ML20245J481

Application for Amend to License NPF-38,requesting Approval for Entergy Operations,Inc to Assume Operating & Mgt Responsibility for facility.Marked-up Amends to License NPF-38 Encl

ML20245J481
Person / Time
Site:	Waterford
Issue date:	08/15/1989
From:	Cain J LOUISIANA POWER & LIGHT CO.
To:
Shared Package
ML20245J475	List: ML20245J481 W3P89-1458, Forwards Application for Amend to License NPF-38, Consisting of Change Request NPF-38-99,seeking Approval for Entergy Operations,Inc to Assume Operating & Mgt Responsibility for Facility
References
NUDOCS 8908180046
Download: ML20245J481 (59)

Text

{{#Wiki_filter:_ _ - _ 'o ~ .1 gey, 4 e 08/07/89 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .In the Matter of ) ) LOUISIANA POWER & LIGHT COMPANY ) ) Oocket No. 50-382 ) (Waterford Steam Electric Station, ) i Unit No. 3) ) l l APPLICATION TO AMEND FACILITY. OPERATING LICENSE NO. NPF-38 Louisiana Power & Light Company ("LP&L") (the " Licensee") is the holder of Facility Operating License No. NPF-38 for Waterford Steam Electric Station- ) Unit 3 (Waterford 3.) The operating license presently authorizes LP&L to possess, use and operate Waterford 3 in accordance with the terms and j conditions of the license. LP&L is a wholly-owned subsidiary of Entergy Corporation ("Entergy"). Entergy also owns the common stock of Arkansas. Power & Light Company ("AP&L"), which is licensed by the Nuclear Regulatory Commission (NRC) to possess, use and operate Arkansas Nuclear One, Units 1 and 2 ("ANO-1" and 'fANO-2), and System Energy Resources, Inc. (" System Energy"), which is licensed to possess, i use and operate Grand Gulf Nuclear Station (" Grand Gulf"), Unit 1 and to~ l 1 construct Grand Gulf, Unit 2. I In requests to the NRC dated July 1, 1988, AP&L and LP&L s,ubmitted proposed license amendment to designate System Energy las the licensed operator-for ANO and Waterford 3, respectively. to this application contains the originally requested license changes for Waterford 3. Entergy now I plans for a new company to be called Entergy Operations, Inc. ("E0I") to become PCEN NLSMISC89062304 - 1 8908160046 890815 PDR ADOCK 05000382 P PDC

its system-wide nuclear operating company. As such, E01 would assume operating responsibility for -- but not ownership of -- Grand Gulf Unit 1, ANO-1, ANO-2, and Waterford 3. This assumption of operating responsibility will be accomplished by operating agreements between LP&L and E01, between AP&L and E01, and between System Energy and E0I, each agreement designating E01 as the agent for the owner and authorizing E01 to operate its plant or plants. The 1 l assumption of operating responsibility by E01 for Waterford 3, ANO-1, ANO-2, and Grand Gulf Unit I will not impact existing plant ownership or entitlement to capacity and energy. i Upon receipt of necessary regulatory approvals and transfer to EDI of LP&L Nuclear Operations personnel, E0I will succeed LP&L as operator of Waterford 3. This amendment application requests that the NRC amend Operating License No. NPF-38 to authorize and reflect in the license the change from LP&L to E0I as the licensee authorized to possess, use and operate Waterford 3. 1/ Specifically, pursuant to 10 C.F.R. S 50.90, the Licensee hereby requests l that the NRC amend Operating License No. NPF-38 to changa the name of the ( l l licensee for Waterford 3, such that: 1/ The proposed changes to the Waterford 3 Operating License to reflect the establishment of E01 as the licensee responsible for the operation of Waterford 3 are included in Attachment 1. Other than submittals currently pending NRC approval, this amendment application involves no additional changes to the Technical Specifications. PCEN NLSMISC89062304 - 2

e (1) E01, 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," is licensed to possess, use and operate Waterford 3 at the designated location in St. Charles Parish, Louiriana, in accordance with the procedures and limitations W. forth in the License; (2) LP&L, pursuant to the Act and 10 C.F.R. Part 50, is licensed to possess Waterford 3 at the designated location in St. Charles Parish, Louisiana, in accordance witn the procedures and limitations set forth in the License; (3) EDI, pursuant to the Act and 10 C.F.R. Part 70, is licensed to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required fer reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (4) EDI, pursuant to the Act and 10 C.F.R. Parts 30, 40 and 70, is licensed to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fissi m detectors in amounts as required; PCEN NLSMISC89062304 - 3

l _4_ s; (5) EDI,. pursuant'to'the Act and 10 C.F.R. Parts 30, 40 and 70, is licensed to receive, possess and use in amounts as required any byproduct, sou?ce or special nuclear material withcut restriction to chemical or physical form, for sample analysis or instrument calibration or associated i with radioactive apparatus or components; and L (6)' E01, pursuant to the Act and 10 C.F.R. Parts 30, 40 and 70, is licensed to possess, but not separate, such byproduct and special nuclear materials as may be produced. by the operation of Waterford 3. 1 Other conforming license changes are noted in Attachment 2 to this Application. 2/ Set forth below is the information in support of the Application to Amend Facility Operating License No. NPF-38. ) l i l I 2/ Conforming changes, if necessary, in insurance.and indemnity agreements will.be made in due course by separate correspondence. i i PCEN NLSMISC89062304 - 4

1 I. GENERAL INFORMATION CONCERNING LICENSE AMENDMENT - A.- Proposed Additional Licensee: Entergy Operations, Inc. B. Address: Echelon One 1340 Echelon Parkway Jackson, MS 39213 l l C. Description of Business or Occupation I a Prior to issuance of this license amendment, EDI will be organized as a-wholly-owned subsidiary of Entergy and will take necessary corporate action to authorize it to operate Waterford 3 and ANO-1, AND-2, and Grand Gulf Unit 1. 1 After approval of this requested amendment and a similar amendment to_the l l Operating Licenses for ANO-1 and AND-2 and Grand Gulf Unit 1, E01 will be responsible for the operation and maintenance of all nuclear plants:in the Middle South Electric System, including Waterford 3. Upon receipt of necessary regulatory approvals, E0I, as distinct from LP&L as the owner of the facility,. will have responsibility for and control over.the physical construction, I operation, and maintenance of the facility. D. Organization and Management of Operating Corporation EDI is a corporation to be organized and existing under the laws of the state of Delaware. Its principal office will be located in Jackson, Mississippi. The corporation will be neither owned, controlled nor dominated ) j: by an alien, a foreign corporation, nor a foreign government. PCEN NLSMISC89062304 - 5 L _ _---___--_----_ ___ a

All prospective directors and principal officers of E0I are citizens of the United States. Their names and addresses are as follows: 3/ Directors Mr. Edwin A, Lupberger Chairman of the Board d Entergy_0perations, Inc. I P. O. Box 61005 .New Orleans, LA 70161 I i l Mr. William Cavanaugh, III President & Chief Executive Officer Entergy Operations, Inc. P. 0. Box 31995. Jackson, MS 39286-1995 Mr. James M. Cain. ) Chairman and Chief Executive Officer Louisiana Power & Light Company P. O. Box 60340 New Orleans, LA 70160 Dr. Joseph M. Hendrie Nuclear Engineering Consultant-50 Be11 port Lane Be11 port, NY 11713 Senior Scientist; Resaarch and Development Brookhaven National Laboratory Mr. Jerry L. Maulden President and Chief Executive Officer-Arkansas Power & Light Company P. O. Box 551' Little Rock, AR 72203 i l 4 l 'l 3/ Additional directors and officers may be named at a later date. l 1 PCEN NLSMISC89062304 - 6 i

l 1 i Officers (LATER) Upon issuance of the Operating License amendment, certain officers of LP&L will become officers of E01. i l 1 l I 1 I l .4 I PCEN NLSMISC89062304 - 7

