ML20206F502
| ML20206F502 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/15/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20206F501 | List: |
| References | |
| NUDOCS 8811210174 | |
| Download: ML20206F502 (8) | |
Text
- _ _ _ _ _ _ _ _ _ _
PRELIMINARY
/ '
~q UNITED STATES 8" e NUCLEAR REGULATORY COMMISSION
?,, ,j wAsHWGTON, D. C. 20646
%,o..../
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR RECTOR REGULATION RELATED TO ANENDMENT N05. AND__ TO FACILITY OPERATING LICENSE NOS. DPR-51 AND NPF-6 ARKAl:SAS POWER 1,Ligli COM_PANY ARKANSAS NUC, LEAR ONE x 0 NIT NOS. 1 & 2 DOCKET N05. 50-313 AND 50-368 1.0 JNTRODUCTION By application dated July 1,1988, Arkansas Power & Light Corpany (AP&L or the licensee) requested changes to the License Conditions to Facility Operating License flos. OPR-51 and i:PF-6 for the Arkansas l'uclear One Unit Nos. I and 2. The proposed changes would transfer the operating reeponsibility to the Systen Energy Resources, Inc. (SERI). This proposed action is also being taken for the t'aterford Steam Electric Station, Unit 3. SERI presently owns and operates Grand Gulf and is constructing Grand Gulf 2. The ownership of ANO-182 will repain with AP&L.
2.0 DISCUSS 10!{
, As early as May 1988, the licensees for Waterford 3 and Arkansas l'ucitar One, Units 1 and 2 announced with Systern Energy Resources, Inc., the proposed transfer of operations and raintenance responsibilities to SERI. The nucleer staff of each of the facilities would be transferred to SERI and only those activities requiring icrediate attention would be proposed for the r.ecessary changes in the initial amendeent. Our evalua-tion of these changes are provided in the Evaluation section.
The consolidation of the nuclear staff under SERI would not affect the ownership of the plants and is being proposed for the h nefits enurerated by the licenste. These benefits are listed, among other places, in the Itcensee's June 1, 1988 (Reference 1) and July 1, 1988 (Reference 2) submittals and as stated by the licensee, include the following:
SERI will have a repository of system nuclear operating 1) expertise and experience Consolidation into one nuclear operating corpany will enhance public safety and economic operations.
- 2) SERI will be better able to provide a consistent philosophy of operation of the system nuclear units. This focused philosophy can be used to achieve excellence in all aspects of nuc1 car operation.
8811210174 DR 801115 p ADOCK 05000313 PDC
2
- 3) The consolidation will allow more effective coreunication and use of system nuclear operating experience.
- 4) Certain non-nuclear support functions will become specialized and focused on the requirements of a nuclear operation company and will thereby be more effective in their support of ANO-182.
- 5) Creation of a system-wide nuclear operating company will contribute to a higher sustained icvel of employee performance, provide a broader base for more competitive environment for upper management candidates, provide an environment in which all erployees would be more highly motivated toward high performance, and provide greater opportunity for career progression.
- 6) Consolidation will riake salary structures, career path policies, and procedures internally censistent and will separate nuclear from non-nuclear employees which will permit managers to focus on special needs and requiren.ents of nuclear employees. This will allow SERI to be competitive in the a:arket for skilled employees and certain quality individuals once recruited.
The information provided by the licensee is to support the transfer of operating responsibility to SERI and the attainn,ent of the above benefits will depend on the licensees' (or SERI's) development and implerentation of effective programs and controls.
Early in the review the llRC expressed the need for the licensee to keep the public and other agencies informed of the proposed transfer of opera-tiuns to SERI. By letters dated September 9,1988 and October 13, 1988 (Referencas 4 and 5), the licensee outlired their efforts in this regard.
l The i:RC staff also contacted the designated State Officiel, Director, 1
Division of Environmental Health-Protection, Arkansas Department of Health, l and discussed the proposed t ansfer.
