ML20203M877
| ML20203M877 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 09/02/1986 |
| From: | Kingsley O MISSISSIPPI POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20203M876 | List: |
| References | |
| TAC-62754, NUDOCS 8609050113 | |
| Download: ML20203M877 (21) | |
Text
,-
BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE NO. NPF-29 DOCKET l10. 50-416 IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and MIDDLE SOUTH ENERGY, INC.
and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION AFFIRMATION I, 0. D. Kingsley, Jr. , being duly sworn, stated that I am Vice President, Nuclear Operations of Mississippi Power & Light Company; that I am authorized by Mississippi
& Light Company, Fower System Energy & Light Inc.
Resources, Company (onMiddle formerly behalfSouth of Mississippi Energy, Power Inc.), and South Mississippi Electric Power Association to sign and file with the Nuclear Regulatory Commission, this application for amendment of the Operating License of the Grand Gulf Nuclear Station; that I signed this application as Vice President, Nuclear Operations of Mississippi Power & Light Company; and that the statements made and the matters set fo therein are true and correct to the best of my knowledge, informatio beliet.
STATE OF MISSISSIPPI COUNTY OF HINDS in and for the County andSUBSCRIBED AND SWORN State above named, this Rhd T0daybefore of ,me, a Notary Puhlic, ,d1986.
5p1777/hr p (SEAL) e60905o113 e609o2 DR ADOCK 0500 6 p NotgPublic My commission expires:
& 2 7, /ff]
J13AECM86082201 - 5
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
-In the Matter of
)
-MISSISSIPPI POWER & LIGHT )
COMPANY, et al. ) Docket No. 50-416
)
(Grand Gulf Nuclear Station, )
Unit No. 1) )
APPLICATION TO AMEND FACILITY OPERATING LICENSE NO. NPF-29 Mississippi Power & Light Company ("MP&L"), Middle. South Energy, Inc. ("MSE"), and South Mississippi Electric Power Association ("SMEPA") (collectively " Joint Licensees") are the holders of Facility Operating License No. NPF-29 for Grand Gulf Nuclear Station ("GGNS"), Unit 1. The operating license presently authorizes MSE and SMEPA to possess GGNS as joint owners and authorizes MP&L to possess, use and operate Unit 1 in accordance with the terms and conditions of the operating licenso.
Effective July 28, 1986, Middle South Energy, Inc. was renamed and reconstituted as a new nuclear generating company.
The newly named company, System Energy Resources Inc.
("SERI"), remains a subsidiary of Middle South Utilities, Inc.
Upon necessary regulatory approvals, and transfer of personnel, SERI, as majority owner of GGNS Unit 1, will succeed MP&L as operator of GGNS Unit 1. This application J10 MISC 860814 - 1
2-requests that the NRC amend Operating License No. NPF-29 to authorize changing the name of MSE in the license to SERI as a licensee authorized to possess GGNS Unit 1 and the substitution of SERI for MP&L as the licensee authorized to possess, use and operate GGNS Unit 1.
Ownership of GGNS Unit I will remain unchanged, with SMEPA ,
retaining its ten percent interest and SERI- (formerly called MSE) retaining its ninety percent ownership interest. The MP&L nuc' lear organization (plant and headquarters) currently operating and responsible for GGNS Unit I will be transferred virtually intact to SERI, which will then assume exclusive responsibility for and control over cperation and maintenance of the facility.
Pursuant to 10 C.F.R. $$50.80 and 50.90, Joint Licensees hereby request that the Nuclear Regulatory Commission amend Operating License No. .JPF-29 to change the name of MSE to SERI in the license as majority owner of GGNS Unit 1 and to substitute SERI for MP&L as operator of GGNS Unit 1.