.g. E. Technical Qualifications The technical qualifications of EDI to carry out-its responsibilities under' the Operating License for Waterford 3, as amended, will meet or exceed l the present technical qualifications of LP&L. LP&L will continue.to act as the l-l operator of Waterford 3, pending.the amendment of the Operating License. When the amendment becomes effective, E01 will assume responsibility for, and control over, the physical construction, operation, and maintenance of the facility. The present Waterford 3 Nuclear Ope' rations organization will be transferred essentially intact to E01. The' technical qualifications of the proposed Waterford 3 organization, therefore, will be at least equivalent to those of the existing organization. Entergy has expended substantial effort in planning a consolidated organization for operation of its nuclear units. Acentral-objectivein l l planning the proposed consolidation and the transfer of employees.and operating 4 responsibilities from LP&L to E01 has been to minimize disruption to the operation of the plants and to respect the integrity of the existing, l successful organizations. Therefore, in the proposed EDI organization, each nuclear organization of the operating plants will be preserved with the only change that the senior nuclear executive of LP&L,-AP&L and: System Energy will i report directly to the Executive Vice President and Chief Operating Officer who i reports to the President and Chief Executive Officer of E01. This organization .I is illustrated in Attachment 3. Thus, for Waterford 3, J. G. Dewease, Senior i Vice President - Nuclear Operations, will report directly to the Executive Vice President and Chief Operating Officer of E01. The Nuclear Quality Assurance l i f .PCEN NLSMISC89062304 - 8 i i

l _g_. Department for the plant.will also have direct access to both'the Executive Vice President and Chief 0perating Officer and the. President and Chief Executive Officer of EDI on matters related to quality. This organizational approach to the consolidation accommodates the current plant-specific structure of the LP&L organization. This allows the transfer of I LP&L nuclear personnel to E0I with virtually no organizational changes or disruption. It also allows the management for Waterford 3 to retain sufficient independence to address plant-specific needs and to' maintain existing priorities and ongoing plant improvement projects. Importantly and as discussed below, there will be in the nea'r term no organizational or physical location changes to the existing, dedicated,- organization, which would include the engineering, quality assurance, and licensing organizations supporting Waterford 3. l The significant elements and advantages to the proposed E01 organization can be summarized as follows: i (1) The structure provides clear lines of authority and responsibility. while ensuring that essential nuclear functions.are dedicated to each project and report to a single responsible project executive. l (2) The effectiveness of project quality assurance will not be degraded. l PCEN NLSMISC89062304 - 9

1 '(3)- The project structure will continue to provide the project executive. the flexibility necessary for managing his resources to achieve -optimal.results. Ongoing plant-improvement plans will not be impacted. l-(4) The project structure provides the flexibility.necessary to adapt to different procedures and methods used at each plant..This is particularly important initially, since most project-nuclear activities will be transferred essentially "as is" to E0I. (5) The effectiveness of a dedicated nuclear support' organization-is enhanced by identity with and sharing of the E01 goals and objectives. I l The consolidation of the System Energy, LP&L, and AP&L nuclear organizations within EDI will be a 'long-term, evolutionary process. The. licensees will continue to study possible organizational and programmatic j i changes to enhance corporate objectives and to realize the full benefits of~ j 1 establishing E0I as the company responsible for nuclear operations in the Middle South Electric System. Obviously,.this application cannot address all ~ of the possible changes that may be made. However, changes will.be made only. after careful analysis. ] Moreover, selected licensee programs are governed by formal plans which l required NRC review and acceptance or approval. The staff's review in this regard focuses on the specific plan and the technical qualifications of the i PCEN NLSMISC89062304 - 10' l t

[- i 1, f j , 13 _ organization which will be responsible for implementing'the plan. Changes'to such plans that involve a decrease in effectiveness or level of commitment of q the plan require prior NRC review and approval. The Quality Assurance l Program, the Emergency Plan, and the Security Plan are examples of such programs governed'by appropriate regulations. Following issuance of the license amendments approving E01 as operator of Grand Gulf Unit 1, ANO-1 and ANO-2, and Waterford 3, E01 will inform the NRC in advance and obtain prior NRC approval of planned changes to organizations covered by such formal plans where the changes involve centralization or consolidation of functions and/or personnel.. It is envisioned that this will be necessary for the first change involving centralization or consolidation of functions covered by such formal-plans. For subsequent changes, E01 will make a determination as to whether or. not NRC review and prior approval is required in accordance with the appropriate provisions of 10 C.F.R. 50.54 or other applicable regulations. In addition, EDI intends to continue.the current LP&L practices of informing the NRC and soliciting their comments on the significant organizational changes affecting Waterford 3. Special emphasis will be given to any changes involving centralization occurring as a result of the assumption of operating responsibility by EDI for Grand Gulf Unit 1, Waterford 3, and AN0-1 and ANO-2. PCEN NLSMISC89062304 - 11

F. Statement of Purposes for the License Amendment The assumption of operational responsibility for Waterford 3, by E0I (along with responsibility for ANO-1, ANO-2, and Grand Gulf Unit 1) will provide benefits. inherent to an integrated nuclear operating company. -Some of the expected benefits are as follows: (1) EDI, as an. operating company for multiple reactors, will have'a.. repository of system nuclear operating expertise and experience. Presently, there is a wealth of nuclear operations talent spread throughout the Middle South Electric System. Consolidation of this talent into one company should have a synergistic effect. The change should enhance the already high level of public safety and i cost-effective operations. (2) Consolidation of talent not only will result in a merger of expertise 1 and experience for system-wide nuclear operations support, but also will permit the specialization of expertise in certain areas that might not otherwise be. developed if each of the companies continued- ) 1 to operate their separate facilities. l l (3) E01 will be better able to provide a consistent vision for the-1 philosophy of operation of the system nuclear units. A company responsible for nuclear operations in the' Middle South Electric j System will allow development of a consistent philosophy.which will be.specifically designed for nuclear plant operations. This-. focused philosophy can be used to maintain excellence in all aspects of-nuclear operation. PCEN NLSMISC89062304 - 12 l

= l. (4) As a result of the consolidation, there will be more effective communication and use of system nuclear operation experience. For example, the system-wide nuclear operating company will allow " lessons learned" to be shared promptly, efficiently, and 1 l consistently among the units. l (5) Certain non-nuclear support functions will become specialized and I focused on the requirements of the System's nuclear units and will thereby be more effective. (6) Bringing the nuclear units in the system under the management of one company will provide a broader base and more competitive environment for upper management candidates who are specialized in nuclear power generation. Further, E0I, in its role as a system-wide operating company, should provide an environment in which all employees continue to be motivated toward high performance. EDI, with its expanded responsibilities, will also provide greater opportunity for career progression and thus greater opportunity to retain valued employees. More specifically, as a result of this consolidation, salary structures, career path policies and human resource procedures will be consistent at each nuclear facility operated by E01. l 4 PCEN NLSMISC89062304 - 13

_ 14'_ G. Financial Considerations E01 will be an operating company with no ownership interest in Waterford 3. EDI, under an operating agreement with LP&L, will be authorized to operate the plant as the agent of the owner. Further, as discussed below LP&L is committed under the operating agreement to provide all-funds necessary to continue. safe operation of Waterford 3, to shut down'Waterford 3, if necessary, and to paintcin Waterford 3 in a safe condition all in conformance with NRC regulations. LP&L's financial responsibility for Waterford 3 and its. sources of funds to suppcet the facility will remain the same as under the present license. To summarize, the following interrelations will be established by the operating agreement between LP&L and E0I: 1. E01 will not have any ownership interest in the Waterford 3 plant, or facilities; however, it will have overall responsibility. for plant operations. E01 will operate Waterford 3 in accordance with the Operating License and shall have exclusive-responsibility for. making safety decisions. 2. LP&L will retain certain controls over ultimate spending limits, and will retain the authority to direct that Waterford 3 be shut down in an orderly fashion by E01 (and in accordance with E01's safety judgment). This retained authority will limit E01's spending authority, but will not encumber EDI's ability to make operational safety decisions and will have no impact on safe operation of Waterford 3. PCEN NLSMISC89062304 - 14

' 3. - Pursuant-to an operating agreement between E0I and LP&L, all costs for the operation, construction, maintenance, repair,-decontamination and decommissioning of Waterford 3 incurred or accrued are liabilities of LP&L when-incurred or accrued.,Thus, the source of-funds for operating Waterford 3 will remain unchanged.' Further, under 10 C.F.R. S 50.'33(f), a full financial qualifications review of either E01 or.the owner is not necessary as a result of the' proposed license amendment. 'This is because, under.the terms of the operating agreement, all-costs associated with operating Waterford 3 will be borne by the, owner and accordingly, EDI will have.the same financial. qualifications as the present licensees. Those qualifications-will be unchanged. H. Antitrust Considerations The plan for E0I to operate Waterford 3 will not impact the existing ownership of Waterford 3 or existing entitleraents to power. Further, the proposed license amendment to designate E01 as' the entity authorized to possess, use and operate Waterford 3 will not' alter the existing antitrust f license conditions applicable to LP&L. Those conditions will remain applicable I to LP&L. Therefore, this proposed license amendment does not require antitrust review pursuant to.Section 105 of the Atomic Energy Act and 10 C.F.R. S 2.101(e). 1 PCEN NLSMISC89062304 - 15 1 j

