ML20245K985
| ML20245K985 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 08/15/1989 |
| From: | ARKANSAS POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20245K957 | List: |
| References | |
| NUDOCS 8908210223 | |
| Download: ML20245K985 (32) | |
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UNITED STATES OF AMERICA y
NUCLEAR REGULATORY COMMISSION 1
j In the Matter of
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ARKANSAS POWER & LIGHT COMPANY
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50-368 i
(Arkansas Nuclear One,
)
Units 1 and 2) l APPLICATION TO AMEND FACILITY OPERATING LICENSE NOS. DPR-51 AND NPF-6 Arkansas Power & Light Company (AP&L) is the holder of Facility Operating License No. DPR-51 for Arkansas Nuclear One, Unit 1, and Facility Operating License No. NPF-6 for Arkansas Nuclear One, Unit 2.
The operating licenses presently authorize AP&L to possess, use and operate Arkansas Nuclear One, Units-1 and 2 (ANO-1 and AN0-2) in accordance with the terms and conditions of 1
these licenses.
AP&L is a wholly-owned subsidiary of Entergy Corporation (Entergy). Entergy also owns the common stock of Louisiana Power & Light (LP&L), which is licensed by the Nuclear Regulatory Commission (NRC) to possess, use and operate the
. Waterford Steam Electric Station, Unit No. 3 (Waterford 3), and System Energy Resources, Inc. (System Energy), which is licensed to possess, use and operate Grand Gulf Nuclear Station (GGNS), Unit 1 and to construct GGNS, Unit 2.
8908210223 890813 PDR ADOCK 05000313 P
PDC APPLICATION TO AMEND - 1
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-In requests to the NRC dated July 1, 1988, AP&L and LP&L submitted proposed license amendments to designate System Energy as the licensed operator for ANO and Waterford 3 respectively.
Entergy now plans for a new company to be called Entergy Operations, Inc. (EDI) to become its system-wide nuclear operating company. As such, E01, would assume operating responsibility for --
but not ownership of -- ANO-1, AND-2, GGNS, Unit I and Waterford 3.
This assumption of operating responsibility will be accomplished by operating agreements between AP&L and EDI, between LP&L and E01 and between System Energy and E01, each agreement designating E01 as the agent for the owner and authorizing E01 to operate its plant or plants. The assumption of operating responsibility by E01 for ANO-1, ANO-2, GGNS, Unit 1 and Waterford 3, will not impact existing plant ownership or entitlement to capacity and energy.
Upon receipt of necessary regulatory approvals and transfer to E01 of AP&L nuclear operational personnel, E01 will succeed AP&L as operator of AN0-1 and ANO-2. This amendment application requests that the NRC amend Operating License Nos. DPR-51 and NPF-6 to authorize and reflect in the licenses the change from AP&L to E01 as the licensee authorized to possess, use and operate ANO-1 and ANO-2. 1 I
The proposed changes to the AN0-1 and ANU-2 Operating Licenses to reflect the establishment of E01 as the licensee responsible for the operation and licensing of ANO-1 and ANO-2 are included in Attachments 1 and 2.
Other than submittals currently pending NRC approval, this amendment application involves no additional changes to the Technical Specifications for either unit.
APPLICATION TO AMEND - 2
c, Specifically, pursuant to 10 C.F.R. 6 50.90, the licensee hereby requests that the NRC amend Operating License No. DPR-51 to change the name of the licensee for AN9-1, such that:
(1) EDI, pursuant to Section 104b of the Atomic Energy Act of 1954, as amended (the "Act"), and 10 C.F.R. Part 50, " Licensing of Production and Utilization Facilities," is licensed to possess, use and operate ANO-1, at the designated location in Pope County, Arkansas, in accordance with the procedures and limitations set forth in the License; (2) AP&L, pursuant to the Act and 10 C.F.R. Part 50, is licensed to possess ANO-1 at the designated location in Pope County, Arkansas, in accordance with the procedures and limitations set forth in the
. License; (3) E01, 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 for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (4) E01, 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 by-product, 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; i
t APPLICATION TO AMEND --3 I
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(5) E01, 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 by-product, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration _or association with radioactive apparatus or components; and (6) E01, pursuant to the Act and 10 C.F.R. Parts 30 and 70, is licensed to possess, but not separate, such by-product and special nuclear materials as may be produced by the operation of ANO-1.
