ML18319A347

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ISFSI, River Bend, Unit 1 & ISFSI, Waterford, Unit 3, & ISFSI, Grand Gulf, & ISFSI, Transfer of Control of License - Order Response
ML18319A347
Person / Time
Site: Grand Gulf, Arkansas Nuclear, River Bend, Waterford  Entergy icon.png
Issue date: 11/15/2018
From: Halter M
Entergy Operations
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
CNRO 2018-00048
Download: ML18319A347 (9)


Text

Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5573 Mandy K. Halter Director, Nuclear Licensing 10 CFR 50.80 10 CFR 50.90 CNRO 2018-00048 November 15, 2018 U.S. Nuclear Regulatory Commission Director of the Office of Nuclear Reactor Regulation ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Transfer of Control of License - Order Response Arkansas Nuclear One, Units 1 & 2 and ISFSI Docket Nos. 50-313, 50-368 & 72-13 River Bend Station Unit 1 & ISFSI Docket Nos. 50-458 & 72-49 Waterford 3 Steam Electric Station & ISFSI Docket Nos. 50-382 & 72-75 Grand Gulf Nuclear Station & ISFSI Docket Nos. 50-416 & 72-50

References:

1) Entergy Operations, Inc. (EOI) letter to U. S. Nuclear Regulatory Commission (NRC), "Arkansas Nuclear One, Units 1 & 2 and ISFSI, River Bend Station Unit 1 & ISFSI, Waterford 3 Steam Electric Station &

ISFSI, Grand Gulf Nuclear Station & ISFSI, Application for Order Approving Transfers of Licenses and Conforming License Amendments," dated September 21, 2017 (ADAMS Accession No. ML17268A213)

2) NRC letter to EOI, "Arkansas Nuclear One, Units 1 and 2; Grand Gulf Nuclear Station, Unit 1; River Bend Station, Unit 1; and Waterford Steam Electric Station, Unit 3 - Orders Approving Direct and Indirect Transfers of Facility Operating Licenses, " dated August 1, 2018 (ADAMS Accession No. ML18177A236, ML18177A237, ML18177A235, ML18177A234)

Entergy Operations, Inc. (EOI) requested in a letter dated September 21, 2017 (Reference 1),

pursuant to Section 184 of the Atomic Energy Act of 1954, as amended (the Act), 10 CFR 50.80, and 10 CFR 50.90, acting on behalf of the subject licensees, as well as their parent companies and itself (the Applicants), that the NRC issue an Order and conforming license

CNRO 2018-00048 Page 2 of 3 amendments approving the transfers of control of the Facility Operating and Independent Spent Fuel Storage Installation Licenses for Arkansas Nuclear One, Units 1 & 2 (ANO) and Grand Gulf Nuclear Station (GGNS), and if required, the Facility Operating and Independent Spent Fuel Storage Installation Licenses for River Bend Station (RBS) and Waterford 3 Steam Electric Station (Waterford). This request was approved in NRC letter dated August 1, 2018, (Reference 2).

Reference 2, Enclosure 1, "ANO, Units 1 and 2, Order," contained the following condition:

Before completion of the proposed transaction, EOI shall provide the Director of the Office of Nuclear Reactor Regulation satisfactory documentary evidence that EAL [Entergy Arkansas, LLC] has obtained the appropriate amount of insurance required of the licensees under 10 CFR Part 140 and 10 CFR Part 50.

The Enclosure of this letter contains a letter from American Nuclear Insurers (ANI) dated October 11, 2018 covering the 10 CFR Part 140 requirements and a letter from Nuclear Electric Insurance Limited (NEIL) dated November 15, 2018 covering the 10 CFR Part 50 requirements. These letters provide evidence that EAL has obtained the appropriate insurance for ANO.

Reference 2, Enclosure 1, "ANO, Units 1 and 2, Order," Enclosure 4, "RBS Order," and , "Waterford Order," each contained the following order:

IT IS FURTHER ORDERED that, after receipt of all required regulatory approvals of the proposed transfer actions, EOI shall inform the Director of the Office of Nuclear Reactor Regulation in writing of such receipt, and of the date of closing of the transfers, no later than 5 business days before the date of the closing of the transfers.