,. ~ - 16'- 4 I. Restricted Data This Application does not contain any Restricted Data.or other defense information, and it is not expected that any such information will' become involved in the licensed activities. However,=in the event that such information does become involved, E01 agrees that it will' appropriately safeguard such.information and it will not permit any individual to have access. to Restricted Data until the Office of Personnel Management shall have made an investigation and report to the NRC on the character, associations andiloyalty of such individual, and the NRC shall have determined that permitting such. person to have access to Restricted Data will not endanger the common defense and security. PCEN NLSMISC89062304 - 16

4 17 __ SP'CIFIC INFORMATION REGARDING RELATED ISSUES II. E A. ' Emergency Planning Upon approval of the license amendment to authorize operation of Waterford 3 by E01, E01 will assume authority and responsibility for functions necessary-to fulfill the emergency planning requirements specified in 10 C.F.R. S 50.47(b) and Part 50, Appendix E. No substantive changes will be made to the existing Waterford 3 emergency plan presently implemented by LP&L. In addition, there will be no changes to the existing Emergency Planning Organization. Transition-plans will be established to ensure that support.. described in the existing emergency plan will be maintained throughout the transition-and as needed following the transition. Appropriate action will be taken-as necessary with respect to existing agreements for support from LP&L, as well as from organizations and agencies not affiliated with.the licensees, to notify the parties to such' agreements of EDI's agency relationship with LP&L and E01's responsibility for management and operation of Waterford 3. This will be accomplished as necessary by LP&L' prior. to the transfer of responsibility. Following the transfer of employees and operating responsibility to E01, emergency planning support will be provided by LP&L-as needed. In essence, to .) the extent that personnel, resources, and facilities are not being transferred to E01,'LP&L will continue to fulfill selected emergency planning functions. These. functions have been thoroughly reviewed and the required support will be assured by the following measures:

1) a support agreement between LP&L and E01

].0 PCEN NLSMISC89062304 - 17 l

and 2) as necessary, new support agreements will be developed between LP&L and E01. Long-term utilization of LP&L resources in these areas will be based on cost-effectiveness-and existing relationships with offsite organizations'and-J agencies. In sum, the proposed license amendment will not impact compliance with the emergency planning requirements. Because the effectiveness of the emergency plan will not be decreased, specific emergency plan and procedure changes will be submitted to the NRC within 30 days after the changes are made, pursuant to 10 C.F.R. S 50.54(q) and Appendix E, Section V. B. General Design Criterion 17 The amendment to authorize assumption of operating responsibility by EDI involves no changes in the ownership or design of the offsite power system for Waterford 3, or in its operation, maintenance or testing. Upon approval of the amendment, LP&L will continue to fulfill its current responsibilities to EDI with respect to compliance with General Design Criterion ("GDC") 17. GDC 17 specifically requires that there be an assured' source of offsite power to the plant. Pursuant to this requirement, EDI and LP&L will maintain and implement procedures and agreements specifying: (1) the arrangements for l provision of a continued source of offsite power and (2) the arrangements for' q controlling operation, maintenance, repair, and other. activities with respect to the Switching Station, the transmission lines and the Switchyard, such that I adequate independent sources of offsite power will continue to be provided. ~ PCEN NLSMISC89062304 - 18

Es . ig. The term " Switching Station" applies to the station located immediately adjacent to Waterford 3. The purpose of this station is.to connect the. plant to the Waterford Switchyard by means of two 230 kv lines. The term " Switchyard" applies to the 230 kv switchyard closest to Waterford 3 consisting of two buses and bays connected in the. typical breaker and a half scheme. In essence, the written procedures and agreements will provide for the future interface between E0I and LP&L..First, LP&L has committed to providing offsite power to Waterford 3. Second, the procedures and agreements will provide for the continuation of current arrangements for the operation and maintenance of the Switching Station, the Switchyard and associated transmission facilities. The procedures and agreements will also specify that LP&L will obtain approval from E0I prior to implementing any changes to the equipment in the Switching Station, which includes the unit oil circuit breakers, switching disconnects, transmission lines and protective relaying which are directly adjacent to the Waterford 3 protected area. In addition, procedures will also specify that LP&L will obtain concurrence from E0I prior to implementing any changes to the 230 kv switchyard equipment dedicated to Waterford 3. PCEN NLSMISC89062304 - 19 i C _____,_________-_____--__m_.__ -__.__2 _.___.___m

l - go. C. Exclusion Area l Upon approval of the amendment providing for assumption of operating responsibility by E0I, EDI will have authority to determine all activities within the Waterford 3 exclusion area, to the extent required by 10 C.F.R. Part 100. As stated in Section 2.1.2 of the Waterford 3 Final Safety Analysis Report (FSAR), LP&L owns all surface rights within the exclusion area boundary of the plant. Under the operating agreement between E0I and LP&L, LP&L will agree to provide E0I with unrestricted access to the property constituting the Waterford 3 site, including the facilities, equipment, Switching Station and personnel property located on the site. Except as modified below with respect to Waterford 1 and 2, EDI shall have authority to exercise complete control over l the exclusion area as designated in the FSAR for the plant, and to determine all activities within that area (including all areas of the Waterford 3 plant i and the Switching Station). This authority will allow E0I to control ingress i and egress and to order an evacuation if necessary. To the extent practicable, E0I will, of course, exercise this control in such a fashion that LP&L's access to the Switching Station, transmission facilities and to Waterford 1 & 2 for proper operation and maintenance of the electric systems on the Waterford site will not be unduly restricted. l Those activities associated with the operation and maintenance of the LP&L l Waterford 1 & 2' fossil generating plants, which are located in the exclusion area, are unrelated to the operation of Waterford 3 and therefore will remain under the control of LP&L. Written procedures and agreements will provide for PCEN NLSMISC89062304 - 20

.1 { the interface between E0I and LP&L to address the operation of these facilities during emergency situations. J With respect to the activities unrelated to plant operation that will occur in the exclusion area identified in Section 2.1.2 of the FSAk, there will be no change. E01 will assume responsibility for the Emergency Plan as discussed above. In essence, there will be no changes to the Waterford 3 i Emergency Plan other than the fact that it will become the responsibility of E01. D. Security The proposed license amendment will not impact compliance with the physical security requirements of 10 C.F.R. Part 73. Upon assumption of operating responsibility, E0I will assume ultimate responsibility for implementation of all aspects of the present security program. Appropriate action will be taken as necessary with respect to existing agreements for support from organizations and agencies not affiliated with the licensees to reflect E01's agency relationship with the owner and E0I's responsibility for i management and operation of Waterford 3. Changes to the plans to reflect this transition will not decrease the effectiveness of the plans and will be 1 submitted to the NRC within 30 days after the changes are made, in accordance I with 10 C.F.R. S 50.54(p). i PCEN NLSMISC89062304 - 21

l 'l E. Quality Assurance Program The proposed license amendment will not impact compliance with the quality I assurance requirements of 10 C.F.R. 50, Appendix B, nor will it reduce the commitments in the NRC accepted quality assurance program description for Waterford 3. Upon assumption of operating responsibility, E01 will assume the ultimate responsibility for present functions associated with the Waterford 3 quality assurance program. The organization, function and structure of the l Waterford 3 quality assurance department will not be affected by this license amendment. Changes to reflect this transition, which will be handled in accordance with 10 C.F.R. 50.54(a), will not reduce the commitments in the quality assurance program description. F. Final Safety Analysis Report With the exception of areas discussed in this license amendment application, the proposed license amendment will not change or invalidate information presently appearing in the Waterford 3 FSAR. Changes necessary to accommodate the proposed license amendment will be incorporated into the Waterford 3 FSAR following NRC approval of the license amendment application, in accordance with 10 C.F.R. 50.71(e). G. Training l The proposed license amendment will not impact compliance with the operator requalification program requirements of 10 C.F.R. 50.54 and related I sections, nor maintenance of the Institute of Nuclear Power Operations l 3 PCEN NLSMISC89062304 - 22

.23 - p, accreditation for licensed and non-licensed training. Upon assumption of1 operating responsibility for Waterford 3,.E0I will. assume ultimate responsibility for implementation of present' training programs. Changes to the programs'to' reflect this transition will not decrease the scope of the approved. operator requalification program'without'the specific authorization of_the NRC in accordance with 10 C.F.R. 50.54(i). l H. Engineering Support i Currently.the engineering support for Waterford 3'is provided by a dedicated engineering organization that is an integral part of the Nuclear j Operations organization. Because the existing Nuclear Operations orga'nization-at LP&L will transfer virtually intact to E01 upon. approval of this license amendment, there will be essentially no change in the engineering support-provided and no change in the interface between the organizations responsible for engineering support, and maintenance and operations at Waterford 3. Thus there will be no degradation of the enginee' ring support function and its integration with maintenance and operations. After issuance of the license amendment, as evolutionary changes are made to consolidate organizations within E0I, EDI will ensure the continued integration of the engineering support function with the maintenance and operation function. 1 .i 1 PCEN NLSMISC89062304 - 23 ) i

~ .1 - ) I 1 III. NO SIGNIFICANT HAZARDS CONSIDERATION EVALUATION PURSUANT TO 10 C.F.R. 50.92 i 1 A. Proposed Change ] ll The proposed amendment would revise Facility Operating License No. NPF-38 1 for Waterford 3 to authorize E01 to act on behalf of LP&L, with responsibility for and control over the' physical construction, operation, and maintenance of the facility. ) I B.

