W3P88-1243, Forwards Application for Amend to License NPF-38,reflecting NRC Approval for Sys Energy Resources,Inc to Assume Responsibility for Plant Operation.Fee Paid

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Forwards Application for Amend to License NPF-38,reflecting NRC Approval for Sys Energy Resources,Inc to Assume Responsibility for Plant Operation.Fee Paid
ML20150B597
Person / Time
Site: Waterford 
Issue date: 07/01/1988
From: Dewease J
LOUISIANA POWER & LIGHT CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20150B598 List:
References
W3P88-1243, NUDOCS 8807120083
Download: ML20150B597 (6)


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LOUISIANA 317 BARONNE STREET P. O. 80X 60340 MIDDLE SOUTH UTIUTIES SYSTEM J. G. DEWE A S E stuct vnt ontsesur.

NUGtAR OrtRA TONS July 1, 1988 W3P88-1243 A4.05 QA U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 (Change Request No. NPF-38-83)

SERI License Amendment Application for Waterford 3 Attn:

Mr. Dennis M. Crutchfield, Director Division of Reactor Projects III, IV, V and Special Projects Gentlemen:

Louisiana Power & Light (LP&L), as the licsnsee for Waterford 3, hereby submits the enclosed application to amend facility operating license No. NPF-38.

This application requests NRC approval for System Energy Resources, Inc. (SERI) to assume responsibility for operation of Waterford 3.

In order to effect this change, the existing LP&L nuclear organization will be transferred, virtually intact, to SERI. Thus, essentially the same organization and staff currently responsible for operating Waterford 3 will continue those responsibilities as a part of SERI.

The application to amend the LP&L operating license contains the information to effect the requested transfer of licensed activities,and to amend the operating license.

In addition, the application contains the significant hazards consideration evaluation required by 10CFR50.92 and

$o 50.91.

A more detailed description of the application is set forth below.

882 ts o As the NRC is aware. this license amendment application is associated with the consolidation of nuclear operations of LP&L, Arkansas Power & Light 00 0 Company (AP&L), and SERI. To ensure that complete and accurate information (W

is submitted to the NRC and to provide what can he called the "total

$o picture" of the associated licensing activities germane to LP&L's y

application, this letter provides certain factual information and describes similar licensing actions planned by AP&L. A similar license amendment j

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a oh application is being forwarded under separate cover by AP&L addressing l

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SERI's assumption of operating responsibilities for Arkansas Nuclear One, Units 1 and 2 (ANO 1 and 2).

The NRC should rely on AP&L's license go

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d.h "AN EQUAL OPPORTUNITY EMPLOYER"

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Pags 2 W3P88-1243 amendment application for information specif.cally pertaining to AP&L and ANO 1 and 2.

Similarly, the NRC should rely on any submittals forwarded by SERI for information on SERI operations at the Grand Gulf Nuclear Station (GCNS).

A.

INTRODUCTION By wsy of background, LP&L, SERI, and AP&L are wholly-owned subsidiaries of Middle South Utilities, Inc. (MSU). LP&L is oresently licensed to own and operate Waterford 3.

AP&L is licensed to os2 and operate ANO 1 and 2.

SERI is presently licensed to own and operate GGNS, Unit 1, and to own and construct GGNS, Unit 2.

For reasons discussed in the application, MSU has decided that SERI will become its system-wide nuclear operating company.

Under the MSU plan, SERI will assume all responsibilities for the management and operation --

but not ownership -- of Waterford 3.

Similarly, as discussed in AP&L's amend-ment application, SERI will assume operating responsibilities of ANO 1 and 2.

The enclosed amendment application specifically addresses SERI's assump-tion of responsibilities for Waterford 3.

B.

OPERATING RESPONSIBILITIES As described in greater detail in the attached application, the transfer of operating responsibilities will be accomplished for Waterford 3 by an operating agreement between the owner (LP&L) and the new operator (SERI).

This agreement will give SERI exclusive authority to made operational safety decisions and to conduct licensing activities with the NRC.

Under the agree-ment, SERI's costs of operating Waterford 3 will be paid by LP&L, as the owner of the unit, and LP&L will be entitled'to all power generated at Water-ford 3.

Although the operating agreement has not been completed as of this filing, we will make it available to the NRC as soon as practicable and, in any event, prior to issuance of the proposed amendment.

C.

OPERATIONAL / ORGANIZATIONAL CRANGES LP&L, AP&L, and SERI have taken a system-wide approach, with strong management oversight, to direct the task of consolidating management of the MSU plants. A special consolidation organization, drawing on resources and expertise from all three companies, has been specifically set up to ensure that licensing and other relevant substantive issues are addressed. One clear objective of consolidation activities has been to minimize disruption due to the changes, and to assure that there is no degradation to organiza-tional performance or public safety.