Further, the licensee hereby requests that the NRC amend Operating License No.
NPF-6 to change the name of the licensee for ANO-2, such that:
(1) E01, pursuant to Section 103 of the Act, as amended, and 10 C.F.R. Part 50, " Licensing of Production and Utilization Ncilities," is licensed to possess, use and operate ANO-2, at the des;gnated location in Pope County, Arkansas, in accordance with the procedures and limitations set forth in the License; (2) AP&L, pursuant to the Act and 10 C.F.R. Part 50, is licensed to possess ANO-2 at the designated location in Pope County, Arkansas, in accordance with the procedures and limitations set forth in the License; APPLICATION TO AMEND - 4
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(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 for reactor operation, as described in the Final l~
Safety Analysis Report, as supplemented and amended; 1
l (4) E01, 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 by-product, 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;.
l (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 by-product, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) E01, pursuant to the Act and 10 C.F.R. Parts 30 and 70, is licensed to possess, but not separate, such by-product and special nuclear materials as may be produced by the operation of ANO-2.
APPLICATION TO AMEND - 5
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4 Other conforming license changes are noted in the attachments to.this Application.2 Set forth below is the information in support of the Application to Amend Facility Operating Licenses Nos. DPR-51 and NPF-6.
I.
GENERAL INFORMATION CONCERNING LICENSE AMENDMENT A.
Proposed Additional Licensee:
Entergy Operations, Inc.
B.
Address:
Echelon One 1340 Echelon Parkway Jackson, MS 39213 C.
Description of Business or Occupation:
Prior to issuance of these license amer.dments, E01 will be organized as a wholly-owned subsidiary of Entergy and will take necessary corporate action to authorize it +o operate Waterford 3, ANO-1, ANO-2, and Grand Gulf Unit 1.
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After approval of these requested amendments and a similar amendment to the Operating Licenses for Waterford 3 and Grand Gulf Unit 1, E01 will be responsible for the operation and maintenance of all nuclear l
plants in the Middle South Electric System, including AN0-1 and 1
ANO-2. Upon receipt of necessary regulatory approvals, E01, as distinct from AP&L as the owner of the facilities, will have 1
responsibility for and control over the physical construction, operation, and maintenance of the facilities.
2 Conforming changes, if necessary, in insurance and indemnity agreements will be made in due course by separate correspondence.
l APPLICATION TO AMEND - 6 6
p D.
Organization and Management of Operating Corporation E01 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 by an alien, a' foreign corporation, nor a foreign government.
All prospective directors and principal officers of E0I are citizens 3
of the United States. Their names and addresses are as follows:
Directors l
Mr. Edwin A. Lupberger Chairman of the Board Entergy Operations, Inc.
P. O. Cox 61005 New Orleans, LA 70161 Mr. William Cavanaugh, III President & Chief Executive Officer Entergy Operations, Inc.
P. O. 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 Bellport Lane Be11 port, NY 11713 Additional directors and officers may be named at a later date.
APPLICATION TO AMEND - 7
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i Directors (Cont.)
' Senior Scientist; Research and Development Brookhaven National Laboratory Mr. Jerry L. Maulden President and Chief Executive Officer Arkansas Power & Light Company P. 0. Box 551-Little Rock, AR 72203 Officers (LATER)
APPLICATION TO AMEND - 8
n Upon iss'uance of these operating license amendments, certain officers of AP&L will become officers of E01.
-E.