Background

i Prio~ to issuance of this license amendment,.E0I will be organized as a f r 1 l wholly-owned subsidiary of Entergy and would assume all responsibilities for. ) operating Waterford 3. Under the current operating license for Waterford 3, i these responsibilities are now held by LP&L, which also is a wholly-owned subsidiary of Entergy. This application is being filed simultaneously with a similar application by AP&L to transfer to E01' operational responsibility for ANO-1 and ANO-2 and by System Energy to transfer to E01 operational ) l responsibility for Grand Gulf Unit 1. Under the terms of the proposed amendment, the operating license for. I Waterford 3 would recognize E0I as the legal entity which will provide the ) technical and managerial resources.for the continued safe operation of the facility,.and~as the entity with exclusive-auth'ority to make operational safety 4 decisions. The proposed licensed amendment involves no~ change in the ownership of the facility and no' physical changes to the plant. PCEN~NLSMISC89062'304 - 24 ___.__________I_

25 All of the current license conditions will remain in effect and the Limiting Conditions for Operation, Limiting Safety System Settings, and Safety Limits specified in the Technical Specifications will remain unchanged. While the emergency plan, security plan, and plant operating and emergency procedures may require administrative changes to reflect E01's role as agent for the owner - and operator of Waterford 3, no changes will be made that decrease the effectiveness of these plans and procedures. Similarly, while.the Quality Assurance Program may require administrative changes to reflect the role of E0I, no changes will be made that reduce the commitments in the' program. A transition plan will ensure an orderly transfer of existing emergency preparedness responsibilities to E0I. Written procedures and agreements maintained and implemented by EDI and LP&L will clearly ensure continued. compliance with GDC 17. Similarly, an operating agreement will ensure that E0I i has authority to determine all activities within the exclusion area. The technical qualifications of E0I to carry out its responsibilities under the Operating License, as amended, will meet or exceed the present technical qualifications of LP&L. LP&L will continue to act as the operator of Waterford 3, pending the amendment of the Operating License. When the i amendment becomes effective, E01 will assume responsibility.for, and control i over, the physical construction, operation, and maintenance of the facility. The present Waterford 3 Nuclear Operations staff will be transferred essentially intact to E0I. The technical qualifications of the E01 Waterford 3 organization therefore will be at least equivalent to those of the existing I organization. l PCEN NLSMISC89062304 - 25

I 1 ' i The transfer of operational responsibility for Waterford 3 from LP&L to l l E01 (along with the transfer from AP&L to E0I of responsibility for ANO-1 and j i ANO-2 and the transfer from System Energy to E0I of responsibility for Grand 1 Gulf Unit 1) will provide benefits inherent to an integrated system-wide, j management company. Some of the expected benefits are as follows: l (1) EDI, as an operating company for multiple reactors, will have a i I repository of system nuclear operating expertise and experience. l J l Presently, there is a wealth of ruclear operations talent spread 1 throughout the Middle South Electric System. Consolidation of this talent into one company should have a synergistic effect. The change l will enhance public safety and cost-effective operation. (2) Consolidation of talent not only will result in a merger of expertise and experience for system-wide nuclear operational support, but also will permit the specialization of expertise in certain areas that might not otherwise be developed if each of the companies continued to operate their separate facilities. i 1 ) (3) E0I will be better able to provide a consistent vision for the i philosophy of operation of the system nuclear units. A company j responsible for nuclear operations in the Middle South Electric System will allow development of a consistent philosophy which will be specifically designed for nuclear plant operations. This focused l i philosophy can be used to maintain excellence in all aspects of nuclear operation. 1 PCEN NLSMISC89062304 - 26

.f-(4) As a. result of.the consolidation,.there'will.be more effective-communication and use.of system nuclear operating' experience. For-example, the system-wide nuclear operating company will allow " lessons learned"' to be shared promptly, efficiently, and consistently among the. units. (5) Certain non-nuclear-support functions will become specialized and focused on the requirements of the System's nuclear units and'ill w thereby be more effective. i (6) Bringing the nuclear units in the System under the management-of one company will provide a broader base and more competitive environment-for upper management candidates who are specialized in nuclear power generation. Further, E0I, in its role as a_ system-wide operating' .{ company, should provide an environment in which all employees l l' continue to be motivated toward high performance. EDI, with its. expanded responsibilities, will also provide greater opportunity for I career progression and thus greater opportunity to retain valued employees. More specifically, as a result of this consolidation, salary structures, career path policies and human resour.ce procedures will be consistent at each nuclear facility operated by E01. i i i l PCEN NLSMISC89062304 - 27 i

C. Analysis The following discussion provides a specific analysis of the proposed change against the three standards delineated in 10 C.F.R. S 50.92 and demonstrates that the proposed change involves no significant hazards consideration: I i 1. The proposed change will not increase the probability or consequences of an accident previously evaluated. The technical qualifications of i E01 will be at least equivalent to those of LP&L presently. Personnel qualifications will remain the same as those discussed in the Technical Specifications and the FSAR. l i i The employees of System Energy, LP&L and AP&L presently engaged in l the operations of Grand Gulf Unit 1, Waterford 3, ANO-1 and ANO-2 will become employees of E0I. The organizational structure of EDI will provide for clear management control and effective lines of l authority and communication among the organizational units involved l l in the management, operation, and technical support of the facility. I As a result of the proposed amendment, there will not be physical changes to the facility, and all Limiting Conditions for Operation, Limiting Safety System Settings, and Safety Limits specified in the Technical Specifications will remain unchanged. With the exception of administrative changes to reflect the role of E01, the quality assurance program, the emergency plan, security plan, and training program are unaffected. Operating agreements will ensure continued PCEN NLSMISC89062304 - 28

4 compliance with GDC 17 as well as-E01 control over activities within the exclusion area. Therefore', the proposed changes will not increase the probability or consequences of an accident previously evaluated. 2. The' proposed amendment will not create the possibility.of a'new or different kind of accident from any accident previously evaluated. The design and design bases of Waterford 3 remain the same. Therefore, the current plant safety analyses remain complete and accurate in addressing the licensing basis events and analyzing plant-- response and consequences. The Limiting Conditions for Operation, Limiting Safety System Settings, and Safety Limits are not affected by'the proposed amendment. With the exception of administrative changes to reflect the role of E01, plant procedures are unaffected. As such, the plant conditions for which the design basis accident analyses'~have been preformed are still valid. 'Therefore, the proposed amendment cannot create the possibility of a new and different kind of accident than previously evaluated. I PCEN HLSMISC89062304 - 29 i

1 3. The proposed amendment will not involve a reduction in a margin of safety. Plant safety margins are established through Limiting Conditions for Operation, Limiting Safety System Settings, and Safety Limits specified in the Technical Specification. Since there will be no change to the physical design or operation of the plant, there j will be no change to any of these margins. The proposed amendment therefore will not involve a reduction in a margin of safety. I D. Conclusion l Based upon the analysis provided herein, the proposed amendment will not ) increase the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a reduction in a margin of safety. Therefore, the proposed amendment meets the requirements of 10 C.F.R. 50.92(c) and does not involve a significant hazards consideration nor an unreviewed safety l question. j i i I l i s i 1 PCEN NLSMISC89062304 - 30

- e 8 l l l ENDORSEMENT AND CONSENT i i l LP&L, presently the sole licensee, hereby endorses and consents to this a 1 application filed under oath or affirmation by J. G. Dewease, Senior Vice ' l President-Nuclear Operations of LP&L, and the proposed assumption of ' operating and licensing responsibilities for Waterford 3 by EDI as described above.- I i 1 1 j ,1 k 7R. R V J. M. Cain Chairman and Chir;f Executive Officer 1 Louisiana Power & Light Company .I '] PCEN NLSMISC89062304 - 31 ]

4 d. G. 6 I - ') NPF-38-99 ATTACHMENT 1- ^. 's - .._.__m_. __..._______o_ _ _ _ _