Specifically, Joint Licensees request that-4 (1) Pursuant to Section 103 of the Atomic Energy Act of 1954 as amended ("the Act")
and 10 C.F.R. Part 50 " Domestic Licensing of Production and Utilization Facilities,"
System Energy Resources, Inc. be authorized to possess, use and operate GGNS Unit 1 at the designated location in Claiborne
- County, Mississippi, in accordance with the procedures and limitations set forth in the operating license; 1/ The proposed changes to the GGNS Offsite Organization chart and the Operating License to reflect the designation of SERI as a nuclear generating company for<GGNS Unit 1
- are included in Attachments 1 and 2 respectively.
J10 MISC 860814 - 2
(2) System Energy Resources, Inc., pursuant to the Act and 10 C.F.R. Part 70, be authorized to receive, possess and use at any time special nuclear material as
-reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (3) System Energy Resources, Inc., pursuant to the Act and 10 C.F.R. Parts 30, 40 and 70, be authorized to receive, possess, and use at any time any by-product, source and special nuclear material as sealed neutron sources fcr reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required;
_ (4) System Energy Resources, Inc., pursuant to the Act and 10 C.F.R. Parts 30, 40 and 70, be authorized to receive, possess, and use in amounts as required any by-product, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (5) System Energy kesources, Inc., pursuant to the Act and 10 C.F.R. Parts 30, 40 and 70, be authorized to possess, but not separate, such by product and special nuclear materials as may be produced by the operation of GGNS Unit 1; (6) Mississippi Power & Light Company having been replaced by System Energy Resources, Inc.,
as operator of GGNS Unit 1 and thus deleted i
as a licensee for GGNS Unit 1, the antitrust conditions in the license applicable to Mississippi Power & Light Company be deleted; and (7) Middle South Energy, Inc. having been renamed System Energy Resources, Inc., the references to MSE also be deleted from License No. NPF-29.
Set forth below is the information in support of this application.
J10 MISC 860814 - 3
i I. GENERAL INFORMATION CONCERNING LICENSE AMENDMENT A. Name: System Energy Resources, Inc.
B. Address: Post Office Box 23054 i
Jackson, Mississippi 39215 C. Description of Business or Occupation-
)
SERI, formerly Middle South Energy, Inc. ("MSE"), is a a wholly owned subsidiary of Middle South Utilities, Inc.
("MSU"). MSE was formed in 1974 to construct, finance and own base-load generating units for the operating subsidiaries of MSU. To date, MSE's business has comprised owning and financing its ninety percent ownership interest in the Grand Gulf Nuclear Station. On July 22, 1986, the Boards of Directors of MSU and MSE took action to rename MSE as SERI as discussed above, and to authorize transferring to SERI all responsibility for the operation of GGNS Unit I now assigned to MP&L upon the receipt of necessary regulatory approvals.
I D. Organization and Management of Oparating Corporation:
] SERI is a corporation organized and existing under the laws of the State of Arkansas. Its principal office is located in Jackson, Mississippi.
All directors and principal officers of SERI are citizens of the United States. Their names and addresses are as fo11ows:2 4
2/ Additional directors (including outside directors) and officers may be named at a later date.
1 I.
i J10 MISC 860814 - 4
. _ ~ , _ _ . _ _ _ _ _ ._ _ . _ _ _ _ . _ _ .._.___ _ . _,_-- _ _ _ _ _ ___ __ _ _ _ _ , _ _.___. _.
-3 Directors Mr. E. A. Lupberger Chairman System Energy Resources, Inc.
225 Baronne Street New Orleans, Louisiana 70112 Mr. William Cavanaugh, III President and Chief' Executive Officer System Energy Resources, Inc.
Post Office Box 23054 Jackson, MS 39215 Mr. D. C. Lutken Chairman of the Board and Chief Executive Officer Mississippi Power & Light Company P. O. Box 1640 Jackson, MS 39215-1640 Mr. J. M. Cain President and Chief Executive Officer Louisiana Power & Light Company /
New Orleans Public Services, Inc.
