ML15009A026
| ML15009A026 | |
| Person / Time | |
|---|---|
| Site: | River Bend, Waterford  |
| Issue date: | 01/02/2015 |
| From: | - No Known Affiliation |
| To: | Division of Administrative Services |
| SECY RAS | |
| References | |
| 79FR71803 00001, NRC-2014-0258 | |
| Download: ML15009A026 (2) | |
Text
RULE' .% '" flRFCTIVESAs of. January 06, 2015Received: January 02, 2015P B6 PH 2: 21 Status: PendingPostPUBLIC SUBM ISSION.", -TP.1 2 racking No. ljz-8geh-zf38Comments Due: January 02, 2015Submission Type: WebDocket: NRC-2014-0258 R E- Q.DConsideration of Approval of Transfer of License and Conforming Amendment; River Bend Station, Unit 1, andWaterford Steam Electric Station, Unit 3Comment On: NRC-2014-0258-0001River Bend Station, Unit 1, and Waterford Steam Electric Station, Unit 3; Consideration of Approval ofTransfer of License and Conforming AmendmentDocument: NRC-2014-0258-DRAFT-0001Comment on FR Doc # 20 14-28422Submitter InformationName: Anonymous AnonymousGeneral CommentRiver Bend Station, Unit 1, and Waterford Steam Electric Station, Unit 3; Consideration of Approval ofTransfer of License and Conforming AmendmentDocket ID: NRC-2014-0258 Agency: Nuclear Regulatory Commission (NRC)You have inaccurately stated the name of the final licensee, as well as the holding company above it, for thesetwo reactors in the Federal Register. As such, you need to reprint and extend the comment period. It is notserious that you cannot even bother to write out the names of the reactor licensees when it is so clearly writtenrepeatedly in the Entergy application documents -even highlighted in red. The name of the Final Licensee isNOT Entergy Louisiana, LLC, as written in the Federal Register, but rather Entergy Louisiana Power, LLC:when the transactions are complete at the end of the day of closing, each owner licensee will have transferred itsassets and liabilities to a new entity, Entergy Louisiana Power, LLC (ELP), that will hold as the owner therespective NRC licenses for RBS and Waterford. This new entity will be owned by a new intermediary holdingcompany named Entergy Utility Holding Company, LLC. Thus, approval of the license transfers is requiredpursuant to 10 CFR 50.80..Upon consummation of the proposed transaction, the former assets and liabilities of ELL and EGSL will beowned by a single operating company, ELP. From CNRO-20 14-00007, June 10, 2014, which is the cover letterto Application for Order Approving License Transfers and Conforming License Amendments, EntergyOperations, Inc. (All Dockets) River Bend Station Docket Nos. 50-458 & 72-49 Waterford 3 Steam ElectricStation Docket Nos. 50-382 & 72-75In contrast, according to the Federal Register regarding transfer of the two nuclear power stations: FollowingSUNSI Review CompleteTemplate = ADM -013E-RIDS= ADM-03Add= 4. .a, (,49) approval of the proposed direct and indirect transfers of control of the licenses, Entergy Louisiana, LLC wouldacquire ownership of Waterford and River Bend..71804 Federal Register / Vol. 79, No. 232 / Wednesday, December 3, 2014 / NoticesTHIS IS INCORRECT-FALSE ACCORDING TO ENTERGY'S APPLICATION!Of even greater concern is the Federal Register-Alan Wang-NRCs conclusion that ELP becomes a subsidiary ofLP&L: resulting in ELP becoming a subsidiary of LP&L. 71804 Federal Register / Vol. 79, No. 232 /Wednesday, December 3, 2014 / Notices While ELP does becomes a subsidiary of the OLD LP&LCOMPANY, the OLD LP&L COMPANY changes its name to Entergy Utility Holding Company, LLC, whichthe Federal Register fails to state. AND, Entergy Energy Company appears no where except to take the name ofthe new entity named Louisiana Power & Light Company, LLC, according to the documents filed by Entergy:the membership interests of Louisiana Power & Light Company, LLC (LP&L LLC)) and liabilities to a newly-formed subsidiary, Entergy Louisiana Power, LLC (ELP). (p. 1) EGSP LLC will merge with and into ELP, withELP surviving the merger. Immediately after that merger, LP&L LLC will change its name to Entergy UtilityHolding Company, LLC, and Entergy Energy Company LLC will change its name to Louisiana Power & LightCompany, LLC. (p. 2) (Application for Order Approving License Transfers and Conforming LicenseAmendments, Entergy Operations, Inc. (All Dockets) River Bend Station Docket Nos. 50-458 & 72-49Waterford 3 Steam Electric Station Docket Nos. 50-382 & 72-75 That is the only place in the application thatEntergy Energy Company, soon to be the NEW Louisiana Power & Light Company LLC appears. Thus wehave no idea what this company does, but it seems to have nothing to do with these two reactors. Thus, to saythat it does is misleading and a potential problem. No record of Entergy Energy Co. is found online. Is itsomewhere in the 14 pages of Entergy subsidiaries found online?Furthermore, if the NRC cannot even accurately state the licensee for the reactors, it is clear that they have notproperly examined what the liability repercussions are of the switch from corporations lying between Entergyand the reactors vs. Limited Liability Companies lying between Entergy and the two reactors. How does the new21% voting rights play in? The fact that LLCs do not keep minutes-records is a serious concern. As well, I mustraise concerns of how having two reactors in a state following the rather unique Napoleonic Code (Louisiana),an entirely different legal system from the rest of the US, will work out with ownership in Texas when a nuclearaccident occurs and for decommissioning and waste liability.WATCH YOUR STEP!