1. ,...,o UNITED STATES

[}- }, NUCLEAR REGULATORY COMMISSION E WASH 6NGTON, D. C. 20S$5 U g LOUISIANA POWER AND LIGHT COMPANY SY. STEM f.NEMY REscullCE5fAC. DOCKET NO. 50-38Z WATERFORD STEAM ELECTRIC STATION, UNIT 3 FACILITY OPERATING LICENSE License No. NPF-38 1. The Nuclear Regulatory Comission (the Comission or the NRC) has found that: g A. The applicat[on for license filed by the Louisiana Power and Light Company 41ic;--.,;;) complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Comission's regulations set forth iri 10 CFR Chapter I, and all required notifications to other agencies or bodies have been duly made; B. Construction of the Waterford Steam Electric Station, Unit 3 (facility), has been substantially completed in conformity with Construction Pemit No. CPPR-103 and the application as amended, the provisions of the Act, and regulations of the Comission; C. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the regulations of the Comission (except as exempted from compliance in Sections 1.!. and 2.D. below); D. There is reasonable assurance: (1) that the activities authorized by this operating license can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Comission's regulations set forth in 10 CFR Chapter I (except as exempted from compliance in Sections 1.I. and 2.0 below); KYsNn ENCBC,y AEsounts,THc.(MRZ)g E. .= m ; : _=: L;f t 3------- is technically cualified to enoaoe in the activities authorized by this operating license in accordance with the Comission's regulations set forth in 10 CFR Chapter It LN:-_L.___ has satisfied the applicable 9rovisions of 10 CFR F. N e Part 140, " Financial Protection Requirements and Indemnity l Agreements", of the Comission's regulations;

1. After a transfer of LP&L nuclear personnel to SERI, SERI has succeeded LP&L as the operator of the Waterford Steam Electric Station, Unit 3.

Consequently, SERI is authorized to act for itself and for LP&L and has exclusive responsibility and control over the physical construction, operation and maintenance of the facility.

l 2-l G.. The issuance of this license will not be inimical to the common defense and. security or to the health and safety of the public; I H. After weighing the environmental, economic, technical, and other benefits of the facility against environmental and other costs, and after considering available alternatives, the issuance of the Facility Operating License No. NPF-38, subject to the conditions for protection of the environment set forth in the Environmental Protection Plan attached as Appendix B, is in accordance with 10 CFR Part 51 of the Comission's regulations and all applicable requirements have been satisfied; and l I. The receipt, possession, and use of source, byproduct, and special nuclear material as authorized by this license will be in accordance with the Comission's regulations in 10 CFR Parts 30, 40 and 70, except that an exemption to the provisions of 10 CFR 70.24 is granted as i described in Supplement No. 8 to the Safety Evaluation Report. This j exemption is authorized under 10 CFR 70.24(d) and will not endanger i life or property or the comon defense and security and is otherwise in the public interest. l 2. Pursuant to approval by the Nuclear Regulatory Comission at a meeting on March 15, 1985, the license for fuel loading and low power testing, License No. NPF-26, issued on December 18, 1984, is superseded by Facility ) Operating License No. NPF-38 hereby issued t> the Louisiana Power and Light Company si:.. ::.......', to read as follows: AND SY3rm dNguy ffswecas,ftvc., A. This license applies to the Waterford Steam Electric Station, Unit 3, a pressurized water reactor and assnciated equipment (the facility). I owned by Louisiana Power and Light Company, 'M t ir-- _ ::). The i facility is located on the t _- ': site in St. Charles Parish, Louisiana and is described i the Louisiana Power and Light Company Final Safety Analysis P.eport a amended, and the Environmental Report as amended. ffy.L i, 8. Subject to the conditions and requirements incorporated herein, the Comission hereby licenses:L=E!;x; L _.. Li,xi :

27 'LFE }r

1. if+ L a

^ Pursuant to Section 103 of the Act and 10 CFR Part 50, to 4 bg/ ,'). possess:== 11' --:- 2 = the facility at the designated locatien in St. Charles Parish, Louisiana in acenrdance with the procedures and limitations set forth in this license; Yst.P S J."ji Pursuant to the Act and 10 CFR Part 70, to receive, possess. i s " d " " * * '"Y

• i"' ' * i ' l ""* l ' "' ** 'i 'l ' ' "' ' ' t' ' '"* l '

3* 56% '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,? e-7 .- __==;

I INSERT B.2 for Waterford 3 License l t 2. SERI, pursuant to Section 103 of the'Act and 10 CFR Part 50, to possess, h use and operate the facility.at the designated location in St. Charles i Parish, Louisiana in accordance with the procedures and limitations set forth in this license 1 l i l l l i i,

. 4 % J; SW' fursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; g-f. rsuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, 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; and j

6. 8.

u s'uant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and 'special nuclear materials - as may be produced by the operation of the facility authorized herein. I C. This license shall be deemed to contain and i's subject to the i conditions specified in the Commission's regulations set forth in i 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations and orders of the Comission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: 4 1. Maximum Power Level.- S6RI 1 m_ -_. is authorized to operate the facility at reactor core power levels not in excess of 3390 megawatts thermal (100% power) in accordance with the conditions specified herein ) and in Attachment 1 to this Ifeense. The items identified in Attachment I to this license shall be completed as specified. Attachdent 1 is hereby incorporated into this license. 2. Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No.+, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. ME W shall operate the facility in accordance with the 1 Technical Specifications and the Environmental Protection Plan. 4 3. Antitrust Conditions L$l =ths=Hoenses: shall comply with the antitrust conditions in Appendix C to this license. j

4-4 Broad Range Toxic Gas Detectors (Section 2.2.1,' SSER 6*) Prior.t artup following the_ first refueling outage, the-Itcenste all propose technical specifications for the Brc Range Toxic Gas Detection System for inclusion in Appendix A to this license. 5. Initial Inservice Inspection Program (Section 6.6, SSER 5) By June 1,1985, the licensee must submit an initial; inservice inspection program for staff review and approval. 6. Environmental Qualification (Section 3.11, SSER 8) Prior to November.30, 1985, the licensee shall environmentally qualify all electrical equipment according to the provisions of 10 CFR 50.49. 7. Axial Fuel Growth (Section 4.2, SSER 5) Prior to entering Startup (Mode 2) after each refueling, the licensee shall either provide a report that demonstrates that. the existing fuel. element assemblies (FEA) have sufficient-available shoulder gap clearance for at least the next cycle of operation, or identify to the NRC and implement a modified FEA design that has adequate shoulder gap clearance for at least the next cycle of operation. This requirement will apply until the NRC concurs that the shoulder gap clearance provided is adequate for the design life of the fuel. 8. Emergency Preparedness (Section 13.3, SSER 8) In the event that the NRC finds that the lack of progress in completion of the procedures in the Federal Emergency-Management Agency's final rule. 44 CFR Part 350, is an indication that a major substantive problem exists in achieving or maintaining an adequate state of emergency (2) preparedness, the provisions of 10 CFR Section 50.54(s) will apply.

• The parenthetical notation following the title of mary license conditions denntes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

+The license originally authorized LP8L to possess, use and operate [ the facility. Consequently, certain historical references applicable to LP6L as the " Licensee" appear in these license conditions.

9. Fire Protection (Section 9.5.1, SSER 8)_ SdRr a. 44*-4+e***** shall maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility through Amendment 36 and as approved in the SER through Supplement 9, subject to-provisions b & c below. SegI b. -*he-44eentee may make no change to features of the' approved fire protection program which would decrease the level of fire protection in the plant without prior approval of the Consission. To make such a change ~ = = must submit anapplicationforlicenseamendmentpilyantto10CFR50.90. SERx SERZ

c. h may make changes to features of the approved fire protection program which do not decrease the level of. fire protection without prior Commission approval, provided:

(1) such changes do not otherwise involve a change in a license condition or technical specification or result in an unreviewed safety question (see 10 CFR 50.59). (2) such changes do not result in failure to complete the fire protection program approved by the Commission prior to license issuance. SERIe==um ww shall maintain, in an auditable fann, a j current record of all such' changes including an analysis i of the effects of the change on the fire protection program and shall make such records available to NRC inspectors upon request. All changes to the approved program made without prior Commission approval shall be reported annually to the Director of the.0ffice of Nuclear Reactor Regulation, together with supporting analyses. d. The licensee shall provide smoke detectors in the Control. Room main control panels, which are installed in accordance . with NFPA 72E, prior to startup following the first refueling outage, e. The licensee shall complete modifications resultina from i its spurious signal analysis prior to startup following the first refueling outage, but in any case not later than June 1, 1987. J } I