The above philosophy has been particularly manifest in the planning of the new SERI integrated operating organization. As discussed in the enclosure, the present application does not contemplate any major organizational changes in LP&L's nuclear organization, other than the transfer of personnel to SERI. The present nuclear organization will

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.g Page 3' W3P88-1243 remain' essentially in place, with a change only to the lines of authority such that the Senior Vice President - Nuclear Operations for Waterford 3 will report directly to the President and Chief Executive Officer of SERI. The Waterford 3

-Quality Assurance Department will also have direct access to the President and Chief Executive Officer of SERI on matters related to quality.

It is anticipated that SERI will in the future, after issuance of this amendment, be considering organization changes to achieve further. integration and efficiencies. However, those changes have not yet been identified and are not part of, or necessary for, the present application. Any such future changes will be governed by an internal policy that will provide appropriate management conttols and assure the continued integration of critical support functions.

In addition, SERI will inform the NRC in advance of planned organization changes which involve major restructuring of.line or nuclear support functions at its nuclear facilities and that are important to plant safety. This commitment shall remain in effect until the NRC and SERI mutually agree that it is no longer required.

A guiding principle of the consolidation task force has been to recognize that MSU currently has three strong, successful organizations operating its plant s.

The reorganization plan therefore specifically acknowledges and maintains the special needs of each existing nuclear organization. Individual plant priorities and ongoing plant improvement initiatives will not be adversely impacted by the consolidation.

Additionally, and in response to an NRC staff concern regarding future operational activities, it is recognized that the operating license for Waterford 3 would not permit the transfer of spent fuel between Waterford 3 and any other facility operated by SERI without specific regulatory approval.

D.

NOTIFICATIONS AND APPROVALS l

While the assumption of responsibilities for Waterford 3 by SERI requires the consent of certain creditors and the review and/or approval of federal and state agencies other than the NRC, it is anticipated that these consents, reviews, or approvals will be completed prior to the end of this year. The NRC will be kept informed of the progress of these parallel efforts and wil'.,

of course, be informed in writing should it appear that any of these actions l

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will not be completed in a reasonable time.

The consclidation task force has also been committed to keeping other relevant state and local of ficials, and the public, informed with respect to j

the MSU nuclear plan. The NRC will be kept informed of these informational activities.

E.

SCHEDULE Finally, with respect to scheduling, it is our intent to submit this application concurrently with the AP&L amendment application for ANO 1 and 2.

In order that administrative matters associated with the change L

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.W3P88-1243 (including the transfers of personnel from LP&L to SERI) can be completed in a timely and orderly fashion, it is requested that the Waterford 3 amendment be issued simultaneously with that for ANO 1 and 2.

We.are

' seeking,.however, to implement the proposed changes as soon as-practicable, gz '

consistent with obtaining other necessary regulatory approvals. Therefore, we request your expeditious review and approval.

This application and the-proposed. amendment has been reviewed.and approved by the Waterford 3 Plant Operations Review Committee.and Safety Review' Committee. As discussed in the application, LP&L has concluded that the proposed amendment to the Waterford 3 operating license does not involve an unreviewed safety question nor a significant hazards consideration.

Yours very truly, gh _O

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J.GI ewease for-Vice President -

i clear Operations JGD/MJM/pim

Enclosures:

NPF-38-83 Filing fee - $150 cc:

R.D. Martin, J.A. Calvo, D.L. Wigginton, NRC Resident Inspectors Office, E.L. Blake, W.M. Stevenson,. Administrator Nuclear Energy Division (State of Louisiana), American Nuclear Insurers i

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i

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In the matter of-

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' Louisiana Power & Light Company

) Docket No. 50-382 l

Waterford 3 Steam Electric Station

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AFFIDAVIT

.J.G. Dewease, being duly sworn, hereby deposes and says that he is Senior Vice President-Nuclear Operations of Louis'.ana Power,6 Light Company; that he is duly authorized to sign snd file with the Nuclear Regulatory Commission the attached Operating License Change Request NPF-38-83; that he is familiar with the content thereof; end that the matters set forth therein are true and correct to the best of his knowledge, information and belief.

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. :. Ile1lrease ior Vice President-Nuclear Operations

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' STATE OF LOUISIANA)

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PARISH OF ORLEANS )

Subscribed and sworn to befor me, a Notary Public in and for the Parish and State above named this d

day of 1988.

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My Commission expires i

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NPF-38-83 i

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