ML19352E138

Entry Int. Wolf Creek General Support Services Agreement with Evergy Inc. Entities

ML19352E138
Person / Time
Site:	Wolf Creek
Issue date:	12/10/2019
From:	Benham R Wolf Creek
To:	Balwant Singal Division of Operating Reactor Licensing
References
CAC MG0235, EPID L-2017-LLM-0005, RA 19-0151
Download: ML19352E138 (7)

Text

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MkFCREEK 'NUCLEAR OPERATING CORPORATION Ron Benham Manager Nuclear and Regulatory Affairs December 10, 2019 RA 19-0151 U.S. Nuclear Regulatory Commission AITN:- Balwant Singal

• - --- Wasftidg_t§rCDC 20555-0001

• :-:.Letter dated March 12, 2018, from B. K. Singal, USNRC, to A C. Heflin, WCNOC, "Wolf Creek Generating Station, Unit 1 - Order Approving Indirect Transfer of Control of Renewed Facility Operating License No. NPF-42 (CAC No. MG0235; EPID L-2017-LLM..0005)"

Subject:

Docket No. 50-482: Wolf Creek Generating Station, Unit 1 - Entry int. Wolf Creek General Support Services Agreement with Evergy Inc. entities

Dear Mr. Singal:

Thank.you_ very much for taking time to talk with us recently. This correspondence confirms the call between *wolf Creek Generating Station (WCGS) personnel and the U.S. Nucleat Regulatory Commission (NRC) held December 2, 2019, and provides the requested organizational charts discussed on that call (Enclosures I and 11). Wolf Creek Nuclear Operating Corporation (WCNOC) personnel briefed NRC participants on the call regarding upcoming changes to the various organizations that comprise Evergy Inc. As discussed, WCNOC has reviewed the planned personnel r~rganization against the criteria described ii"!

NRC Regulatory Issue Summary 2001-06 and concludes that this change does not result in either a-direct-or indirect transfer of control of the NRC license for WCGS for which prior NRC consent is required and is consistent with the prior approval granted in Reference 1 for the reasons generally described below and on the call. We felt it important to communicate this to the NRC in advance of the change, and appreciate the NRC staffs time in discussing it *with us. 1 As background, in the Reference, NRC provided its consent for the indirect transfer of control resulting from the combination of the parent companies of two separate 47% owners of WCGS.

Together, the combined parent ("HoldcoD in the Reference), presently named Evergy, Inc. holds 94% of the ownership of both WCGS and the voting stock of WCNOC, the NRC licensed operator of the facility} As a result of the same transaction, WCNOC became part of the larger 1 1n the Reference, by order dated March 12, 2019, the NRG consented to indirect control by Evergy, Inc.,

the parent of Evergy Kansas Central, Inc. (f/k/a Westar Energy, Inc.) and its wholly owned subsidiary, Evergy Kansas South, Inc. (f/k/a Kansas Gas & Electric Company), which is a 47% owner of WGCS.

Please refer to the attached organizational charts, References 2 and 3.

2 The re~aining 6% ownership of WCGS and stock of WCNOC is held by Kansas Electric Power AO[) (

Cooperative. /+

P.O. Box 411 / Burlington, KS 66839 / Pho~: (620) 364-8831 AA Equal Opportunlly, Emplo'f"er M/F/HCNET

RA 19-0151 Page 2 of 2 Evergy group of companies (i.e., Evergy Metro, Inc., Evergy Kansas Central, Inc., and.Evergy Kanas South, Inc.).

Consistent with obtaining the efficiencies of the combined ownership, Evergy now plans to transition WCNOC workers to employees of Evergy Kansas Central, Inc. (f/k/a Westar Energy,

_ Inc), which is the 100% owner of Evergy Kansas South, Inc. (f/k/a Kansas Gas and Electric Company), a 47% owner of WCNOC. This planned personnel reorganization allows Evergy to realize the economic advantages of the benefits of its combined size. Evergy Kansas Central, Inc. is an intermediate parent of WCNOC and will continue to provide operating services (specifically, the same WCNOC personnel) to WCNOC under the Wolf Cree~ General Support Services Agreement. Organization charts, which reftect the relevant corporate relationships pre- and post-merger, are attached.

There will be no change to the Board of Directors or officers or management of WCNOC as a result of this reorganization. Officers and senior managers of WCNOC who currently exercise ultimate decision-making authority over decisions involving nuclear safety or security at WCNOC will retain their positions and authority at WCNOC while also becoming employees of Evergy Kansas Central, Inc. This "dual hattingD of the Chief Nuclear Officer/President and other officers ensures that decisions exercised by those licensee officials may not be modified, overruled, or reversed except by the WCNOC licensee. The makeup of the WCGS site organization will remain unchanged and continue to operate according to the operating licensee's Appendix B programs and procedures. This activity does not result in a functional change to the operating organization, its technical qualifications, the facility, o~ the plant technical specifications.

The Company plans to implement this change effective_ January 1, 2020, and accordingly requests that the NRC inform us at the first opportunity of any questions or concerns that might affect that implementation date. Should you have any questions or comments on this letter please contact the undersigned.

Sincerely,

~Ron Benham RDB/kdl/rlt

Enclosures:

I Simplified Organization Chart II Evergy WCNOC Organization Chart cc: S. A. Morris (NRC, w/e N. O'Keefe (NRC, w/e Document Control Desk (NRC), w/e Senior Resident Inspector (NRC), w/e

Enclosure I to RA 19-0151 Simplified Organization Chart (2 pages)

'Fi2urel Simplified Organizational Chart - Premerger Great Plains Westar Energy Energy, Inc.

Incorporated I

KCP&L KG&E KEPCo 147.0% 47.0% 16.0%

WCNOO WCGS*

• Note: The owners own undivided interests in WCGS and stock in WCNOC.

Figure2 Simplified Organi7.ational Chart- Post-Closing I

Holdco I

Westar Energy, Inc.

KCP&L KG&E KEPCo 47.0% 47.0% 16.0%

WCNOC/

WCGS*

• Note: The owners own undivided interests in WCGS and stock in WCNOC.

,r Enclosure II to RA 19-0151 Evergy WCNOC Organization Chart (1 page)

Kansas Electric Power Cooperative (Kansas) 6.0%

Revised December 2, 2019