] w I f. The licensee shall provide neutron flux indication at LCP-43 which is electrically independent of the control room and cable vault prior to start-up following the first j refueling outage, but in any case not later than June 1, 1987. g. The licensee shall provide a continuous fire watch in the relay room at the isolation panel from initial criticality until acceptable resolution of adverse effects, if any, of the loss of this panel on safe shutdown. 10. Post-Fuel-Loading Initial Test Program (Section 14, SSER 10) l Any changes to'the Initial Test Program described in Section 14 of the FSAR made in accordance with the provisions of 10 CFR 50.59 shall be reported in accordance with 50.59(b) within one month of such change. 11. Emergency Response Capabilities (Section 22, SSER 8) Sur =ans=3:imems.m: shaji compi, with the. repairements of Supplement I to NUREG-0737 for the conduct of a Detailed Control Room Design Review (DCRDR). Prior to May 1,1985, the licensee shall submit for staff review and approval the DCRDP Sumary Report, including a description of the process used in carrying out the function and task analysis performed as a part of both the DCRDR and the Procedures Generation Package efforts. 12. Reactor Coolant System (RCS) Depressurization Capability (Section 5.4.3, 55ER 8) By June 18, 1985, the licensee shall submit the results of confirmatory tests regarding the depressurization capability of the auxiliary pressurizer spray (APS) system. This infor1 nation must demonstrate that the APS system.can perfom the necessary depressurization to meet the steam generator single-tube rupture accident acceptance criteria (SRP 15.6.3) with loop charging isolation valve failed open. Should the test results fail to demonstrate that the acceptance criteria are met, the licensee must provide for staff review and approval, justifica-tion for interim operation, and a schedule for corrective actions. 13. Response to Salem ATWS Event (Section 7.2.9 SSER A) The licensee shall submit responses and implement the reovirements of Generic Letter 83-28 on a schedule which is consistent with that niven in the Itcensee's letter of May 30, 1984

, I 1 14 Fuel Movement in the Fuel Handling Building In the' fuel handling building, during Modes 1-5, no more than one fuel assembly shall be outside an approved shipping container, an approved storage rack, the fuel transfer tube (including upender), the fuel elevator, or the spent fuel handling machine. i In addition to the above fuel assembly inspection / reconstitution may take place outside of an approved storage rack,.when. required, provided that the inspection / reconstitution area is borated to a level at or above 1720 ppe.

15. Qualification of Personnel (Section 13.1.3, SSER 8)

NU "-+ 'Re-iee shall have on each shift operators who meet -the requirements described in Attachment 2. is hereby incorporated into this Ifeense.

16. Operational 0A Enhancement Program (SSER 9)

The items listed below shall be completed on the schedule indicated. a. Prior to completion of Phase III of the Waterford 3 startup test program, the licensee shall conduct a comprehensive audit of the Operational 0A Program that will include a sumary QA document of the Operational QA Program, the definition of responsibilities i and interfaces, and guidance on the location of information on QA matters at all levels of concern. b. Prior to completion of Phase !!! of the Waterford 3 startup test program, the licensee shall supplement its existing QA training program to incorporate specific discussion of QA problems experienced during construction and how this experience applies to operational activities. c. Prior to completion of Phase III of the Waterford 3 startup test program, the licensee shall address each of the recommendations in the Task Force Support Grouc (TF56) Limited Scope Audit Report of LP&L Operational ()uality Assurance Program, dated December 4, 1984 d. Prior to completion of Phase III of the Waterford 3 startuo test program..the licensee shall complete corrective actions related to the 23 NRC issues as identified in the LP&L responses. J ..i

'q s e 17. Basemat The licensee shall comply with its comitments to perform a basemat cracking surveillance program and additional confirma-q tory analyses of basemat structural strength as described in ) its letter of February 25, 1985. Any significant chance to i this program shall be reviewed and approved by the NRC staff I prior to its implementation.- D. The' facility requires an exemption from certain requirements of Appendices E and J to 10 CFR Part 50. These exemotions'are described in the Office of Nuclear Reactor Regulation's. Safety Evaluation Report, Supplement No.10 (Section 6.1.2) and Supplement ~ No.. 8 (Section 6.2.6), respectively. These exemptions are authorized by law and will not endanger life or property or the comon defense and security and are otherwise in the public interest. These exemptions are, therefore, hereby granted pursuant to 10 CFR.50.12. With the granting of these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the' Act, and the rules and regulations of the Commission. SERr E. m; ' t =- -== shall fully implement and maintain in effect all provisions of the Comission-approved physical security, cuard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Inforation protected under 10 CFR 73.21, are entitled: "Waterford Physical Security Plan," with revisions submitted through March 21,1088; "Waterford Security Training and Oua11fication Plan," with revisions submitted through December 16, 1983; and "Waterferd Safeguards Contingency Plan," with revisions submitted through January 6, 1987. Changes made in accordance with 10 CFR 73.55 shall be implemented in accordance with the schedule set forth therein, sear F. Except as otherwise provided in t echnical Specifications or the Environmental Protection Plan,W shall report any violations of the requirements contained in Section 2.C of this license in the following manner. Initial notification shall be made within 24 hours to the NRC Operations Center via the Emergency Notification System with written follow-up within 30 days in accordance with the procedures described in 10 CFR 50.73 (b), (c) and (e).

t. P + L.

G. .ths=ttsauses.shall have and maintain financial protection of such type arvd in such amounts as the Commission shall require in accordance with i Section 170 of the Atomic Energy Act of 1954, as amended, to enver public liability claims.

l l .g. H. This license is effective as the date of issuance and shall expire at l midnight on December 18, 2024 FOR THE NUCLEAR REGULATORY COMMISSION Harold R. Denton, Director Office of Nuclear Reactor Regulation 4

Enclosures:

I

1.

l

2.

I 3. Appendix A (Technical Specifications) (NUREG-1117) l 4 Appendix B (Environmental Protection Plan) 5. Appendix C (Antitrust Conditions) Date of Issuance: March 16, 1985 I l l e _m_.____m____

MAR 10 cs ATTACHMENT 1 WATERFORD STEAM ELECTRIC STATION OPERATING LICENSE NPF-38 This attachment identifies items which must be completed to the Conmission's satisfaction print to startup following the first refueling outage. Continuous, direct position indication in the control room for the containment isolation valves for instrument line penetrations 53 and 65. 1 4 k l _______________a

4L(R 1 a..:.; ATTACHMENT 2 Waterford Steam Electric Station Operating License NPF-38 Operating Staff Experience Requirements ShSf3C =cRtb shall have a licensed senior. operator on each shift who has had at least six months of hot operating experience on a pressurized water reactor, including at least six weeks at power levels greater than 20% of full power, and who has had startup and shutdown experience. For those shifts where such an. individual is not available on the plant staff, an advisor shall be provided who.has had at least four years of power plant experience, including two years of nuclear-plant experience, and who has had at least one year of experience on shift as a licensed senior operator at a similar type facility. Use of adviso_rt who were licensed only at the R0 level will besevaluated on 1 tasej-o -catt_ basis, i Advisors shall be trained on plant procedures, technical specifications an~d plant systems, and shall be examined on these topics at a level sufficient to to assure familiarity with the plant. For each_ shift, the remainder of the shift crew shall be trained in the role of the advisors. Advisors, or fully trained and qualified replacements, shall be retained until the experience levels identified in the first sentence above have been achieved. The names of any replacement advisors shall be certified by prior to these individuals being placed on shift. The NRC shall' be notified at least 30 days prior to the date t#8% proposes to release the advisors f om further service. 23fAJ: I SEgr I i 9

0

q 4

NPF-38-99 ATTACHMEFTT 2 l

4 4 s.= =*a, u ,'o, UNITED $TATES [t e j NUCLEAR REGULATORY COMMISSION l wasmNotoN. o. c. 20sss \\...../ LOUISIANA POWER AND LIGHT COMPANY .SYMEtt ENEAGY RESOURCES,:CAC. DOCKET NO. 50-352 WATERFORD STEAM ELECTRIC STATION, UNIT 3 FACILITY OPERATING LICENSE License No. NPF-38 1. The Nuclear Regulatory Comission Ithe Comission or the NRC) has found that: A. The applica n for license filed by the Louisiana Power and Light Company (^ m...,d; complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Comission's regulations set forth iri 10 CFR Chapter I, and all required notifications to other agencies or bodies have been duly made; B. Construction of the Waterford $ team Electric Station, Unit 3 (facility), has been substantially completed in conformity with Construction Pemit No. CPPR-103 and the application as amended, the provisions of the Act, and regulations of the Comission; C. The ' facility will operate in confomity with the application, as amended, the provisions of the Act, and the regulations of the Comission (except as exempted from compliance in Sections 1.I. and 2.0. below); D. There is reasonable assurance: (1) that the activities authorized by this operating license can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Comission's regulations set forth in 10 CFR Chapter I (except as exempted from compliance in k. ' _ _ * ' _b . ',...,%,,,, h E u s 1 W ) O P'E W M s ilEI2-7Eu e ib;E ' 5 7 M it'echnica11y qualified to encace E. in the activities authorized by this operating license in accordance with the Comission's regulations set forth in 10 CFR Chapter I; Lf&L F. 1 -: _ --- has satisfied the applicable provisions o* 10 CFR e Part 140, " Financial Protection Requirements and Indemnity Agreements", of the Comission's regulations; N r-Eoz fAfter a transfer of LPR nuclear personnel to [Esh, N has succeeded LPE as the op erator of the Waterford Steam Electric Station, Unit 3. Consequently, 7 m is authorized to act for itself and for LPE and has exclusive responsibility and control over the physical construction, operation and maintenance of the facility.