Technical Qualifications
-The technical qualifications of E01 to carry out its responsibilities under the Operating Licenses for ANO-1 and ANO-2, as amended, will meet or exceed the present technical qualifications of AP&L. AP&L will continue to act as the operator of ANO-1 and ANO-2, pending issuance of the proposed amendment of the Operating Licenses. When the amendments become effective, E01 will assume responsibility for and control over the physical construction, operation, maintenance, and licensing of the facilities. The present ANO-1 and AN0-2 nuclear organizations will be transferred essentially intact to E01. The technical qualifications of the proposed ANO-1 and ANO-2 organizations 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. E01 has now been designated as the organization to fulfill that role. A central APPLICATION TO AMEND - 9
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objective in' planning.the proposed consolid' ation'and the transf' er of.
employees ~ and operating responsibilities from AP&L~ to'E01 has been
~to minimize disruption to the operation of the plants and to respect the; integrity of the existing. successful organizations. Therefore,
-in the proposed E01 organization, each nuclear organization for the operating plants will be preserved, with the only change.that_the-senior nuclear executive.of AP&L, LP&L and System' Energy will report
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directly to..the Executive Vice President and Chief Operating Officer who reports to the President and Chief Executive Officer'of E01.
This organization is illustrated in Attachment 3.
Thus, for ANO-1 and ANO-2 T. G. Campbell, Vice President, Nuclear, will report directly to' the Executive Vice President and Chief Operating Officer of E0I. The Nuclear Quality organization for the plant will also have direct access to both the Executive Vice President and Chief Operating' Officer and the President and Chief Executive Officer of E01 on matters related to quality.
This organizational approach accommodates the current plant-specific structure of the AP&L organizations. This allows the transfer of
. AP&L nuclear personnel to E01 with virtually no organizational changes or disruption.
It also allows the management for each facility to retain sufficient independence to address plant-specific needs and tv maintain existing priorities and ongoing plant improvement projects.
Importantly, and as discussed below, there will be in the near term no organizational or physical location APPLICATION TO AMEND - 10
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-changes to the existing, dedicated organization, which would include the engineering, quality assurance, and licensing organizations supporting the ANO-1 and ANO-2 plants.
The significant elements and advantages to the proposed E0I
. organization can be summarized as follows:
(1) The structure provides clear lines of authority and responsibility while ensuring that essential nuclear support functions are dedicated to each project and report to a single responsible project executive.
(2) The effectiveness of project quality assurance will not be degraded.
(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.
(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 E01.
APPLICATION TO AMEND - 11
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.(5) The effectiveness of a dedicated nuclear support organization is enhanced by identity with and sharing of the E01 goels and
. objectives.
The consolidation of the System Energy, LP&L, and AP&L nuclear organizations within E01 will be an evolutionary process. The licensees will continue to study possible organizational and programmatic changes to enhance corporate objectives and to realize the full benefits of establishing E01 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 license programs are governed by formal plans which 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 organization which will be responsible for implementing the plan. Changes to such plans that involve a decrease in effectiveness or level of commitment of the plan require prior NRC review and appr; val.
The Quality Assurance Program, the Emergency Plan, and the Security Plan are examples of such programs governed by appropriate regulations.
APPLICATION TO AMEND - 12
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Following issuance of the license amendments approving E01 as operator of ANO-1 and 2, Grand Gulf Unit 1, 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, E01 intends to continue the current AP&L practices of informing the NRC and soliciting their comments on the significant organizational changes affecting ANO-1 and AN0-?.
Special emphasis will be given to any changes involving centralization occurring as a result of the assumption of operating responsibility by E01 for Grand Gulf Unit 1 Waterford 3, and ANO-1 and ANO-2.
i APPLICATION TO AMEND - 13
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Statement of Purposes for the License Amendments p
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The assumption'of operational responsibility for ANO-1 and AN0-2 by E0I (along with. responsibility for Waterford 3 and GGNS, Unit 1)-
wi11' provide benefits inherent to an integrated nuclear operating company. 'Some of the expected benefits are as follows:
~(1)L E01, 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 will enhance the already high level-of public safety and cost-effective plant operation.
o (2) Consolidation of talent not only will result in a merger of
. expertise and experience for system-wide nuclear operational L-
-support, but it~ also 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.
APPLICATION TO AMEND - 14
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.2 (3) EDI will be better 'able; to provide a consistent vision for the j
philosophy of operation of.the system. nuclear units. A company.
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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. philosophy can be used to maintain excellence in all aspects of nuclear operation.