3.0 EVALUATION The staff's evaluation is of the licensee's submittel dated July 1, 19P8 (Reference 2) and from supporting information in the proposed Operating Agreerent between AP&L and SFR1 as contained in the licensee's submittel dated October 17, 1988 (Reference 6). The proposed Operating Jgreenent l between the licensee and SERI delineates their respective responsibilities in operating the plant corriensurate with t!RC requirements, including those contained in License Conditions. After issuance of the license amendment and the effective date of the transfer of operation to SERI the NRC will normally ccur.onicate with AP&L thru SERI and any changes to the Operating Agreecient to fulfill NRC requirerents will be an AP&t. and SERI matter not to influence or delay implerentation of the NRC requiret.ent. Since the AP&L and SERI are signees of the agreement and the NRC is not, a license condition to this effect is recomended. As such, the NRC may find the Operating Agreement information as supportive but need not approve or find it specifically acceptable. The staff review is presented in the following sections.
l ttanagement and Technical Qualifications lhe requested change would transfer AP&L's nuclear organization so that the Vice President, Nuclear for ANO-182 will report directly to the President of SERI. The present nuclear organization, down through the plant staff, will remain essentially in place as SERI employees. Therefore, the technical qualifications of the proposed ANO-1&2 orscnization will be at least equivalent to the existing organization. This includes engineering support which, at At:0-1&2, is an integral part of the nuclear organization.
We find the requested change acceptable as it meets the acceptance criteria of S2ction 13.1 of NUREG-0800, the Standard Review Plan. This requested change does not require any revision to Section 6 of the Technical Speci-fications for ANO-182.
Financial Considerations l The ownership of the facility and all rights to electric power from the facility will remain with AP&L. In addition, as stated on page 15* of Aptt'sApplicationtoAmendFacility' NPF-6 datec July T,'BBB',AWloFtsTor'ihToferFtlbiI,'coIntTuFtFoII, Operating Licen
~
maintenance, repair, decontamination and decommissioning of Af;0-1 and At:0-2 incurred or accrued will be the responsibility of AP&L wnen incurred or accrued." The staff notes, however, that Article V, Section 5.1 of the Proposed Operating Agreement between AP&L and SERI dated October 12, 1988 suggests that AP&L may not agree to pay for operation and capital improve-ment costs that exceed either (1) the annual budget for the facility to which APEL and SERI are to agree by flovember of the year prior to the budget year or (2) the maxic:um arounts to be paid wi',hin the parameters of.
the then-current SERI five-year business plan. iotwithstanding this, Article XI, Section 11.5 provides that neither SERI nor AP&L are permitted i to delay or withhold paypent due and owing under the Proposed Operating Agreement except that AP&L shall have the right to make any contested 1 payments under protest. The staff understands the provisions contained in j Sections 5.1 and 11.5 of the Proposed Operating Agreement taken together do not contradict AP&L's comitment, as referenced above Fo'pily for all costs for the operation, construction, maintenance, repair, decontamination and decomissioning of ANO-1 and ANO-2. The staff believes that AP&L's comitaient should be incorporated as part of license conditions to preclude a situation where a conflict over costs between AP&L and SERI could adversely affect protection of public health and safety, s
9EgFlT of LP&L's application for W-3.
-4 AP&L will remain subject to the retail rate jurisdiction of the Arkansas Public Service Comission and the wholesale rate jurisdiction of the Federal Energy Regulatory Comission. Because of this and LP&L's continuing entitlement to the electric power from ANO-1 and ANO-2, the staff believes that AP&L will continue to be financially qualified to pay the costs of ANO-1 and ANO-2 as provided in the proposed license amendments.
The staff believe that there will be no financial consequences adversely affecting safety trom allowing SERI to assume exclusive responsibility for making safety decisions. The economic benefits which the licensee anticipates froin SERI's operation of ANO-1 and ANO-2 are not expected to be gained at the expense of public health and safety given AP&L's continuing consnitment to pay the costs, including safety-related costs, of ANO-1 and ANO 2. Thus, the staff concludes that the financial consequences of the proposed action will not adversely affect protection of public health and safety.