2-G. The issuance of this license will not be inimical to the comon defense and security or to the health and safety of the public; H. After weighing the environmental, economic, technical, and other benefits of the facility against environmental and other costs, and after considering available alternatives, the issuance of the-Facility Operating License No. NPF-38, subject to the conditions for protection of the environment set forth in the Environmental Protection Plan attached as Appendix B, is in accordance with 10 CFR Part 51 of the Comission's regulations and all applicable requirements have been satisfied; and I. The receipt, possession, and use of source, byproduct, and special nuclear material as authorized by this license will be in accordance with the Commission's regulations in 10 CFR Parts 30, 40 and 70, except that an exemption to the provisions of 10 CFR 70.24 is granted as described in Supplement No. 8 to the Safety Evaluation Report. _ This j exemption is authorized under 10 CFR 70.24(d) and will not endanger life or F 3perty or the comsn defense and security and is otherwise in the public interest. l 2. Pursuant to approval by the Nuclear Regulatory Comission at a meeting on March 15, 1985, the license for fuel loading and low power testing, t.icense No. NPF-25, issued on December 18, 1984, is superseded by Facility Operating License No. NPF-38 hereby issued to the Louisiana Power and Light Company -ji_ toreagas o ow -.-- curg uy CArbvrtous; IAsc., A. This license applies to the Waterford Steam Electric Station, Unit 3, a pressurized water reactor and associated equipment (the facility), owned by Louisiana Power and Light Company.{ 1 'ir=::). The site in St. Charles Parish, facility is located on the ?"- Louisiana and is described i the Louisiana Power and Light Company Final Safety Analysis Report a amended, and the Environmental Report i as amended, ff#.L,9 8. Subject to the conditions and requirements incorporated herein, the Cossiission hereby licenses:L----hi;x; _ _...; L i p-i. ^ _, ny { L ML } ; ^

1. L f+ L>

Pursuant to Section 103 of the Act and 10 CFR Part 50, to 3 bg ?. possess:== =?

= =t= the facility at the designated location s

in St. Charles Parish, Louisiana in acenrdance with the procedures pF and limitations set forth in this license; . Y ,2G Pursuant to the Act and 10 CFR Part 70, to receive, possess, s " " ' and use at any time special nuclear material as reactor fuel, ,mm in accordance with the limitations for storage and amounts 3* M required for reactor operation, as described in the Final l Safety Analysis Report, as supplemented and amended.? = ? ___m__________._

l .q i INSERT B.2 for Waterford 3 License 60% 2. filhat, pursuant to Section 103 of the Act and 10 CFR Part 50, to possess, use and operate the facility at the designated location in St. Charles Parish, Louisiana in accordance with the procedures and limitations set forth in this license 1 i l 4 l b i i 1 1 l I

. ph, i $,X fursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source and special l nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation-1 monitoring equipment calibration, and as fission detectors in mounts as required; g f. ursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or p ociated with radioactive. apparatus or components; and (s..if. /urs#uant to the Act and 10.CFR Parts 30, 40, and 70, to possess. but not separate,'such byproduct and special nuclear materials as may be produced.by the operation of the facility authorized herein. C. This license shall be deemed to contain and fs subject to the conditions specified in the Comission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the I Act and to the rules, regulations and orders of the Comission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: 1. Maximum Power Level.- M-dhs=Hconsas:is authorized to operate the facility at reactor l core power levels not in excess of 3390 megawatts therm 1 l (1005 power) in accordance with the conditions specified herein and in Attachment 1 to this license. The items identified in to this license shall be completed as specified. Attacident 1 is hereby incorporated into this license. 2. Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No.+, and the Environmental Protection Plan' M,b contained in Appendix B, are hereby incorporated in the license. I C u W shall operate the facility in accordance with the l l Technical Specifications and the Environmental Protection Plan. 3 ' Antitrust Conditions Eor. 5 N =She=$toonses: shall comply with the antitrust conditions in i Appendix C to this license. i l

] ~ 4 Broad Range Toxic Gas Detectors (Section 2.2.1, SSER 6*) Prior t s artup following the first refueling outage, the Y licensq e all propose technical specifications for the Bro Range Toxic Gas Detection System for inclusion in Appendix A to this license. 5. Initial Inservice Inspection Program (Section 6.6, SSER 5) By June 1,1985, the licensee must submit an initial inservice inspection program for staff review and approval. 6. Environmental' Qualification (Section 3.11, SSER 81 Prior to November 30, 1985, the licensee shall environmentally qualify all electrical equipment according to the provisions of 10 CFR 50.49, 7. Axial Fuel Growth (Section 4.2, SSER 5) Prior to entering Startup (Mode 2) after each refueling, the licensee shall either provide a report that demonstrates that the existing fuel element assemblies (FEA) have sufficient available shoulder gap clearance for at least the next cycle of operation, or identify to the NRC and implement a modified FEA i design that has adequate shoulder gap clearance for at least the next cycle of operation. This requirement will apply until the NRC concurs that the shoulder gap clearance provided 'is adequate for the design life of the fuel. j 8. Emergency Preparedness (Section 13.3, $$ER 8) In the event that the NRC finds that the lack of progress in completion of the procedures in the Federal Emergency Management Agency's final rule, 44 CFR Part 350, is an j indication that a major substantive problem exists in achieving or maintaining an adequate state of emergency (2) preparedness, the provisions of 10 CFR Section 50.54(s) will apply.

• The parenthetical notation following the title of mary license conditions denn*.es the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed, j

+The license originally authorized LML to possess, use and operate [ the facility. Consequently, certain historical references applicable to LP&L as the " Licensee" appear in these license conditions. i h

l y.. q - 5.- ll 1 9. Fire Protection (Section 9.5.1, SSER 8)

==^ Sox a. W shall maintain in effect all provisions of the -{ approved fire protection program as described in the Final Safety Analysis Report for the facility through Amendment'36 and as approved in the SER through Supplement 9. subject to . i provisions b & c below, $3Rt& Eor b. -he-44eeeeen may make no change to features of the approved fire protection program which would decrease the level of fire protection in the plant without prior approval of the ~ 3 -Commission. To make such a change " ' '=== must submit an application for license amendment ptlyant to 10 CFR.50.90. 3DG Eor. \\ ~3mes -4he-44een*** may make changes to features of the approved fire c. protection program which do not decrease the level of fire protection without prior Comission approval provided:= (1) such changes do not otherwise involve a change in a license condition or technical specification or result in an unreviewed safety question (see 10 CFR 50.59). (2) such changes do not result in failure to complete the fire protection program approved by the EoI "",,ssi n pri r to license issuance. mss =tisensaw shall maintain, in an auditable form. a current record of all such changes including an analysis of the effects of the char.ge on the. fire protection program and shall make such records available to NRC inspectors upon request. All changes to the approved program made without prior Commission approval shall be reported annually to the Director of the.0ffice of Nuclear Reactor Regulation, together with supporting analyses. d. The. licensee shall provide smoke detectors in the Control i Room main control panels, which are installed in accordance with NFPA 72E, prior to startup following the first refueling outage. e. The licensee shall complete modifications resultino from its spurious signal analysis prior to startup following-the first refueling outage, but in any case not later than' June 1, 1987. i i i

