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'vce Rescent . . November 21, 1989

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y Nucleo Opectons

-U.S.: Nuclear Regulatory Commission -MailiStation P1-137>

. Washington, D.C.' 20555 i? ,"

Att$ntion: Document-Control Deskg ,

Gentlemen:SUBJECT: Grand Gulf Nuclear Station e

[ Unit 1

| Docket No. 50-416 ,License No. NPF-29'Entergy Operations, Inc.Proposed Amendment to the OperatingLicense (PCOL-89/07) SupplementalInformationAECM-89/0191 ,

on August 15, 1989, System Energy Resources, Inc. (System Energy),Arkansas Power.and Light Company (AP&L), and Louisiana Power and Light Company

= (LP&L); submitted to-the Nuclear Regulatory Commission proposed license;- amendments to-designate Entergy Operations, Inc. (EOI) as the licensed--

Loperator for Grand Gulf. Nuclear Station (Grand Gulf) Unit 1, Arkansas Nuclear-' .E One (ANO) Units 11and 2, and|Waterford Steam Electric Station, Unit 3 ,

L(Waterford~3), respectively. The proposed amendments are intended to'establish a new company, to be called EOI, as the system-wide nuclear ;

- operating company. -

h Clarification to the System Energy August 15, 1989 application was. provided to the NRC by System Energy in a submittal on August 22, 1989.

~

In response to discussions with NRC staff at meetings on October 12 and19, 1989, System Energy has determined that the propcsed amendment to the:Grand Gulf Unit 1 Operating License as set forth in Attachment 2 to the August15 and August 22, 1989 submittals should be further clarified. Theseclarifications.are described in the Attachment 2 to this letter. A revised

~ markup of;the Grand Gulf Unit 1 Operating License has been provided as<Attachment 4.

,

~ System Energy has reviewed the August 15, 1989 submittal and determinedthat the submittal addresses 10CFR50.80 requirements and contains the

'

applicable information requested by the provisions in 10CFR50.80(b). A-comparison of the August 15, 1989 submittal to 10CFR50.80(b) is included asAttachment 3.

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In-accordance with the provisions of 10CFR50.4, the signed original of ithis submittal is. enclosed and the appropriate copies will be distributed.

The August 15, 1989Eamendment application provides the background andtechnical justification 7to support the requested operating license amendment.

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AECM-89/0191.> 'e,- Piga 2-

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;The| Plant Safety Review Committee has reviewed and approved this additional; ..;information.. 'The Safety Review Conaittee reviewed the original application.

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Yours truly, r

c :> rdsurz:WTC:tkm' !Attachments: 1.' Affirmation per 10CFR50.30, ,

2.. Sunnary Description ofL OL Markup Clarificaticn-'

3. Comparison with Information Requested by 10CFR50.80(b) ,4. PCOL-89/07 Markup of OL

.

cc ' Mr. D.-C.;Hintz'(w/a)~

Mr.'T. H. Cloninger (w/a)>

Mr. J. G..Cesare (w/o)Mr. R. B. McGehee (w/a):Mr. N.' S. Reynolds (w/a)-Mr. H. L. Thomas (w/a) 'Mr..H. 0.. Christensen'(w/a)

Mr. Stewart D.'Ebneter (w/a)-Regional Administrator-U.S. Nuclear: Regulatory CommissionRegion--II,

.,

101 Marietta St., N.W., Suite 29001 Atlanta, Georgia 30323

Mr. L. L'.i.Kintner, Project Manager (w/a)-Office of Nuclear Reactor Regulation'U.S. Nuclear Regulatory CommissionvMail-Stop.14B20Washington, D.C. 20555 I

'

.Mr. Dennis M. Crutchfield..

t-

-Associate Director:for Special Projects~0ffice of Nuclear Reactor RegulationU.S. Nuclear Regulatory | CommissionMail'Stop 7D24 .Washington,.D.C. 20555

Mr. David L. Wigginton, Project Manager. Project Directorate'- IVDivision of Reactor. Projects -'III, IV, V, ;

and'Special Projectszoffice of Nuclear. Reactor RegulationU.S. Nuclear Regulatory CommissionMail Stop'13D18Washington, D.C. 20555 !

-Dr. Alton B. Cobb (w/a)'State-Health OfficerState Board of HealthP.O. Box 1700Jackson, Mississippi 39205,

A9101003/SNLICFLR - 2.

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Attrehment 2 to AECM-89/0191PIga 11

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SUMMARY DESCRIPTION OPERATINGLICENSE MARKUP CLARIFICATION

In response to discussions with NRC staff at a meeting on October 12, 1989, SystemEnergy has determined that the proposed amendment to the Grand Gulf Unit 1 OperatingLicense (OL) as set forth in Attachment 2 to the August 15 and 22, 1989 submittalsshould be further. clarified. The OL markup changes, which are included as Attachment4, are summarized as follows:

Change fromOL Reference 8/15,22/89 Markups Description of Change

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1.A Words_in lines 4 and 5 change to Reworded to betterstate: "(SMEPA), as amended..."- describe application being

amended

1.E First line begins: "Entergy Footnote is unnecessary.Operations, Inc. (EOI) 3n..."Delete footnote at bottom of page.

