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

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

ML20245J472
Person / Time
Site:	Waterford
Issue date:	08/15/1989
From:	Dewease J LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
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
W3P89-1458, NUDOCS 8908180044
Download: ML20245J472 (5)

Text

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T 4-samhmm %s -. LoulInin2 Powir & Light CompIny

' 317 Barmne Street

'~T 'P. O. Box 60340 Now Orleans, LA 70160-0340-W3P89-1458 A4.05 QA l

J August 15,.1989

-U.S.. Nuclear Regulatory Commission I Mail Stati'on F1-137' Attn: Document Control Desk l Washington, D.C. .20555

SUBJECT:

.Waterford 3 SES Docket No. 50-382 License No. NPF-38 t Change Request No. NPF-38-99' Entergy Operations, Inc. License Amendment Application Gentlemen:

1 BACKGROUND l,

In a request to the Nuclear Regulatory Commission on July 1, 1988,' Louisiana

' Power 6 Light Company (LP&L) submitted a proposed license amendment to desig-nate_ System Energy Resources,.Inc. (System Energy) as the licensed operator {

i for Waterford-3. LP&L and System Energy are wholly-owned subsidiaries. of l Entergy Corporation (Entergy), formerly known as Middle South Utilities, Inc.

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Entergy now plans for a new company, to be called Entergy Operations, Inc. l (E01), to'become its-system-wide nuclear operating company-instead of System Energy as originally proposed. E01 will be a wholly-owned subsidiary of Entergy.

LP&L hereby submits the attached application to amend FacilityL0perating l License No. NPF-38 for Waterford Unit 3. This' application requests NRC l approval for E01 to assume operating and management responsibility for- 'I Waterford 3. This letter, in combination with similar letters from AP&L and System Energy, provides joint information relative to'the applications-  ;

and the status / schedule of other required state and federal regulatory '

l approvals. .The submittal from LP&L supplements the previous' license amendment application' filed on July 1, 1988. 1

-i OPERATING AGREEMENTS j Draf ts of the proposed AP&L/E0I, LP&L/E01 and System Energy /E01 Operating Agreements are scheduled to be submitted to the Securities and Exchange Commission (SEC) in September 1989 as part of the application of System Energy, AP&L and LP&L requesting approval of the proposed consolidation.

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[ PDR ADOCK 050003Sf p PDC.

An Entorgy Conipany '

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.1 W3P89-1458 q Change Request No. NPF-38-99 1 Entergy Operations, Inc. License Amendment Application Page 2 August 15,_1989 LP&L filed a draft of its Operating Agreement with EDI with the Louisiana Public Service Commission (LPSC) on August 10, 1989. A copy of the formal submittal to the SEC including all of the draf t Operating Agreements will be submitted to the NRC for review contemporaneously with' the SEC filing. j The Operating Agreements include the provisions described in the application 1 which is attached.

PAYMENT OF CIVIL PENALTIES a

Any civil penalties levied by the NRC, if' and when they may be incurred by E01 for Waterford 3 related activities, should be levied by the NRC against E0I.

The NRC should expect payment to be made by E01.

STATUS OF REGULATORY APPROVALS The plan for EDI to assume operating and management responsibility for )

Waterford 3 is subject .to the approval of the LPSC. LP&L has filed with  ;

the LPSC for Waterford 3 an application seeking approval for E01 to assume I operating responsibility. Furthermore, LP&L intends to file an application l with the Council of the City of.New Orleans asking the Council for a letter I of non-opposition to the proposed consolidation. Also in September, AP&L, I LP&L and System Energy plan to file an application with the SEC seeking I approval of the proposed consolidation. Progress toward these regulatory approvals required for the consolidation effort will proceed independently '

i of each other. Therefore, it is requested that the NRC issue the Safety Evaluation Report (SER) for the consolidation request separately from the operating license amendment approval. LP&L will make a separate request I for issuance of the license amendment at such time as other prerequisite regulatory approvals have been obtained and E01 is ready to assume operating responsibility for Waterford 3. System Energy will keep the NRC informed of  !

the status of regulatory agency reviews.

