sth day seAme coes nes ee.e Considereden of en aW be of October toes. Appresel of a Proposed Transfer of For the Nucfeer Regulasse5 Commission. Intemete Under a Proposed Sale and NAC Porm 212A,"Queefloetione. 8 aaaa*=* Treneocoon, Proposed no Donale M.W Slytlecant Hazards Determination, I.nr 2- .Clericel/Secreterter'; .

A ssistant Directorfor Safety Aueument.

Division of f.> censing Office of%cles' 06h8 & ofInformados fan " n** Soncitaden of Connenente and ReactorRegvlotion M W kr Hearing FR Doc. 86-2538o Filed 11-4-8&&45eml Amescv:U.S' Nucleer Regulatory The Nuc!est Regulatory Commisalon

. a u s.*coes rse**+ = ,

Commlaston. Is considering an application dated -

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'.' Federal Register / Vol. 50. No. 7.14 / Tuesday. November 5.1966 / Notices October IL toes. !!!ed by Anzona Pubiac the PNM. as a lassee rather than an essentially is e recogninoa ef the Service Company (APS) on behalf of owner, and the obe present lice- conversion of PNM's naht of pomenion Public Service Company of New Mexico of PVNCS Unit 1. APS would continue of an interest in PVNGS Unit 1 from a to be the sole !!censee authorized to um fee interest to a leasehold. does not (PNM) and b First National Bank of Boston. as Owner Trustee (Owner and operato PVNCS Unit 1. present an unreviewed environmental Trustee). for the luuance of an order It is proposed that throughout the ter a impact and that no environmental under 10 CDL Part 50 appmving (l) the of the leaseholds PNM will have the full impact atanment or appraisal need be transfer by PNM to the Owner Trustee and exclusive authority and prepared in acting upon the application.

cf the fee interest and (ii) the responsibdity to exarcise and perforas No determination has been made of simultaneous tranafar by the Trustw all of the righs and duties of a whether granting the request would back to PNM of a long4erm (2sw years. Participant in PVNCS under the ANPP require an amendmant or transfer of epproximately) posu seory lea sehold Participation Agreement. PNM will also license NPF-41. Should a license interest in a major protion of PNM's la2 retain reeponsibthty for the papnent of amendment be necessary, the percent interesa in Palo Verde Nuclear its shan of the opersting and Commission will have made findings Generating Seation (PVNGS) Unit 1 as maintenance wim and costs of required by the Atomic Energy Act of contemplated in the proposed sale and cap {talimm ws during the term of 1954. amended (the Act) and the leanback financas tr=ruartion b leasebolds and thereafter,in the Commission's regulations.

descnbed in the application. Under the absence of other Commission action. for The Commission has made a proposed proposed transaction. it is represented la2 percent of the oosts of determination that an amendment. if th:t PNM would remain le possasion of decommissioning aseodated with needed, would involve no significant its present interests in PVNCS uruw a PVNGS Un6t 1. hazards consideration. Under the leasehold tother than by vntue of ne application proposee that the Commfesion's reguistions in 10 CFR cwnership. order authorizing b transfere 5092, this means that operation of b Under Facility Operating ile=a== contemplated by the sale and leasebeck facility in accordance with the proposed NPF-41. tanced June 1.1986. PNM. APB transaction incorporate conditions (a) amendments would not (1)Irwolve a and other named utilities are licecsed to that the rights acquimd by b Owner significant inasase tn the probabihty or possese PVNCS Umt t and APS is Trustee and any equjty investor and any consequences of so acddent previously licensed to use and operate b facihty. successors and assigne (toclading any evalastad: or (2) create 6 possibuity of PVNCS Unit 1is part of a thrn amt mortgagee or secured party of eoch a new or different kind of acodent from PVNCS project jointly owned by tboos Owner Trustee)In and to PVNC8 Unit 1 any acddent previously evaluated; or (3) ttilities, with PNM having a 10.2 percent may be exarased only in compliaans involve a signmeant reerdna in a interest in PVNCS Unit 1 and the with and sob}ect to the same margm of safety.

PVNCS pectects commna fachties. requirements and restrictions as would na applicant's request la for approval Under a Arizona Nocieer Power Protect apply to PNM pursuant to b provisions of the sale andleaseback transaction

- (ANPP) Participation Agreement, each of the Ucense, the Atomic Energy Act of. with PNM remaining in possession plits _ ..

owner of the PVNCS project is obligated 1954, as amended, and the reguietions present interests in PVNCS and to pay a share, equal to its owcarshsp twued by the Commission porouant to continuing to be obligated to pay its interest. of all costs of construaion. the Act (b) that neither the Owner share of all costs of construction.

mistecance operation. capital Trustee por any equity lavestor nor any maintetunra operstion, capstal improvements and decommissinn=wi of of hir respective succenors or awigns improvements and decommissioning.