1 s f. The licensee shall provide neutron flux indication at LCP-43 which is electrically independent of the control room and cable vault prior to start-up following the first refueling outage, but in any case not later than June 1,- 1 1987. g. The licensee shall provide a continuous fire watch in the relay room at the isolation panel from' initial-criticality until acceptable resolution of adverse. effects, if any, of the loss of this panel on safe shutdown. 10. Post-Fuel-Loading Initial Test Program (Section 14, SSER 10) Any changes to the Initial Test Program described in Section 14 of-the FSAR made in accordance with the provisions of 10 CFR 50.59 shall be-reported in accordance with 50.59(b) within one month of such change. il. Emergency Response Capabilities (Section 22, SSER 81 g 35C =5hs=Hconsus shall comply with the requirements of Supplement 1 to NUREG-0737 for the conduct of a Detailed Control Room Design Review (DCRDR).- Prior to May 1,1985, the licensee shall submit for staff review and approval the DCRDP Sumary Report. including a description of the process used in carrying out the function and task analysis performed as a part of both the DCRDR and the Procedures Generation Package efforts. 12. Reactor Coolant System (RCS) Depressurization Capability (Section 5.4.3. 55ER 8) By June 18, 1985, the licensee shall submit the results of confirmatory tests regarding the depressurization capability of i the auxiliary pressurizer spray (APS). system. This information must demonstrate that the APS system can perform the necessary i depressurization to meet the steam generator single-tube ~ rupture accident acceptance criteria (SRP 15.6.3) with loop i charging isolation valve failed open. Should the test results i fall to demonstrate that the acceptance criteria are met. the licensee must provide for staff review and approval,,1ustifica-tion for interim operation, and a schedule for' corrective actions.

13. Response to Salem ATWS Everet (Section 7.2.9. SSER A)

The licensee shall submit responses and implement the requirements of Generic Letter 83 28 on a schedule which is consistent with that oiven in the licensee's letter of May 30, 1984 J

] i -7 14. Fuel Movement in the Fuel Handling Building In the' fuel handling building, during Modes 1-5, no more than one fuel assembly shall be outside an approved shipping container, an approved storage rack, the fuel transfer tube (including upender), the fuel elevator, or the spent fuel handling machine. In addition to the above fuel assembly inspection / reconstitution may take place outside of an approved storage rack, when required, l provided that the inspection / reconstitution area is borated to a level at or above 1720 ppm. 15. Qualification of Personnel (Section 13.1.3, SSER 8) Eor E U Se ' ReMee shall have on each shift operators who meet the requirements described in Attachment 2. is hereby incorporated into this license.

16. Operational OA Enhancement Program (SSER 9)

The items listed belew shall be completed on the schedule indicated. a. Prior to completion of Phase III of the Waterford 3 l' startup test program, the licensee shall conduct a comprehensive audit of the Operational QA Program that will include a summary QA document of the Operational QA Program, the definition of responsibilities and interfaces, and guidance on the location of information on QA matters at all levels of concern. b. Prior to completion of Phase !!! of the Waterford 3 startup test program, the licensee shall supplement its existing QA training program to incorporate specific discussion of QA problems experienced during construction and how this experience applies to operational activities. c. Prior to completion of Phase !!! of the Waterford 3 startup test program, the licensee shall address each of the reconwendations in the Task Force Support Group (TFSG) Limited Scope Audit Report of LP&L Operational f)uality Assurance Program, dated December 4, 1984, d. Prior to completion of Phase !!! of the Waterford 3 startue test orogram, the licensee shall complete corrective actions related to the 23 NRC issues as identified in the LP&L responses.

8 17. Basemat The licensee shall comply with its comitments to perfom a basemat cracking surveillance program and additional confirma-tory analyses of basemat structural strength as described in its letter of February 25, 1985. Any significant chance to this program shall be reviewed and approved by the NRC staff prior to its implementation. O. The facility requires an exemption from certain requirements of Appendices E and J to 10 CFR Part 50. These exemptions are described in the Office of Nuclear Reactor Regulation's Safety Evaluation Report Supplement No.10 (Section 6.1.2) and Supplement No. 8 (Section 6.2.6), respectively. These exemptions are authorized by law and will not endanger life or property or the comon defense and security and are otherwise in the public interest. These exemptions are, therefore, hereby granted pursuant to 10 CFR 50.12. With the granting of these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Comission.

S#i@g EEoI E.

i: 'i==== shall fully impicment and maintain in effect all provisions of the Comission-epproved physical security, cuard training and qualification, and safeguards contingency plans including amendrents r.ade pursuant to provisions of the Miscellaneous Amendments and ~ Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Infomation protected under 10 CFR 73.21, are entitled: "Waterford Physical Security Plan," with revisions submitted through March 21,1988; "Waterford Security Training and Qualification Plan," with revisions submitted through December 16, 1983; and "Waterford Safeguards Contingency Plan " with revisions submitted through January 6, 1987. Changes made in accordance with 10 CFR 73.55 shall be implemented in accordance with the schedule set forth therein. -S e g, 2 0.7 F. Except as otherwise provided in t echnical Specifications or the Environmental Protection Plan -+*r++r=== shall report any violations of the requirements contained in Section 2.C of this license in the following manner. Initial notification shall be made within 24 hours to the NRC Operations Center via the Emergency Notification l System with written follow-up within 30 days in accordance with the procedures described in 10 CFR 50.73 (b), (c) and (e). LP+L G. .@s=ttsussus;shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover pubite liability claims.

i H. This license is effective as the date of issuance and shall expire at midnight on. December 18, 2024 FOR THE NUCLEAR REGULATORY CDMMISSION Harold R. Denton, Director Office of Nuclear Reactor Regulation

Enclosures:

1.

l

2.

3. Appendix A (Technical Specifications) (NUREG-1117) 4 Appendix B (Environmental Protection Plan) l S. Appendix C (Antitrust Conditions) Date of Issuance: March 16, 1985 1 i l r

a yg i o c.., ATTACHMENT 1 WATERFORD STEAM ELECTRIC STATION OPERATING LICENSE NPF-38 This attachment identifies items which must be completed to the Comission's satisfaction prior to startup following the first refueling outage. Continuous, direct position. indication in the control room for the containment isolation valves for instrument line penetrations 53 and 65.

q M AA b.i a ? ATTACHMENT 2 Waterford Steam Electric Station Operating License NPF-38 Operatine Staff Experience Requirements ?h N shall have a licensed senior operator on each shift who has had at least six months of hot operating experience on a pressurized water reactor, including l at least six weeks at power levels greater than 20% of full power, and who has had startup and shutdown experience. For those shifts where such an individual is not available on the plant staff, an advisor shall be provided who has had at least four years of power plant experience, including two years of nuclear l plant experience, and who has had at least one year of experience on shift as ) a licensed senior operator at a similar type facility. Use of advisnet who were licensed only at the R0 level will besevaluated crrrease-cy'casOasis. ~ Advisors shall be trained on plant procedures, technical specfTications an~d plant systems, and shall be examined on these topics at a level sufficient to to assure familiarity with the plant. For each shift, the remainder of the shift crew shall be trained in the role of the advisors. Advisors, or fully trained and qualified replacements, shall be retained until the experience levels identified in the first sentence above have been achieved. The names of any replacement advisors shall be certified by prior to these individuals i being placed on shift. The NRC shall' be notified at least 30 days prior to I the date4*$t proposes to release the advisors f om further service. OUT Ecr fig - Sor I

4., _ ' -g. .. t 4

• i

. 4 NPF-38-99 ATTACHMENT 3 3. l I .i l ~b 1 ('. b i 1 i i (' l-' l I '. i l i ~ - - - ~ - _ _ _ _ _ _ _ _ _._. _ _ _ _,. _ _ ', _ _ _,, __ .)

7 6-I PROPOSED ENTERGY OPERATIONS, INC. ORGANIZATION CHART l l l BOARD OF DIRECTORS-l l l l I l I l l CEO & PRESIDENT l 1 1 I l l l l l l l l l 1 -1 l l l l l l l l l HUMAN l ACCOUNTING l l EXECUTIVE l l LEGAL & l l NUCLEAR I l P.ESOURCES & l i ~& l l VICE PRESIDENTI l EXTERNAL l l ASSURANCE & l l ADMINISTRATION c l TFIASURER l l & CHIEF l l AFFAIRS l l FUEL l l l l' l l OPERATING l l l 'l PROCUREMENT l 1 r' l OFFICER l -l l 'l l l l l l l 1 l l l l 1 l l l 1 1 I l l l 1 I ENGINEERING l l OPERATIONS l l GRAND GULF l l AND l l WATERFORD 3 ! l l l SUPPORT l l OPERATIONS l l OPERATIONS l l OPERATIONS l l l l 1 l l l l NOTE: Quality organizations for each plant have access to President & CEO and Executive Vice President and C00 on matters related to Quality. I l PCEN NLSMISC89062304 - 32 ._-__--_w}}