EOI is hereby informing the Director of the Office of Nuclear Reactor Regulation that the date of closing will be on or about November 30, 2018.

EOI has reviewed the Draft Conforming Amendments for ANO Unit 1, ANO Unit 2 and Grand Gulf Nuclear Station (Grand Gulf) that were provided in Reference 2. ENO finds these are acceptable and request the amendments be issued with an effective date of November 30, 2018.

This letter contains no new regulatory commitments.

Should you have any questions or require additional information, please contact Bryan Ford, Senior Manager Regulatory Assurance, at (601) 368-5516.

Respectfully, Mandy K. Halter

CNRO 2018-00048 Page 3 of 3 MKH/chm

Enclosure:

Proof of Insurance Letters for ANO cc: NRC Region IV Regional Administrator NRC Project Manager - ANO NRC Project Manager - RBS NRC Project Manager - Waterford NRC Project Manager - Grand Gulf NRR Project Manager - EOI NRC Senior Resident Inspector - ANO NRC Senior Resident Inspector -RBS NRC Senior Resident Inspector -Waterford NRC Senior Resident Inspector -Grand Gulf

bcc w/o attachments:

C. Bakken (ECH)

Applicable COO(s)

John Ventosa - COO (GGN, WF3, RBS)

Lawrence Coyle - COO (ANO)

Applicable Site Vice President(s)

ANO GGN RBS WF3 K. Jury (ECH)

R. Gaston (ECH)

M. Halter (ECH)

J. Giddens (ECH)

B. Ford (ECH)

L. J. Smith (ECH) bcc w/ attachments:

Applicable Regulatory Assurance Manager(s)

ANO GGN RBS WF3

ENCLOSURE CNRO 2018-00048 Proof of Insurance Letters for ANO (4 Pages Follow)

Jason Martinez, CPCU, ARM, ARe Director, Underwriting October 11, 2018 Attn: Document Control Director, Office of Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 205550001 Re: Entergy Arkansas, LLC NRC Operating License Transfer for Arkansas Nuclear One (ANO)

Entergy Mississippi, LLC NRC Operating License Transfer for Grand Gulf Nuclear Station To Whom It May Concern, This letter confirms that American Nuclear Insurers will write nuclear liability insurance for Entergy Arkansas, LLC for Arkansas Nuclear One (ANO), Units 1 & 2 and Entergy Mississippi, LLC for the Grand Gulf Nuclear Station.

As of the date of the license amendment, which is expected to be on or before November 30, 2018, we will amend the policy and certificates for the Arkansas Nuclear One (ANO) as follows:

a. Facility Form Policy No. NF 0210: ANI will amend the named insured to Entergy Arkansas, LLC and Entergy Operations, Inc. in lieu of Entergy Arkansas, Inc. and Entergy Operations, Inc.
b. Master Worker Certificate No. NW 0590: ANI will amend the named insureds to Entergy Arkansas, LLC and Entergy Operations, Inc. in lieu of Entergy Arkansas, Inc.

and Entergy Operations, Inc.

c. SFP Certificate No. N 0048: ANI will amend the named insureds to Entergy Arkansas, LLC and Entergy Operations, Inc. in lieu of Entergy Arkansas, Inc. and Entergy Operations, Inc.
d. SFP Certificate No. N 0048: ANI will add Entergy Arkansas, LLC to the Bond for payment of retrospective premiums. Entergy Arkansas, LLC is assuming all past and future liabilities of Entergy Arkansas, Inc. for the payment of retrospective premiums.

American Nuclear Insurers 95 Glastonbury Blvd., Suite 300 Glastonbury, CT 06033-4453 jmartinez@nuclearinsurance.com Voice: (860) 682-1341 Fax: (860) 659-0002

Attn: Document Control October 11, 2018 Page 2

e. SFP Certificate No. N 0068: ANI will amend the named insureds to Entergy Arkansas, LLC and Entergy Operations, Inc. in lieu of Entergy Arkansas, Inc. and Entergy Operations, Inc.
f. SFP Certificate No. N 0068: ANI will add Entergy Arkansas, LLC to the Bond for payment of retrospective premiums. Entergy Arkansas, LLC is assuming all past and future liabilities of Entergy Arkansas, Inc. for the payment of retrospective premiums.