each of the PVNGS units. and entitled to may take poseewies of anylaterest in h Owner Trustee would not have any share equal to its ownership Interests of PVNCS I pdor to either (1) the i===a nn= right of possession in, absent further the electrical output of the units. APS la of a Beanse frous the Camm4==aa= license amendment. or control over cubrized to act as agent for the other authne'ving ench posaission or (2) the PVNCS Unit 1. APS would be the sole licensees of PVNCS Unit 1. and has tranafar of the Ucanse ==hrtag PNht liceneee authorized to use and operate cxchistve responsibility and control over to possese an internet in FYNC8 Unit 1 the faci!!ty. Besed oc the above. and the physical construction. maintenance upos an application Soe tr===l== of such under b criteria in 10 CPR 50.92(c) the cod operation of the fedifty. Ucense fHed pursuant to 10 CFR 50,a0 Staff proposed to determine,if a liceme APS has filed the subject appBeation 04; and (c} that nan == b Ownee asse ndm=nt is necessary, that on behalf of PNM seeking Comm+=alon's Trustee nor any eqmay invwtor nor any amenA=mt to the hcease would not approval for PNM to sell n the Owner of their respective successors and involve sesmificant hazards Trustee for the benefit of equity assigns need become a licensee under coesiderations.

Investors, all or a portion of FNM's 10.2 6 Ucanse unless and tmtil the b f%-i== ion La seeking public percent ownership intarut la PVNC8 Commission shall have taeued as comments ce the application and this Unit I and all or a proportionata share amendment of such Ucecae authorizing proposed detsemmation. Any enrnmaata of one. third of PNM's interest in the such Owner Trustee, equity Investor, received witlan 30 deymalter the date of PVNCS project's enmmne fac18 ties with sucessor or assign to take possession of publication of this sonce will be the Owner Trustee simultaneously an Interat in PVNCS Unit 1 or sheD considered in malmo, any final Ircoing back these toterests to PNM for have approved a treas(er o(PNM's determination, m Commluion will not a basic term of about 23% years wtth Ucense to such Owner Trueese, aquetF normeBy make e final determination rights of renewal and repurchase.h inventor aer=aana or assign. la unten it recalves a request for a opphcation does not request any addition. the Commtamion may also he artng.

emendment or transfer of b Heense incorports, each mber conditions or Comments should be aMreened to the NPF-41 es it is not requested that b amend b liconee in wech manner se ft Rules and Records Branch Division of Owner Trustee beve any right of beMeve, necewery to protect b pubtle Rules and Records. Osce of possession in. absent e futher liceme health, safety and laternt. Adminf stration. U.S. Neclear Regula tory amaadment, or control over PVNCS Unit ne application also asserts that the Commiwien. Wa shington. DC 20u5.

1. hee ryhts would remain solely in grant of the rettof requested.wLich Comments may also be delivered to e_ _ , . _ _ --..,_.e,..-n._,____.m._,__,,,.. , , _ , _ _

- I ' Federal Register / Vcl. 50. No. 214 / Tu:sdsy. Nevsmbtr 5.1985 / N ticas 45957 s

' Room 400lL Maryland National Bank sought to be litigated in the matter and Washington. DC. by the above date.

. Budding.Bethesda Maryload from 3:15 the bases for each contention set forth Where petitions are Aled during the last 9 a.m. to 520 p.m. Monday through Friday. with reasonable spectAcity. Contentions ten (10) days of the nonce period it is P Further, although no determination shau be limited to matters within the requested that the petitioner proraptly so l has been made to hold hearman on the scope of the amendments under inform the r%==waiaa by a toll. free subject application, by Decc aber 5. consideration. A petitioner who fails to telephone call to Western Union at (sool i

1905, the licensee may Sie a request for & such a supplement which sationes 325-4000 (in Missouri (800l 342-4700).

j e hearing with respect to issuance of the these requirements with respect to at & Western Union operator should be i

amendment to the subject facility lease one contention will not be given Datagram Identincation Number l operating licensee and any person permitted to participate as a party. 3737 and the following message addrese l whose interest may be afected by this Those permitted to latervene become to Edward J. Butcher:(petitioner's name i proceedmg and who wishes to es to the proceedag, subject to any and telephone number) (date petism participate as a party in the proceeding ' 'tations la the order granting leave to was mailed). (plant name), and l

j must file a written petition for leave to intervene and have the :;; Mty to (publication date and page numiser Wa*.

intervene in any hearings which may be partidpete Adly la the conduct of the this Federal Register nonce). A copy of

. held. Request for a hearing and pentions hearing. including the opportunity to the petition shold also be sont to the l present evidence and crose examine Executive 1sgal Director. U.S. Nuclear i

for leave to intervene shau be Aled in accordance with the co==3==s==*s witneseen. Regulatory Co==iaa'a= Washmston.