Post Office Box 60340 New Orleans, Louisiana 70160 Mr. J. L. Haulden '
President and Chief Executive Officer Arkansas Power & Light Company Post Office Box 551 Little Rock, Arkansas 72203 Principal Officers Mr. William Cavanaugh, III President and Chief Executive Officer System Energy Resources, Inc.
Post Office Box 23054 Jackson, Mississippi 39215 Mr. Edwin Lupberger Chairman System Energy Resources, Inc.
225 Baronne Street New Orleans, Louisiana 70112 J10 MISC 860814 - 5 s
4 j Mr. R. Drake Keith Senior Vice President-Chief Financial Officer System Energy Resources, Inc.
- 225 Baronne Street New Orleans, Louisiana 70112
- Upon issuance of the operating license amendment, the >
following officers of MP&L will become officers of System Energy Resources, Inc.:
Mr. Oliver D. Kingsley, Jr.
, Vice President Nuclear Operations System Energy Resources, Inc.
Post Office Box 23054 Jackson, Mississippi 39215 Mr. Ted H. Cloninger Vice President Nuclear Engineering & Support System Energy Resources, Inc.
Post Office Box 23054 Jackson, Mississippi 39215 i E. Technical Qualifications I The technical qualifications of SERI to carry out its i
- responsibilities under the operating license, as amended, will be i
! the same as the technical qualifications of MP&L presently. MP&L l will continue to act as the operator of GGNS Unit 1, pending the f
amendment of the operating license. Upon issuance of the j amendment, the agency agreement between SERI and MP&L under which l MP&L is authorized to operate GGNS Unit 1 on behalf of SERI will be terminated and the MP&L nuclear organization, including the l
, Nuclear Operations and Nuclear Engineering & Support Departments (see GGNS Unit 1 Technical Specifications Figure 6.2.1-1, Offsite Organization, attached hereto as part of Attachment 1), will be transferred to and employed by SERI, which currently has no I
l I
i J10 MISC 860814 - 6 l
i 4
i employees other than certain officers serving in a dual capacity, j
, Thus, the same MP&L organization and staff that are currently '
responsib1'e for operating GGNS Unit I will continue those responsibilities in the employ of SERI. In addition, all necessary support functions such as finance, administration, j legal, communications, internal auditing, purchasing, contract '
1 l administration and security will be integral to and directly i
employed by SERI.
- Attachment I hereto identifies proposed modifications to
?
the GGNS Unit 1 Technical Specffications including Figure 6.2.1-1, Offsite Organization. Attachment 2 identifies proposed modifications to the operating license for GGNS Unit Ij !
- 1. The only change between the current and proposed structure for plant operations and offsite nuclear support is a change in title of the senior officer from President and Chief Operating Officer ;
} of MP&L to President and Chief Executive Officer of SERI. The 1 duties of the position will now be limited to those necessary j for the operation and maintenance of GGNS Unit 1 and the management of the construction of GGNS Unit 2.3 All duties and 4
responsibilities for the remaining positions shown on Attachment 1 t
remain unchanged. The President and Chief Executive Officer of f 1 SER1 will report directly to the Chairman of the Board of SERI.
t i 3/ The Joint Licensees have filed under separate cover an application to the NRC to amend the GGNS Unit 2 construction permit (CPPR-119) to conform that permit to these changes in responsibilities, l
) J10 MISC 860814 - 7 1
i_-_______ - ----
8-There will be no change in the people who operate GGNS Unit 1 as a result of the change. Therefore, implementation of the change proposed by this application will cause no adverse change in the current technical qualifications.
In fact, Joint Licensees believe that the transfer of operational responsibility for GGNS Unit 1 to SERI will provide benefits inherent in en integrated nuclear generating company, including the concentration of leadership, management, financial, engineering and operating talents solely on nuclear plant operations. This initiative is thus consistent with the views and perspectives of the Nuclear Regulatory Commission in recent years, calling for strong and focused management of power reactor operations.