We will also amend the policy and certificates for the Grand Gulf Nuclear Station as follows:

a. Facility Form Policy No. NF 0257: ANI will amend the named insured to Entergy Mississippi, LLC, Entergy Operations, Inc., System Energy Resources, Inc. and Cooperative Energy, a Mississippi electric cooperative in lieu of Entergy Mississippi, Inc., Entergy Operations, Inc., System Energy Resources, Inc. and Cooperative Energy, a Mississippi electric cooperative.
b. Master Worker Certificate No. NW 0619: ANI will amend the named insureds to Entergy Mississippi, LLC, Entergy Operations, Inc., System Energy Resources, Inc. and Cooperative Energy, a Mississippi electric cooperative in lieu of Entergy Mississippi, Inc., Entergy Operations, Inc., System Energy Resources, Inc. and Cooperative Energy, a Mississippi electric cooperative.
c. SFP Certificate No. N 0079: ANI will amend the named insureds to Entergy Mississippi, LLC, Entergy Operations, Inc., System Energy Resources, Inc. and Cooperative Energy, a Mississippi electric cooperative in lieu of Entergy Mississippi, Inc., Entergy Operations, Inc., System Energy Resources, Inc. and Cooperative Energy, a Mississippi electric cooperative.
d. SFP Certificate No. N 0079: ANI will add Entergy Mississippi, LLC to the Bond for payment of retrospective premiums. Entergy Mississippi, LLC is assuming all past and future liabilities of Entergy Mississippi, Inc. for the payment of retrospective premiums.

The commitment to write insurance for Arkansas Nuclear One (ANO) and Grand Gulf Nuclear Station remains valid thru December 31, 2018. In the event the license transfers occurs after this date, ANI will review the existing circumstances prior to reinstating our commitment to provide insurance.

Attn: Document Control October 11, 2018 Page 3 Please feel free to contact me with any questions or concerns.

Yours sincerely, Jason Martinez, CPCU, ARM, Are Director, Underwriting C: Entergy - Rispoli, Ron & Murphy, Megin Stephens - Wilson, Mike

NEILCJ ---

MICHAEL W. KOLODNER, CPCU, ARM, ARE Vice President - Underwriting Nuclear Electric Insurance Limited 1201 N Market St, Suite 1100 Wilmington, DE 19801 November 15, 2018 office +1 302 573 2263 mobile +1 302 588 5654 mkolodner@myneil.com Eric Olvera Indemnity Specialist U.S. Nuclear Regulatory Commission Mail Stop 12D3 1 White Flint North Rockville, MD 20852 Re: . Entergy Arkansas, LLC

Dear Mr. Olvera:

This letter confirms that Nuclear Electric Insurance Limited will write nuclear property insurance for Entergy Arkansas, LLC as the owner of 100% of Arkansas Nuclear One. The insurance will be effective on the date of the transfer of the licensed plant from Entergy Arkansas, Inc. to Entergy Arkansas, LLC.

Effective on the closing date of the asset transfer, the following Primary Property and Decontamination Liability Policies, and Decontamination Liability, Decommissioning Liability and Excess Property Insurance Policies, for Arkansas Nuclear One will be amended to delete Entergy Arkansas, Inc. and add Entergy Arkansas, LLC:

Arkansas Nuclear One - P18-045 and BX18-001 The combined limits on the above policies will satisfy the NRC required minimum property insurance limit of $1.06 billion in accordance with 1 O CFR 50.54(w).

This commitment to write nuclear property insurance for Arkansas Nuclear One remains valid through December 31, 2018. If the asset transfer takes place after that date, we will review the circumstances before re-stating our commitment.

Sincerely, Michael W. Kolodner, CPCU, ARM, ARe Vice President - Underwriting cc: Ronald Rispoli, Megin Murphy, Jager Smith, Bryan Ford, Howard Mahan, Katelyn Fowler, Scott Lauch Ian, Peter Cavanaugh