"Rulee of Prectice for Domestic If a hearing is requested the DC 20555, and to Arthur C. Gehr. Snell a Ucensing Proceedmas" la to CFR Part 2. Commission wtH make a flaal Wilmer. 3100 Valley Bank Center.

If a request for a hearing or ptition for determinados on the iseos of no Phoenix. AZ 85073.

leave to intervene la Sled by the above signincaat hazards consideration and Nontimely Slings of petitions for leave j; date and it is deternmed that a hearing whether heartage are necessary.The to intervene, amended pestions.

be held the Ce==h=% or en A

omic Anal determination wGl serve to decide - espplemental petidone and/or req aests i Sefety and ucensing Board, designated when the hearing, if any,is held. for heart 3 will not be entertained i by :he r a==iamaa or by the cAmirmaa If b Real determination le that the absent a determination by the of the AtomicSafety andIwaaaeng ammid==at request favolves se

• Commission, the proelding ofBcer or the j( Board Panel, will rule on the request sigmScant hazards considerettee. the Atomic Safety and ucensing Board

and/or petition and the Secretary or the Co==f aanos may issue the amendmente designated to rule on the pention and/or

! designated Atomic Safety and ucename and make them efective, requat. tast the petitioner has made a Board willlasue a notice of hearing or notwithstanding the request for a substantial showing of good cause for lJ an appropriate order. hearing. Any hearing held would take the granting of a late petiden and/or

!. As required by to OR 2.714 a place after inseance of b aansedesats. request.ht determination will be

! petition for leave to latervene shau set if the Haal determinettom is that a based upon a h=Imarias of the factors h; forth with particularity the interest of license amendment involving a speci8ed la te OR 2.714(a)(2)(iHv) and jj the petidonerla the proceeding, and signi8 cant hazards consideration is 2.714(d).

• i h how that interest maybe gffected by b h For further details with respect to this results of the proceeding.The petition necessary, place before % inseance earing held of any would take acdon ese b apphcedon dated

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should spedAcally explain the reasons why intervention should be permitted amendment.

NormaHy. b Commission wGl not October te, tees, which to available for public 8-- da= at the ra==i==3aa's with particular reference to the issue the amendments ir til the Public Doi: ament Room,1717 H Street.

. following factore:(1).The nature of the expiretion of the 30 day aotico period. NW. Washington. DC, and at the loca!

[ petitioner's right under the Act to be made a party to the proceeding:(2) the However, should circumstances change public document room at the Phoenix during b notics period such that fattere Public Ubrary.12 E.McDoweu Road.

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nature and extent of the petitioner's to act la e timely way would result for Phoenix. AZagosa.

! property, financial or other interest la ===ple. in derating or sheidews of the -

. e, Deted et asesedaataryland. his 1st day the proceedms: and (3) b poselble ~ faciuty. therCommise6am may leems the e effect of any order which may be license ===ad==ete before the emoweber. tem i entered in the proceeding on the expiration of the so. day aedes period. For the Nuclur ilegulatory Comeuemen.

l petitioner's interest. The petition abould provided that its Saal determinatica la Freak J.Monda.

identify the spa 4h a*pect(s) of the that the ====d== ate levolve se Depery Duecaer. Drrisees of.-- - - %. Of)Vm subject matter of the proceeding as to =4==+6=ae hasards considerstica.The , efMarJoerAescerAsseAssion which petitioner wishes to intervens. Saal determination wtB consider aR (m Dec.sweert rund it.4.am aos eel Any person who has tGed a petition for public and State -to rooseved. ause ossereum.m e leave to latervene or who has been Should the r%==a==% take thee asson, admitted as a party may amend the it will publish a modes of Isseance and j petition without requesting leaveof the provide for opportonity for a heartag yg Board up to fifteen (18) days prior to the after la===- The e--a=='a= exposee . ,

first prehearing conference scheduled la that the need to take this aseen wtu m

! the proceeding, but such an amended occur very fairegesesty. . .

I Petition must satisfy the ; f -n- A rquest for a hearing or a petition for Proposed Cftence he Hours of Cnaster'io requirements described abows. leave to latervene must be fued with the g ,,qce etpiecfte,DW Not later than Afteen (15) days prior to Secretary of ther a==1==ta= U.S.

, the Rret prehearing conference Nuclear Regulatory t'a==8==Aa= aesscv: Customs Service. Treasury.

l scheduled in the proceeding, a Washington, DC 30865. Anendom- acTtost Notice of proposed change in i peititioner shall Rie a supplement to the Docketing and Service Branch, or mey hours of service: solidtation of I Petition to intervene which must include be delivered to the Commiselon*e Pubic '**"'"

l e list of the contentions which are Document Roorn.1717 H Street. NW.

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