PUBLIC INFORMATION The system-wide communications plan developed for the. consolidation activities '

in mid-1988 has been updated to keep key internal and external audiences up to date. Specifically, plans call for press releases at appropriate regulatory milestones, and periodic meetings with state and local officials as well as community leaders. Employees have been kept informed through the Nuclear  ;

Horizons newsletter which has been published six times in 1989. l Employees will continue to be kept informed by publication of Nuclear Horizons, .;

[ employee meetings, plant visits and video tapes. Dates for these actions will correspond to appropriate regulatory activities or other milestones.

Shareholders will be brought up to date through a Nuclear Consolidation update in the Entergy Corporation Quarterly Report brochure scheduled for release September 1, 1989.

e W3P89-1458 Change Request No. NPF-38-99 Entergy Operations, Inc. License Amendment Application Page 3 August 15, 1989 SIGNIFICANT ORGANIZATIONAL CHANGES Selected licensee programs are governed by formal plans which require NRC review and acceptance or approval. Tne 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 commitment of the plan require prior NRC review and approval. The Quality Assurance Program, the Emergency Plan, and the Security Plan are examples of such programs governed by appro-priate regulations.

Following issuance of a license amendment approving E0I as operator of Waterford 3, E0I 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, EDI will make a determination as to whether or not NRC review and prior approval is required in accordance with the appropriate provisions of 10 CFR 50.54 or other applicable regulations.

In addition, E0I intends to continue the current LP&L practice of informing the NRC and soliciting their comments on significant organizational changes af fecting Waterford 3. Special emphasis will be given to any changes involving centralization or consolidation occurring subsequent to approval of the license amendments.

FUEL TRANSSHIPMENT BETWEEN SITES Your letters of July 28, 1988 and July 29, 1988 stated that the NRC-intends to stipulate in license conditions that fuel not be relocated between ANO and Waterford 3 without specific NRC review and approval. Such a license condition would be consistent with our understanding of the regulations and the licenses as proposed to be amended. This condition is also consistent with the commitments regarding fuel transshipment in our July 1, 1988 submittals. E01-also will not relocate fuel between Grand Gulf Unit 1 and the other two sites.

SYSTEM ENERGY ENDORSEMENT AND CONCURRENCE l I

This letter in combination with similar letters from AP&L and System Energy provide joint submittals on E01 becoming the system-wide nuclear operating company. LP6L endorses and concurs with the AP&L and System Energy applications.

Yours very truly,

)

. . Dewease J D/WTE/MJM/dc l

m________________.___1_______ __ a

7-W3P89-1458 Change Request No. NPF-38-99

Entergy Operations, Inc. License Amendment Application Page 4.

August 15, 1989 1.

(' cc: Messrs. E.L. Blake-W.M. Stevenson F.J. Hebdon D.L. Wigginton R.D. Martin D.M. Crutchfield NRC Resident Inspector's Office (W3)

Administrate'or Nuclear Energy Division (State of LA)

Office of Environmental Affairs P.O. Box 14690' Baton Rouge, LA 70898 American Nuclear Insurers The Exchange Suite 245-270 Farmington Avenue Farmington, Conn. 06032 l

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of )

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Louisiana Power & Light Company ) Docket,No. 50-382 Waterford 3 Steam Electric Station )

AFFIDAVIT J.G. Dewease, being duly sworn, hereby' deposes and says that he is Senior Vice President-Nuclear Operations of Louisiana Power & Light Company; that.

he is duly authorized to sign and file with-the Nuclear Regulatory Commission the attached. Operating License Change Request NPF-38-99; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.

7 J.G Dewease e for Vice President-Nuclear Operations STATE OF LOUISIANA)

)ss PARISH OF ORLEANS )

Subscribed and sworn to before me, a Notary Public in and f for the Parish and State above named this /(A day of Gu n..< A ,

1989. ,)

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44LJ4 Notary Public l

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My Commission expires MM _

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