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.(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 all'ow'" 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 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 I
in nuclear power generation.
Further, E01, in its role as a system-wide operating company, should provide an environment in which all employees continue to be motivated toward high performance. E01, with its expanded responsibilities, will also provide greater opportunity for career progression and APPLICATION TO AMEND - 15
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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.
G.
Financial Considerations E01 will be an operating company with r.o ownership interest in ANO-1 and ANO-2. E01, under an operating agreement with AP&L, will be authorized'to operate the plant as the agent of the owner.
- Further, as discussed below AP&L is committed under the operating agreement to provide all funds necessary to continue safe operation of ANO-1 and ANO-2, to shut dcwn AN0-1 and ANO-2, if necessary, and to maintain AN0-1 and ANO-2 in a safe condition all in conformance with NRC regulations. AP&L's financial responsibility for ANO-1 and ANO-2 and its sources of funds to support the facility will remain the same as under the present license.
To summarize, the following interrelations will be established by the operating agreement between AP&L and E0I:
(1) E01 will not have any ownership interest in ANO-1 and ANO-2; however, it will have overall responsibility for plant operations. E01 will operate ANO-1 and ANO-2 in accordance with the operating licenses and shall have exclusive responsibility for making safety decisions.
APPLICATION TO AMEND - 16
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(2). LAP &Lwill'retaincertaincontrolsover_ultimatespending limits, and ~will retain the author.ity to direct.that A.N0-1 and ANO-2 be shut down in an orderly fashion by E01-(and in -
accordance with.L01's safety judgment). This. retained authority wi'l limit E0I's spending authority, but will.not encumber E0T's ability to make operational safety decisions and will hne no impact on safe operation of ANO-1 or ANO-2.
(3) Pursuant.to an operating agreement between E01 and AP&L, all
-costs for the operation, construction, mainten'ance, repair, decontamination and decommissioning of ANO-1 and AN0-2 incurred-or accrued are liabilities of AP&L when incurred or accrued.
Thus, the source of' funds for operating ANO-1 and ANO-2 will remain unchanged.
Further, under 10 C.F.R. 9 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 ANO-1 and ANO-2 will be borne by the owner and accordingly, E01 will have the same financial-qualifications as the present licensees. Those qualifications will be unchanged.
? APPLICATION TO AMEND - 17
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..' Antitrust Considerations
' The plan for E01.' to operate ANO-l' and ANO-2 will not impact the existing ownership of the units. or existing' entitlement to power.
These proposed license. amendments do not require statutory antitrust review pursuant to Section 105 of the Atomic Energy Act and 10
- 1 C.F.R.: 92.101(e),
p 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, c
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
'and loyalty 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.
II.
SPECIFIC INFORMATION REGARDING RELATED ISSUES A.
Emergency Planning Upon approval of the license amendments to authorize operation of ANO-1 and ANO-2 by E01, E01 will assume authority and responsibility APPLICATION T0 AMEND - 18
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l for functions necessary to fulfill the emergency planning requirements specified in 10 C.F.R. 9 50.47(b) and Part 50, Appendix E.
No substantive changes will be made to the existing emergency plans presently implemented by AP&L. -In addition, there will be no changes to the existing Emergency Planning Organization.
Transition plans will be established to ensure that the support described in the existing emergency plans will be maintained throughce the transition and as needed following the transition.
Appropriate action will be taken with respect to existing agreements for support from AP&L, as well as from organizations and agencies not affiliated with the licensees, to notify the parties to such agreements of E01's agency relationship with the owner and E01's responsibility for management and operation of ANO-1 and ANO-2.
This will be accomplished by AP&L prior to the transfer of responsibility.
Following the transfer of operating responsibility to E01, emergency planning support will be provided by AP&L as needed.
In essence, to the extent that personnel, resources, and facilities are not being transferred to E01, AP&L will continue to fulfill selective 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 E01 and AP&L and 2) as necessary, new support agreements will be developed between AP&L and E01. Long-term utilization of AP&L resources in these areas will be based on cost-effectiveness and existing relationships with offsite organizations and agencies.
