ML20209A833
| ML20209A833 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 04/23/1987 |
| From: | Kingsley O SYSTEM ENERGY RESOURCES, INC. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| AECM-87-2-0002, AECM-87-2-2, NUDOCS 8704280289 | |
| Download: ML20209A833 (6) | |
Text
._ _ _ ____________
EVEREM ENERGY REEDtJRCEE, INC.
Ouc D. KrGSLEY. JR
[MU$em April 23, 1987 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Document Control Desk Gentlemen:
SUBJECT:
Grand Gulf Nuclear Station Unit 2 Docket No. 50-417 Construction Permit No. CPPR-19 Extension of Unit 2 Construction Permit - Amended Request AECM-87/2-0002
References:
(1) J. B. Richard letter to H. R. Denton, " Extension of Construction Permit Date, Grand Gulf Unit 2," AECM-84/2-0003, dated August 15, 1984.
(2) E. G. Adensam letter to J. B. Richard, Grand Gulf Nuclear Station, Unit 2 " Extension of Construction Permit Date,"
dated August 22, 1985.
(3) W. Cavanaugh, III letter to W. J. Dircks, " Status of GGNS Unit 2," AECM-85/2-0018, dated September 20, 1985.
(4) T. M. Novak letter to W. Cavanaugh, III, dated October 24, 1985.
In reference (1), Mississippi Power & Light Company (MP&L) requested an extension of Construction Permit No. CPPR-19 for Grand Gulf Nuclear Station (GGNS) Unit 2 to April 30, 1991.1/ Effective December 20, 1986, Construction Permit No. CPPR-19 was amended to substitute System Energy Resources, Inc. (SERI) for MP&L as the licensee responsible for licensing activities for GGNS Unit 2. SERI owns a 90% undivided ownership interest in GGNS. For the reasons set forth below, SERI herein amends Reference (1) and requests that Construction Permit No. CPPR-19 be amended to reflect a latest estimated construction completion date for GGNS Unit 2 of January 1, 1997. SERI submits that good cause exists for this extension as discussed below:
87042802s9 870423 PDR ADOCK 05000417 A PDR-
-1/ The construction completion date currently set forth in CPPR-19 is October 1, 1984. Because MP&L timely filed for an extension of the construction permit in Reference (1), pursuant to 10 C.F.R. 50.55(b), the construction permit remains in effect. See 10 C.F.R. 2.109.
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AECM-87/2-0002 Page 2 l
I In Reference (1), MP&L requested an extension of the Construction Permit based upon reduced construction activities at GGNS Unit 2. In December 1979, SERI reduced construction activities on GGNS Unit 2 because of the unavailability of funds necessary to continue the full construction of both GGNS Unit 1 and GGNS Unit 2 at the same time and because of the need to concentrate its resources on the completion of GGNS Unit 1. SERI anticipated that funds would become available for GGNS Unit 2 after commencement of commercial operation of GGNS Unit 1. SERI therefore assumed in submitting Reference (1) that " full construction" of GGNS Unit 2 would resume in 1985, and that the estimated latest construction completion date of the Unit would be April 1991. In connection with its review of MP&L's application, the NRC Staff, in Reference (2), requested MP&L to provide it with additional information regarding the future plans of SERI for GGNS Unit 2.
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Shortly thereafter, in September 1985, the Mississippi Public Service Commission (MPSC) issued an order instructing SERI and MP&L to suspend immediately all construction activities that were being performed at GGNS Unit
- 2. In Reference (3), MP&L notified the NRC that the limited construction activities that were still being conducted on GGNS Unit 2 had been suspended following the MPSC order. Further, as a result of subsequent discussions between MP&L and the NRC Staff, the Staff, in Reference (4), agreed to allow MP&L to defer a response to the Staff's request for additional information on future plans for GGNS Unit 2 until after SERI had made a decision regarding completion of the Unit.