F. Financial Qualifications Pursuant to contractual agreements between MSE and SMEPA as joint owners, all costs for the operation, maintenance, repair, decontamination and decommissioning of GGNS Unit 1 incurred or accrued are liabilities of the joint owners when incurred or accrued and are borne in proportion to their ownership interests in GGNS. This arrangement governing the allocation and payment of GGNS costs will continue in effect upon substitution of the name SER1 for MSE on the GGNS Unit 1 operating license.
J10 MISC 860814 - 8
9 SERI is a generating subsidiary of Middle South Utilities.
Inc., a registered public utility holding company. It is an entity that generates electricity and sells it at wholesale to the operating companies of the Middle South System at rates established by the Federal Energy Regulatory Commission.
Therefore, SERI is an " electric utility" as defined in 10 C.F.R. 550.2 and is excepted frc.m the requirements of 10 C.F.R. 550.33(f).
G. Statement of Purposes for Which Transfer is Requested The Joint Licensees request that the authority under the operating license to operate GGNS Unit 1 be transferred from MP&L to SERI and that MP&L be deleted as a licensee of the unit. Benefits of the requested change include the following:
(1) All executives of SERI will be able to focus full attention on the safe and efficient operation of GGNS Unit 1. Duties associated with the management of non-nuclear activities will be eliminated for these executives. Management will retain all authority commensurate with their responsibility to operate SER1 as a nuclear generating company and will be involved on a full-time basis in day-to-day nuclear operations.
(2) Salary structures, carent paths, policies, and procedures for nuclear employees of SERI will be separate and distinct from MP&L's non-nuclear employees. This will permit nuclear msnagers to focus entirely upon the special needs, qualifications and requiremerts of nuclear employees. Human resource and compensation policies tailored exclusively to nuclear operations will allow SERI to be competitive in the market for J10 MISC 860814 - 9
i f
ji d skilled nuclear professionals without directly influencing, or being bound by, personnel policies and procedures governing non-nuclear personnel. The ability to
]; attract superior nuclear talent and retain quality individuals once recruited will have 1
] a direct positive impact on the quality of 1
GGNS operations.
(3) Certain corporate support functions such as financial, administration, legal, corporate t
l communications, and internal auditing will '
i become specialized and focused on the requirements of a nuclear generating company
) and thereby be more effective in their j
] support of GGNS.
l (4) All responsibility for the licensed
- performance of GGNS Unit I will reside within
! SERI, as the principal owner of the unit, rather -
than within a contracted operator such as MP&L.
j Coordination.of policies and responsibilities for
! operation of GGNS Unit I will therefore be enhanced
- while control of plant operation will be centralized.
j Excellence in nuclear plant operations and integrated i-comprehensive services will be afforded through j full time, dedicated management in all operational areas i and related support functions, i
! H. Nature of Transaction Necessitating,or Making i
Desirable the License Transfer 1
{ A Service Agreement, effective June 21, 1974, between MSE I
f and MP&L provided that MP&L would act as agent for MSE for the 1.
design, construction, maintenance and operation of the Grand l I
Gulf Nuclear Station. Effective as of 1980, SMEPA acquired a f 10'. undivided' ownership interest in the Grand Gulf Nuclear j
1 Station and became a co licensee of the nuclear facility.
i I
I
( J10 MISC 860814 10 i
Pursuant to the ownership agreement between MSE and SMEPA, MSE is authorized to act as agent for SMEPA for matterr. relating for the design, construction, maintenance, operation and licensing of the drand Gulf Nuclear Station. Upon the effective date of the requested amendment, the Service Agreement between MSE (now SERI) and MP&L will be terminated, and SERI will assu e sole responsibility of the design, construction, maintenance and operation of the GGNS Unit 1. SERI will continue to act as SMEPA's agent in carrying out these responsibilities. ,
I. Restricted Data This application does not contain any Restricted Data or other defense information, and it is not expected that any will become involved. Ilowever, SERI agrees that it will appropriately safeguard such information if it does become involved and it will not permit any individual to have access to Restricted Data until the Civil Service Coremission [now Office of Personnel Management] shall have made an investigation and report to the Nuclear Regulatory Commission on the character, associations and loyalty of such individual, and the Nuclear Regulatory Commission shall have determined that permitting such person to have access to Restricted Data will not endanger the common defenso and security.