APPLICATION TO AMEND - 19
_ _ _____________ __- _ - _ - ___ __-___ _ - __ _ _ D
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In sum, the proposed license amendments 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. G 50.54(q) and Appendix E,Section V.
B.
General Design Criterion 17 The amendments to authorize assumption of operating responsibility by E01 involve no changes in the ownership or design of the offsite j
power systems for ANO-1 and ANO-2, or in their operation, maintenance _or testing. Upon approval of the amendments, AP&L will continue to fulfill its current responsibilities 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 plants. Pursuant to this requirement, E01 and i
AP&L will maintain and implement procedures and agreements specifying:
(1) the arrangement for provision of a continued source of offsite power, and (2) the arrangements for controlling operation, maintenance, repair, and other activities with respect to the transmission lines and the switchyard, such that adequate independent sources of offsite power will continue to be provided.
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APPLICATION TO AMEND - 20
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,I In essence, the written procedures and agreements will provide for i
the future interface between E01 and AP&L.
First, AP&L has committed.to providing offsite power to the units. Second, the procedures and agreements will provide for the continuation of current arrangements for the operation and maintenance of the switchyard and associated transmission facilities. The procedures and agreements will also specify that AP&L will obtain concurrence from E01 prior to implementing any changes in the switchyard.
C.
Exclusion Area Upon approval of the amendments providing for assumption of operating responsibility by E01, E01 will have authority to determine all activities within the ANO-1 and AN0-2 exclusion areas, to the extent required by 10 C.F.R. Part 100.
As stated in Chapters 2.2.2 and 2.1.2.1 of the Safety Analysis i
1 Reports (SARs) for AN0-1 and ANO-2 respectively, AP&L controls all 1
surface rights within the exclusion area boundary of the units.
With respect to certain property owned by the United States Government, AP&L controls the area under an easement. Under the operating agreement to be entered into between E01 and AP&L, AP&L will agree to provide E01 with unrestricted access to the property constituting the ANO site, including the facilities, equipment, switchyard, and personal property located on the site. Also, E0I will have authority to exercise complete control over the exclusion areas as designated in the SARs for the plants, and to determine all APPLICATION TO AMEND - 21
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.o activities within those areas ~(including all areas of the site and the switchyard). This authority'will allow E01 to control ingress and egress and to order an evacuation if necessary. To the extent practicable, E01 will, of course, exercise this control in such a fashion that AP&L's access to the switchyard and transmission facilities for proper operation and maintenance of the el :tric systems on the ANO site will not be unduly restricted.
As stated in the SARs, certain activities unrelated to plant operation (e.g., use of roads) will occur in the exclusion area.
There will be no change from the existing situation.
E01 will assume responsibility for the emergency plans as discussed above.
D.
Security The proposed license amendments will not impact compliance with the physical security requirements of 10 C.F.R. Part 73. Upon assumption of operating responsibility, E01 will assume ultimate responsibility for implementation of all aspects of the present 1
security program. Appropriate action will be taken with respect to existing agreements for support from outside organizations and agencies to notify the parties to such agreements of E01's relationship with the owner and E01's responsibility for management and operation of ANO-1 and ANO-2. Changes to the plans to reflect this transition will not decrease the effectiveness of the plans and will be submitted to the NRC within 30 days after the changes are made, in accordance with 10 C.F.R. 9 50.54(p).
APPLICATION TO AMEND - 22 r
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Quality Assurance.
The proposed license amendments will not impact compliance with the quality assurance requirements of 10 C.F.R. 50, Appendix B, nor will they reduce the commitments in the NRC-accepted quality assurance
-program descriptions for ANO-1 and ANO-2. Upon assumption of operating responsibility, E01 will assume the ultimate responsibility for present functions associated with the ANO-1 and ANO-2 quality assurance programs. The organization, function and structure of the nuclear quality organization will not be affected by these license amendments. 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 descriptions.
t F.
Safety Analysis Reports With the exception of areas discussed in this license amendment application. the proposed license amendments will not change or invalidate information presently appearing in the AN0 SARs. Changes necessary to accommodate the proposed license amendments will be incorporated into the AN0-1 and ANO-2 SARs following NRC approval of the license amendment application in accordance with 10 C.F.R. 50.71(e).