Antitrust The proposed license amendrunt is subject to an antitrust review pursuant to 10 CFR 50.90 of the Comissicn's Rules and Regulations and Section 105c of the Atornic Energy Act as atended. As such, the staff will publish in the Federal Register receipt of the proposed amendment and request corrents on its competitive impact. In the course of its antitrust review, tre staff will censult with art seek the advice of the Attorney General.
Restricted _ Data The licensee has addressed the limits on restricted data and other defense information and SERI agrees to the appropriate conditions of protection and processes. The current enployees of LPAL who are aware of and responsible for safeguarding information will transfer to SEP,1, therefore no reduction in understanding or responsibility is expected.
ELerg,ency,Planaing The licensee proposes to transfer to SER1 the authority and responsi-bilities for functions necessary to fulfill the emergency planning requirements specified in 10 CFR 50.47(b) and Part 50, Appendix E.
There will be no initial changes to the ANO-182 emergency plan or planning organization.
The SERI organization plans, in the future, to add organizatio#nal components to assume overall energen.y planning. In a letter dated July 29, 1988, the NRC states its position on plan and program centralization and NRC apprevals. With centralization, plans may be transferred to another area or site. Our concern will be that the new organization possesses Cne technical capabilities as was found acceptable at ANO-182 site. Any changes with the plans or programs at the site may be made in accordance with established rules and processes. Since it is not clear that the rules and processes centerplated such drastic changes as transfer to a new
l*.
y .
1 l
5-t organization at a new site, the NRC har determined and the licensee has !
agreed that the initial plan and program change to a new site would be l l reviewed by the NRC prior to the change. Subsequent changes would revert :
! to current established practices. This understanding with the licensee i l and SERI applies to areas other than Emergency Planning as well, i l
f l The current and eventual emergency plan will depend upon a continuing i working arrang. rent between AP&L and SERI. Ce rta i.': support functions will i ren,ain with AP&L and AP&L can be expected to proside emergency non-nuclear l support from other company areas as needed. We find this sense of coopera- r tion both essential and acceptable. l Offsite Power !
1 General Design Criterion 17 requires that there be an assured source of power to the plant. The offsite power available to ANO-180 and as four.d acceptable to the NRC is as described in the Final Safety Analysis ,
Report. With the transfer to SERI, this will not change, bewever, arrange- j cents have been proposed for the interface between SERI as operator of a t nuclear plant and AP&L ncn-nuclear employees for the upkeep and maintenante ;
of offsite power ties to the plant. These arrangements are riecessary to ;
assure that the NRC's acceptance of the offsite power to ANO-1&2 is t continued. I i
Security an,d,Ex,clusjon, Are,a, Con,t,rol j
The ervloyees of AP&L responsible for security will becone SERI ervloyees l and SERI will continue to c:aintain and irplen,ent the security plans as ;
previously found acceptabic. Sore transition thanges nay be appropriate i to reflect AP&L and SERI relationships but these changes should not ;
decrease the effectiveness of the plans. Processes are underway to address l such changes. Control of the exclusion area involving security and l non-nuchar interfaces with AP&L has been addressed by the licensee and include considerations fo norral and emergency access. Written procedures I and agreements are appropriate to assure that URC approved activities in I and control of the exclusion area is maintained. NRC's approval of the !
SERI operation and control of exclusion area does not change any of the [
provisions between Ar&L and the United States Covernrent under the easecent. :
r Quality Assurance Prog n m SERI will assuse responsibility of the functions associated wijh the i ANO-112 quality assurance progran. The organization, function, and [
structure of the ANO-1&2 quality assurance department will not be affected by this license amendrent. As discussed in the Emergency Plan l section above, any proposed change to centralire plans to a new site will i require NRC initial approval; the quality assurance plans also fall in the i category and understanding with AP&L and SERI. !
i i
7.
l l .
l ., , .
l
, Training The licensee has stated that the training program, requirements, and naintenance of the Institute of fluclear Power Operations accreditation for licensed and non-licensed training will continue as before but under SERI.