J10?!!SC860814 - 11 I S
J. Antitrust Conditions The transfer from MP&L to SERI of operating responsibility for GGNS Unit 1 requested by this application necessitates amendments to the antitrust license conditions included in the GGNS Unit 1 operating license. The antitrust conditions currently
- apply to MP&L. Following the transfer of operating responsibility 3
to SERI, it is proposed that MP&L will rot remain an NRC licensee and the license conditions applicable to MP&L thus will be inappro,priate. In any event, MP&L believes that the principles of the antitrust conditions have been implemented by it by interconnection agreements entered into with the other two 5
electric power generation, transmission, or distribution entities i whose members constitute all the Entities, as such term is defined in the license, in the Western Mississippi Area, the relevant I
market defined in the antitrust conditions. Based on these i circumstances, the existing antitrust license conditions should be deleted.'
The majority of the existing antitrust conditions pertain to interconnections, bulk power transactions, and transmission 4/ There is no doubt that Commission regulations (e.g.,
10 C.F.R. $$ 2.200 - 2.204, 2.206) give the Director of the Office of Nuclear Reactor Regulation authority to modify license conditions--including antitrust license conditions -
where necessary to reflect changing circumstances. See, e.g , Toledo Edison Company, et al. (Davis Besse Nuclear i
Power Station, Units 1, 2 and 3), ALAB-560,10 NRC 265, 294 (1979); Consolidated Edison Co. of New York (Indian Point .
Station, Unit No. 2), LBP78-21. 7 hRC 1048 (1978).
! J10 MISC 860814 - 12 V
i I
l services. " Western Mississippi Area" is defined for purposes of the ant'ftrust conditions in Condition I.A. The two 1
relevant Entitles in the area are South Mississippi Electric
- Power Association ("SMEPA") (the minority owner of GGNS) and the Municipal Energy Agency of Mississippi ("HEAM"). On July 18, 1979, MP&L entered into a long-tern Interconnection Agreement with SMEPA (Attachment 3). On July 1, 1984, MP&L entered into a similar Interconnection Agreement with MEAM (Attachment 4). Letter Agreements relating to the obligations of MP&L under the antitrust license conditions have also been signed f by the individual municipal members of MEAM (copies attached to the MEAM Interconnection Agreement). MP&L submits that the I
Interconnection Agreements and Letter Agreements implement the r
principles in the antitrust conditions of the GGNS Unit 1 operating license. These agreements will remain in effect !
j following the amendment of the license to add SERI and delete MP&L. The Interconnection Agreements, in light of developments i
subsequent to their execution, are long-term contracts. By j contract dated June 15, 1984, MP&L has agreed with MEAM not to I
j terminate the MEAM Interconnection Agreement prior t6 the date of I
- permanent cessation of operation of GGNS Units 1 and 2. By its i
terms, the SMEPA Interconnection Agreement was extended to the date of cessation of operation of GGNS Unit 1 and 2 upon SMEPA's
] acquisition of an ownership interest in the plant.