APPLICATION TO AMEND - 23
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G.
Training i
L The proposed license amendments will not impact compliance with the operator requalification program requirements of 10 C.F.R. 50.54 and t
related sections, nor maintenance of the Institute of Nuclear Power Operations accreditation for licensed and non-licensed training.
'Upon assumption of operating responsibility for ANO-1 and ANO-2, E01 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).
H.
Engineering Support Currently the engineering support for AN0-1 and ANO-2 is provided by a dedicated engineering organization that is an integral part of the nuclear organization. Because the existing nuclear organization at AP&L will transfer virtually intact to E01 upon approval of these license amendments, 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 for each plant.
Thus, there will be no degradation of the engineering support function and its integration with maintenance and operations. After issuance of the license amendments, as evolutionary changes are made to consolidate i
organizations within E01, E01 will ensure the continued integration of the engineering support function with the maintenance and operation function.
APPLICATION TO AMEND - 24
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III. NO'SIGNIFICANT HAZARDS CONSIDERATION EVALUATION
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j lt PURSUANT TO 10 C.F.R.-50.92 A..
Proposed Change The proposed amendments would revise Facility Operating License No.
'DPR-51 and facility Operating License No. NPF-6 for AN0-1 and ANO-2,.
L' respectively, to authorize E0I to act on behalf of AP&L, with:
responsibility for and control over tt e physical construct'on, r
operation, and maintenance of the fat,ilities-.
B.
Background-o
' Prior to issuance of'these license amendments, E01 will be organized as a_ wholly-owned subsidiary of Entergy. Under the proposed amendments,.E01 would assume all responsibilities for operating
-AND-1 and ANO-2. Under the current operating licenses, these responsibilities are now held by AP&L, which also is a wholly-owned.
subsidiary of Entergy. This application is being filed
. simultaneously with a similar application by LP&L to transfer to E01 operational responsibility for Waterford 3 and by System Energy to transfer to E0I operational responsibility for GGNS, Unit 1.
Under tFe terms of the proposed amendments, the operating licenses for ANO-1 and ANO-2 would recognize E01 as the legal entity which will provide the technical and managerial resources for the continued safe operation of the facilities, and as the entity with APPLICATION TO AMEND - 25 1
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'l exclusive authority to make operational safety dec4sions. The proposed license amendments involve no change in the ownership of i
the facilities'and no physical changes to the plants, and no substantive change to operating procedures.
Funds for operation of the plant will continue to be provided by the owners.
All of the current license conditions will remain in effect and the Lithiting Conditions for Operation, Limiting Safety System Settings, and Safety Limits specified irc the Technical Specifications will remain unchanged. While the emergency plan, security plan, and plant operating and emergency procedures will require administrative changes to reflect E01's role as agent for the owner and as operator of the units, 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 E01, no changes will be made that reduce the commitments in that prog am. A transition plan will eesure an orderly transfer of existing emergency preparedness responsibilities to E01. Written procedures and agreements maintained and implemented by E0I and AP&L will clearly ensure continued compliance with GDC 17. Similarly, the operating agreement will ensure that E01 ht.s authority to determine all activities within the exclusion area.
The technical qualifications of E01 to carry out its responsibilities under the Operating Licenses, as amended, will meet or exceed the present technical qualifications of AP&L. AP&L will APPLICATION TO AMEND - 26
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continue to act as the operator of ANO-1 and ANO-2, pending amendment of the Operating Licenses. When the amendments become effective, E01 will assume responsibility.for, and control over, the physical construction, operation, and maintenance of the facilities.
The present AH0-1 and ANO-2 nuclear organizations will be transferred essentially intact to E01. The technical qualifications of the E01 ANO-1 and ANO-2 organizations therefore will be at least equivalent to those of the existing organization.
The assumption of. operational responsibility for ANO-1 and ANO-2 by E01 (along with responsibility for Waterford 3 and GGNS, Unit 1) will provide benefits inherent to an integrated nuclear operating company.. Some of the expected benefits are as follows:
(1) E0I, 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 will enhance public safety and cost-effective plant operation.