Processes for NRC approval of changes that inay decrease the scope of the approved opertor requalification program will continue as before.
I License Conditions The licensee has proposed changes to the license conditions to reflect SERI operation and inaintenance of ANO-182 and continued Ap5L ownership of Af;0-182. We have reviewed the proposed license conditions and recomend two changes. Reactor fuel at ANO-182 is to remain at ANO-182 unless specific i:RC approval is obtained otherwise. The license conditiori for SER! to receive, possess, and use reactor fuel is to be codified to reflect Al;0 reactor fuel at the ANO site. The licensee agreet. to this change.
A license condition will be added to recognize the existence of the cperating agreerrent between SERI and AP&L as a roeans of 6ssuring SERI and AP&L collectively maintain the requirenents of and cooperatively ccrrunicate with the NRC. SERI will be solely responsible for all decisions relating to public health and safety, including decisions on expending funds for safety-related corponents, systerns, and services, and for all ratters related to i;RC licensing of the plant. Furthercore, under the operating agreerent, it shall be SERI's obligation to corrunicate with AP&L and to provide data, infernation, and other support as inay be necessary to eriable AP&L to satisfactorily discharge any responsibilities it may have, as the owner of the plant, with regard to naintaining regulatory corpliance and traking all necessary health and safety-related expenditures. So long as this condition is satir.fied, the operating agreer.ent ray be arrended by SERI and AP&L as those pcrties ray deterrine to be appropriate.
4.0 ENVIR0tWENTA!.,CONSJDERATJ00 The amendrent relates to changes in recordneeping, reporting, or adr.inis.
trat".n procedures or requirements. The Corrission has previusly issued a proposed finding th4t this an.endrent involves no significant hazards
) consideration 6nd there has been no public conrent on such finding.
Accordingly, the atendment reets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b),
no environmental irpact statment or environmental assessrent feed be prepared in connection with the issuance of this are.idunt.
d
, s ,
, 6.0 CONCLilS10N Based upon its evaluation of the prnposed changes to the ANO-182 License Conditions, the staff has concluded that; there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and such activities will be conducted in compliance with the Conimission's regulations and the issuance of the amendeent will not be inimical to the common defense and security or to the health and safety of the public.
Dated: November 15,1988 (Preliminary)
Principal Contributorst D. Wigginton F. A11enspach C. Itarbuck
- R, Crown W. Larbe i
s M
r i
i l
L l
_n -,
4 .
j ,
e
.- References
- 1) Letter dated June 1, 1988 from T. G. Campbell to NRC, D. M. Crutchfield transmitting draft proposed amendment for SE'I operation of Arkansas Nuclear One, Units 1&2.
- 2) Letter dated July 1,1988 from T. G. Campbell to to . t. : tion:
D. M. Crutchfield transmitting application for amendt. e "secting SERI operation of ANO 1&2.
- 3) Letter dated July 29, 1988 from C. Harbuck to T. U. C6, sell, subject "Systems Energy Resources, Inc. (SERI) License Amendrent Application for Arkansas Nuclear One, Units 1 and 2 (AND 1&2)" transmitting clarifications of positions and requesting AP&L responso.
i
- 4) Letter rated September 9,1988 from O. D. Kingsley, Jr., to NRC, Attention:
D. M. Crutchfield, response to NRC July 29, 1988 request for information (reference 3 above).
- 5) Letter dated October 13, 1988 from J. G. Cesare, Jr. (SERI) to NRC transmitting actions to keep public and appropr' ate agencies fully informed.
- 6) Letter dated October 17, 1988 from D. Howard to NPC, subject "AP8L/SERI ,
Proposed Operating Agreements" transmitting proposed operating a Security and Exchange Commission submittals, letter reference ?)greements, above, Ar.&ansas Public Service Conmission submittal, and SERI Financial Statement dated June 30, 1988.
J t
__ _ _ _ - - ___ . . . _ _ ._ _ __ _ _.-_ . _