! MP&L bellsvos that these agreements assure, among other l things, adequate interconnection poi..ts and coordination between i ,
s 1
J10 MISC 860814 - 13 s
MP&L and the entities of the Western Mississippi Area. The agreements also provide for partial requirements power as well as other necessary bulk power supply services, and include provisions for emergency economy, reserve capacity, replacement energy, and scheduled maintenance services. Under the agreements, all parties are also obligated to establish and maintain adequate generating capacity reserves on a nondiscriminatory basis, and MP&L is obligated under circumstances consistent with the antitrust conditions to provide bulk power transmission services in such amounts as SMEPA and MEAM may specify.3 SERI will be a nuclear generating company upon isst.ance of the proposed amendment to the GGNS Unit 1 operating license.
SERI's responsibilities and authority will not involve power distribution, interconnections, bulk power sales, and trans-mission services. In light of this and the existing Interconnec-tion Agreements between MP&L (which will remain a non-nuclear generating company as well as a transmission and distribution company) and SMEPA and MEAM, the current antitrust conditions should be removed from the license, with one exception. The 5/ In this regard, see the letter from MEAM's. counsel to H.R.
Denton, dated July 19, 1983. As stated in that letter, MEAM was satisfied that MP&L has worked in good faith with MEAM to satisfy the antitrust license conditions. A copy of the letter is attached hereto (Attachment 5).
J10 MISC 860814 - 14
l-I l exception is part of Condition IV regarding participation in ownership of GGNS and any future nuclear power plants. SERI is able to assume this condition and consents to do so.
In order to facilitate the Staff's review of the proposed amendment pertaining to the antitrust conditions, MP&L and SERI will, as necessary, supplement this aspect of the license amendment application with information in response to any Staff requests during the Staff review of this matter.6 K. Bifurcation of the Amendment Review The proposed license amendment involves two distinct aspects, viz., (1) the technical aspect involving basically the transfer to SERI of MP&L's nuclear organization and its responsibilities as plant operator, and (2) the antitrust t licerse conditions. Joint Licensees request that the safety ,
review of the amendment application by the NRC Staff and any antitrust review by the Staff (and the Department of Justice) be bifurcated to recognize this distinction.
Specifically, the Staff review of the technical aspect should commence immediately following receipt of this application. The review should be completed, and the amendment issued and made effective at the earliest date 6/ While the ownership agreement between MSE and SMEPA authorizes MSE to act so SMEPA's agent in licensing activities for GGNS, MSE acknowledges that SMEPA, as an entity affected by the antitrust conditions, may freely express its views to the NRC (or the Department of Justice) on the proposal to delete the antitrust conditions as they bear on MP&L.
J10 MISC 860814 - 15 l
consistent with 10 C.F.R. 550.90-50.92, whether or not any antitrust review is completed, with the present antitrust conditions remaining in place and applicable to HP&L pending completion of that rcview. Bifurcation in this manner is appropriate and in the public interest because establishment ,
of SERI as a nuclear generating company for GGNS Unit I represents an enhancement in overall managerent and operation of the piant that should be effected as soon as possible. The change is consistent with Commission guidance emphasizing the i
! public safety advantages of nuclear generatinh companies as licensees of nuclear power plants.
Recognizing that the current antitrust conditions apply 1
i only to MP&L, and that under a bifurcated Staff review SERI j
1 likely will be the licensee prior to completion of the anti-I j
trust review, Joint Licensees suggest that the NRC condition the technical amendment as appropriate to assure that any subsequent findings from the antitrust review will be given full force and effect. Compare 42 U.S.C. $2135c(8). The technical amendment could be issued substituting SERI for t
l MP&L as operator of GGNS Unit 1, with a condition providing I for removal of the antitrust license conditions applicable to HP&L only upon completion of the antitrust review and a finding that there are no significant antitrust 4
I 1
1 1
l J10 MISC 860814 - 16
! 1 l
_ - - ._ __ ._= _ _ .- . __
i
- i implications.
l Although the schedule for any appropriate review of the anti-trust aspects of the amendment application need not take the maxi-f mum period provided by law, experience suggests that the review a may take longer than will be needed for the technical review.