(2) Consolidation of talent not only will result in a merger of expertise and experience for system-wide nuclear operational i
support, but also will permit the specialization of expertise l
in certain areas that might not otherwise be developed if each l
of the companies continued to operate their separate facilities.
l APPLICATION TO AMEND - 27 c
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' (3) -E01 will be better able to provide a consistent vision for the philosophy of operation of the system nuclear units. A company.
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 philosophy can be used to achieve excellence in all aspects of nuclear operation.
(4) As a result of.'the consolidat' ion, 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 be come specialized and 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, E01, in its role as a system-wide operating company, should provide an environment in which all employees continue to be motivated toward high performance. E01, with its expanded responsibilities, will also provide greater opportunity for career progression and APPLICATION TO AMEND - 28 a
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thus greater opportunity.to retain valued employees. More specifically, as a. result of consolidation, salary structures, g 9 career path policies and human resource procedures will be; Lconsistent at each nuclear facility operated by E01.
C.-
Analysis The~ following. discussion provides a specific analysis o'f the proposed change against the three standards delineated in
~
10 C.F.R. 6 50.92-and demonstrates that the proposed change involves no significant' hazards consideration:
1 (1) The proposed change will not increase the probability or consequences of an accident previously' evaluated..The technical qualifications of E01 will be.at least equivalent to those of AP&L presently. Personnel qualifications'will remain L-the same as those discussed in the Technical Specifications and
.the SARs.for ANO-1 and ANO-2.
The employees of System Energy, LP&L and AP&L presently engaged in the operation of GGNS, Unit 1, Waterford 3, ANO-1 and ANO-2 will become employees of E01. The organizational structure of EDI will provide for clear management control and effective i
lines of authority and communication among the organizational units involved in the management, operation, and technical I
support of the facilities.
APPLICATION TO AMEND - 29
w 1
As a result of the proposed amendments, there will not be physical changes to the facilities, and all Limiting Conditions
.for Operation Limiting Safety System Settings, and Safety Limits specified in the Technical Specifications will remain l
unchanged. With the exception of administrative changes to reflect the role of EDI, the quality assurance programs, the emergency plans, security plans and training programs are unaffected. Operating agreements will ensure continued compliance with GDC 17 as well as E01 control over activities within the exclusion areas.
-Therefore, the proposed changes will not increase the probability or consequences of an accident previously evaluated.
l-l (2) The proposed amendments will not create the possibility of a new or different kind of accident from any accident previously evaluated. The design and design bases of ANO-1 and ANO-2 remain the same. Therefore, the current plant safety analyses remain complete and accurate in addressing the licensing basis l
events and analyzing plant response and consequences.
l The Limiting Conditions for Operation, Limiting Safety System Settings and Safety Limits are not affected by the proposed amendments. With the exception of administrative changes to reflect the role of E01, plant operating and emergency procedures are unaffected. As such, the plant conditions for which the design basis accident analyses have been performed APPLICATION TO AMEND - 30
4 are still valid. Therefore, the proposed amendments cannot create the possibility of a new or different kind of accident than previously evaluated.
(3) _ The proposed amendments 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 Specifications. Since there will be no change to the physical design or operation of the plants, there will be no change to any of these margins. The proposed amendments therefore will not involve a reduction in a margin of safety.
D.
Conclusion Based upon the analysis provided herein, the proposed amendments 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 amendments meet the requirements of 10 C.F.R. 50.92(c) and do not involve a significant hazards consideration nor an unreviewed safety L
question.
i APPLICATION TO AMEND - 31
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ENDORSEMENT AND CONSENT-
-AP&L presently the sole licensee, hereby endorses and consents to this application filed under oath or affirmation by T. G. Campbell, Vice President, Nuclear, of AP&L, and the proposed assumption of operating L
and licensing responsibilities for ANO-1 and ANO-2 by EDI as described above.'
/
Mr. R. Drake Keith President and Chief Operating Officer Arkansas Power & Light Company N
APPLICATION TO AMEND - 32
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