In December 1985 SERI, following the direction of the Board of Directors of Middle South Utilities, Inc. (MSU), determined to continue with full suspension of construction on GGNS Unit 2 pending a comprehensive evaluation of available options for the future of the plant. In this regard, in early 1986, a special group of Middle South System officials was organized to evaluate and review GGNS Unit 2. Among the alternatives evaluated by the group were: (1) cancellation of the Unit, (2) continued suspension of construction on the Unit through 1989 or beyond, when future load and energy requirements may be more definitive and the Middle South System's financial capabilities are expected to be less restrictive, and (3) conversion of the Unit to an alternate fuel source. This group completed its review in November 1986.
On December 5, 1986, the SERI Board of Directors (with the MSU Board of Directors concurring) adopted the recommendations of the study group that suspension of construction activities on GGNS Unit 2 be continued and that a further decision be made by 1990 on the future status of GGNS Unit 2, in light of alternatives available at that time. SERI was directed by the Board to continue during the suspension period to evaluate various alternatives for the future of GGNS Unit 2. It is the opinion of the SERI and MSU Boards of Directors that during the period construction on the Unit is suspended present uncertainties regarding demand for electricity in the region served by the Middle South System, the costs of completing a nuclear power plant, and potential for alternatives for electric generation will be further clarified.
During this time, SERI believes that the best interest of the Middle South System would be served by keeping open the option of completing GGNS Unit 2
- at a later date.
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AECM-87/2-0002 Page 3 Under financial agreements to which SERI is a party, SERI must limit capital expenditures (other than those required by regulation) to $80 million per annum in the aggregate for both GGNS Unit 1 and GGNS Unit 2. This covenant, which will remain in effect until 1989, will not allow resumption of full construction of GGNS Unit 2 prior to 1989. However, the current forecast of load growth in the Middle South System suggests that at the expected growth rate, capacity additions of the size of GGNS Unit 2 will be needed by 1995 at the earliest and 1999 at the latest. Since the estimated cost to complete GGNS Unit 2 is comparable to the estimated cost to build other generation alternatives being considered, GGNS Unit 2 remains a viable alternative to meet expected capacity needs in the Middle South System in the mid to late 1990's.
In September 1985 when construction was suspended, engineering for GGNS Unit 2 was approximately 90% complete, and field construction was approximately 35% complete based on the estimated manhours needed to complete the Unit. Most of the major components and equipment for the Unit have been delivered to SERI i and paid for. Some of the pieces of equipment are installed in their permanent locations. SERI will submit information regarding preservation of Unit 2 equipment in May of 1987.
Based upon this current status of the plant, SERI is amending its 1984 construction permit amendment application (Reference (1)) to reflect the possibility of resuming GGNS Unit 2 construction in 1990. Assuming full construction beginning in 1990, the earliest estimated construction complete date is January 1, 1995. The latest estimated construction completion date is January 1, 1997.
SERI submits that in accordance with 10 C.F.R. 50.55(b) there is " good cause" for the proposed construction permit extension. In Texas Utilities Electric Company (Comanche Peak Steam Electric Company), CLI-86-15, 24 NRC 397 (1986), the Commission explained that good cause may exist both for past and future delays. The Commission specifically clarified that a permittee may demonstrate good cause for an extension if delays have been or will be the result of a valid business purpose. Id. at 400-401; Washington Public Power Supply System (WPPS Nuclear Project No. 2), ALAB-722,17 NRC 546, 551-53 (1983). Such good cause niay be based upon need for power, cost of completion, and the lack of financial resources available to the utility to support continued construction. Compare Public Service Company of New Hampshire (Seabrook Station, Unit 2), CLI-84-6, 19 NRC 975, 979 at n.2 (1984).