Therefore, under the bifurcated approach, this review should be conducted on a separate, parallel track from the technical review, 4
beginning with this application. Joint Licensees submit that the bifurcated approach offers the most beneficial, efficient, and l logical solution, and is clearly in the public interest. The NRC Staff should determine promptly the procedures to be followed in
- reviewing this application.
II. ANALYSIS OF NO SIGNIFICANT HAZARDS CONSIDERATION The p;oposed amendment involves changes to the GGNS Offsite Organization chart (Attachment 1) and the Operatit:g s
i License (Attachment 2) to reflect the designation of SERI as a I
o nuclear generating company and operator of GGNS Unit 1. The i
i designation of SERI on the operating license as the majority owner 4
2/ HP&L submits that following final NRC approval of the
! substitution of SERI for MP&L as licensee, MP&L will no longer be the operator of the licensed facility and therefore will not be subject to NRC jurisdiction. Nor will there be any nexus between activities under the license and the obligations imposed on MP&L by the license conditions.
5 l
l 4
1 J10 MISC 860814 - 17 ;
r
and operator of GGNS Unit I will permit the focus of management attent.~on exclusively on nuclear operations, which is intended to enhance safe operation of GGNS Unit 1. This objective will be achieved by establishing a dedicated nuclear organization whose resources will be devoted to all aspects of nuclear plant operation, construction, and raintenance. For example, the President and Chief Executive Officer of SERI will focus entirely I on GGNS and will not be diverted to matters associated with non-nuclear activities of an electric utility such as transmission, distribution, and fossil production. The formation of SERI will also separate salary structure, career paths and human resources policies and procedures from those of MP&L's i
non-nuclear organization, allowing SERI to continue to be j competitive in developing, recruiting and retaining skilled nuclear professionals. Changes in these areas should have a l
positive effect on thi safe and reliabic operation of GGNS.
The technical aspects of the proposed amendment are basically administrative in nature in that they merely reflect the renaming of MSE to SERI and the transfer to SER1 of MP&L's nuclear organization and responsibility for operation of GGNS i Unit 1. The proposed amendment does not involve hardware or j procedural modifications that could lead to a significant increase in the probability or consequences of an accident previously evaluated, does not create the possibility of a new or I
J10 MISC 860814 - 18
different kind of accident from any accident previously evaluated, and does not involve a significant reduction in a margin of safety. These changes actually will increase management efficiency and intensify management focus on the conduct of GGNS activities. Thus, the proposed amendment should enhance safe reactor operation. Accordingly, the NRC should find pursuant to 10 C.F.R. $50.92(c) that the proposed amendment involves no significant hazards consideration.
III. EFFECTIVE DATE The assumption of responsibilities for the operation of GGNS Unit I by SER1 requires the consent of MSE's creditors under the terms of various bank loan agreements and may require the approvals of other agencies in addition to the Nuclear Regulatory Commission. These consents and, if
~
required, additional approvals are anticipated to be obtained in an expeditious manner. In any event, it appears likely that NRC approval will be the critical path regulatory approval for SERI to assume its responsibilities. Therefore, the Joint Licensees request that the NRC approve the proposed t echnical operating license amendment without delay. Should it subsequently appear that the other consents or approvals will not be obtained in a timely fashion, the Joint Licensees will promptly notify the Commission. Subsequently, changes to the antitrust license conditions may also be made, consistent with the i bifurcated approach described above.
4 J10 MISC 86081~ - 19
IV. CONSENT MP&L and SMEPA hereby consent to the assumption of 4
responsibilities by SERI as described above:
It is requested that, af ter the effective date of the amendment, all co:amunication be sent to Mr. Oliver D. Kingsley, Jr.
Vice President Nuclear Operations System Energy Resources. Inc.
Post Office Box 23054 Jackson, Mississippi 39215 The service lists identifying required distribution of correspondence addressed to the NRC will remain unchanged.
I f
i i
l l J10 MISC 860814 - 20 I