GGNS Unit 2 has been delayed in the past due to lack of financial resources available to support continued construction of the Unit. The current decision to continue the suspension in construction of the Unit is based on a slower growth rate of electrical power than had been originally projected in the Middle South System and a present lack of financial resources available to SERI to continue with construction. Furthermore, current uncertainty as to the ultimate cost of the Unit and recent controversies over GGNS Unit 1, including the adverse reaction of various state and local rate regulatory bodies to allocation and payment of costs of that Unit, have contributed to the delay in the construction of Unit 2. Nevertheless, because of the large investment already made in GGNS Unit 2 and of the potential that the Unit can still be an J12AECM87031201 - 3
AECM-87/2-0002 Page 4 economical source of power for the Middle South System in the 1990's, MSU and SERI believe that the option to complete the Unit should be retained. Deferral is therefore based on valid business purposes. Good cause for the extension requested exists and the extension is for a reasonable period of time.
In Reference (2), the NRC Staff sought additional information regarding the original request (Reference (1)) for an extension of the GGNS Unit 2 construction permit. The NRC Staff requested "an update of the estimated latest construction complete date" and " additional justification to show that good cause exists for the requested extension." This information is provided above. However, in Reference (2), the Staff " recommended" three actions to be taken for environmental protection during construction completion. SERI's response to this item is provided in Attachment 1. Finally, in Reference (4),
the Staff also requested that the licensees address its " plans for a quality assurance program for safety-related Ecuipment . . . during the period of suspended construction." Consistent with the Commission's proposed policy statement on deferred plants (52 Fed. Reg. 8075), SERI will provide quality assurance information in May of 1987.
As always, if you require any additional information or further clarification regarding this request, please let me know.
Yours t uly, f
ODK:rg Attachment cc: Mr. T. H. Cloninger (w/a)
Mr. R. B. McGehee (w/a)
Mr. N. S. Reynolds (w/a)
Mr. H. L. Thomas (w/o)
Mr. R. C. Butcher (w/a)
Dr. J. Nelson Grace, Regional Administrator (w/a)
U. S. Nuclear Regulatory Commission Region II 101 Marietta St., N. W., Suite 2900 Atlanta, Georgia 30323 J12AECM87031201 - 4
- l Attachment to AECM-87/2-0002 Page 1 RESPONSE TO NRC REQUEST RELATED TO GRAND GULF NUCLEAR STATION UNIT 2
- 1. (a) RECOMMENDATION Approximately one year before loading fuel into Unit 2 MP&L should report to NRC on the current status of all environmental permits and approvals and should provide NRC with a description of any post OL-FES design changes having potential environmental impacts.
RESPONSE
One year. prior to loading. fuel into Unit 2, SERI will report to the NRC on the current status of all environmental permits and approvals and will provide the NRC with a description of any post OL-FES design changes having potential environmental impacts.
(b) RECOMMENDATION Site runoff control structures, catchment basins, and sedimentation ponds should be maintained until the site' is graded to final eleva .
tions and reseeded or otherwise stabilized.
RESPONSE
Site runoff control structures and sedimentation ponds will remain until the site is graded to its final elevations and seeded. However, maintenance of the sediment basins will not include maintaining a minimum volume in these basins. The original Environmental Protection Program was modified on December 31, 1981, by Amendment 7 to Construction Permits CPPR-118 and CPPR-119, to delete monitoring and capacity requirements for sediment retention basins at the Grand Gulf Nuclear Station (GGNS).
(c) RECOMMENDATION The environmental protection program should continue until OL issuance.
RESPONSE
The GGNS Environmental Protection Program was designed to monitor the impact of construction on the environs surrounding GGNS and to protect that environment. During the period of suspended construction, SERI will meet this objective. During this period, most environmental surveillance activities associated with the GGNS Unit 2 Environmental Protection Program will be performed in concert with'the operational environmental protection program for Unit 1.
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Attachmznt to AECM-87/2-0002 ~
Page 2' However, with construction on Unit 2 suspended, some aspects of the Environmental Protection Program will be unnecessary. These include the following:
1... Dust Control and Monitoring
- 2. Noise Control
- 3. Chemical and Solid Waste Management
- 4. Vegetation Surveys
- 5. Unit 2 Dewatering
~
Upon resumption of construction of GGNS Unit 2, SERI will reinstate these elements of the Environmental' Protection Program as appropriate to the scheduled activity.
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