2.B(2) Add: "but not operate " in Line 2 To be more precise inbetween " possess" and "the" describing SERI and SMEPA

possession of facility

2.B(3) Add: "at the facility site and as To address transshipmentdesignated solely for the of spent nuclear fuel asfacility" in Line 2 between " time" committod in the transmittal.and "special" letter to the August 15, 1989 |

submittal AECM-89/0147

2.B(3) Change in Line 2 first "any" to To correct a typographical"at" error

2 '. C( 3 ) Number paragraph (a). In line 10 Paragraph must be numbereddelete: "of this transfer"; (a) because.(b) is beinginsert: "related to the added. Clarifles what "thisapplication dated September 2, 1986. transfer" means. AdditionalSERI is authorized to transfer its antitrust license condition !rights to operate the facility to paragraph (b) provided. |EOI." (b) MP&L and SERI areresponsible and accountable forthe actions of their respectiveagents to the extent said agents' <

actions contravene the antitrustlicense conditions."

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Att:chment 2.to AECM-89/01911

Pi P g) 2i';' SUMMARY DESCRIPTION OPERATING

LICENSE MARKUP CLARIFICATION;

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!S Change from,'l' -OL Reference' 8/15,22/89 Markups Description of Change!~

2.C(4)(a) Change "EOI" to "EP&L" Grand Gulf Unit 1 entered2.C(5). 'or "EOI's" to-"MP&L"s" Operating Condition 2 >,2.C(6)- _ startup).the first(2.C(8); refueling-outage on2.C(9). November 29, 1986.2.C(10) -Amendment-27 to the -;2.C(11) Grand Gulf Unit 1

j. . 2.C(13). Operating License |! '2.C(14) authorizing SERI toE' -2.C(15)_ assume operating

2.C(16)- responsibility was .'1st sentence issued by-the NRC.

2.C(17) December 20, 1986.-2.C(19) Therefore, OL. commit-2.C(22) ments " prior to2.C(28) , startup following the2.C(29) first refueling i2.C(31) _ outage" were completed

; 2.C(33)(a)| while MP&L was the~

2.C(33)(b) -operator.2.C(33)(c)

| 2.C(33)(d)(1)_.lst sentence

2.C(33)(e) ,~ 2'.C(33)( f) ,2'C(33)(g)- .|.

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-Att:chment|2 to-AECM-89/0191P ga 3 'e

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SUMMARY DESCRIPTION OPERATING'

- LICENSE MARKUP CLARIFICATION

Change from''OL Reference 8/15,22/89 Markups Description of Chango

'2.C(31) Replace "MP&L's" with "the". Makes the wordingclesrer.

2.C(31) Replace first sentence with: Clarifies the wording"The following conditions challbe completed to the satisfactionof the NRC."

2.C(33)(a) Change "MP&L" to "SERI" Corrects an error.

2.C(36) Delete:", as revised through Simplifies theAmendment No.53 to this license" wording

2.C(39) No change Operating LicenseCondition 2.C(39) isno longer in effect.Therefore, 2.F iscorrect on which items -|E0I will reportviolations. f

Appendix C- " Middle South Electric System" Reflects name chango |II.(c) should be "Entergy Corporation" from Middle South

Utilities to EntergyCorporation

Appendix C " Middle South-Electric System" Reflects name change ;jIV.(b) should be "Entergy Corporation" from Middle South :

Utilities to EntergyCorporation.

!EPP Change "E0I" to "GGNS" in Final EnvironmentalPage.4-2 5th line in Subsection 4.2.2. Report is for GGNS ;,,

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- =e.Att chment'3 to AECM-89/0191'

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COMPARISON WITH INFORMATION REQUESTED BY-10CFR50.80(b)'>

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I' INdORMATION REQUESTED LOCATION IN SERI APPLICATION3; ,

A)"-10CFR50.80(b)' LAn, application.for t'ransfer of a license shall-

-include as much of the.information described-..in Section 50.33....-'

Section 50.33

-Section 50.33 Contents.or applications;-generalLinformation'

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Each; application ~shall state:

(a) Name of applicant; -Page 8, Paragraph I.A'

(b)n Address of applicant; Page 8, Paragraph I.B

!(c) Description of business'or occupation Page 8, Paragraph I.C1'

of applicant;,

:(d). If applicant is an

(1) -individual,' state citizenship. Applicant'is-not an-

individual.

'( 2 )' 'If. applicant is a partnership,- Applicant.is not astate name,. citizenship and. partnership.- |address of each' partner and- jthe principal location wherethe partnership does business. l

1 (3) If applicant is a corporation- Pages 9-12, Paragraph.I.D.or an unincorporatedassociation, state:

(1) The state where it isincorporated or organized.and the principal locationwhere'it does business;

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Atttchnant 3 to AECM-89/0191;,m|- Pzg; 2- ,. #.

COMPARISON WITH INFORMATION REQUESTED BY 10CFR50.80(b)

,,

INFORMATION REQUESTED LOCATION IN SERI APPLICATION '{

h A) .10CFR50.80(b) (continued)

SECTION 50.33 (continued)

(11) Whether it is owned,controlled, or dominatedby-an alien, a foreign ,corporation, or government,-and if so, give details;

(4) If the applicant is acting as page 1, Transmittal letter; lagent or representative of Page 2 of Application; i

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another person in filing the page-18, Paragraph I.Gapplication, identify theprincipal and furnishinformation required'under thisparagraph with respect to suchprincipal.

(e) The class of license SERI Operating License and'

cpplied for, the use to all other licenses willwhich the facility will be remain unchanged except forput, the period of time for changes to reflect transfer

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which the-license is sought, of operating responsibilityand a list of other to E0I.licenses, except operator'slicenses, issued or appliedfor in connection with theproposed facility.

(f) Except for an electric Ownership does not change.utility applicant for a Financial qualifications'license to operate a remain the same,

utilization facility of the See Pages 18-20,type' described in Section Paragraph I.G.=50.21(b) or Section 50.22,information sufficient to

7

demonstrate to theCommission the financialqualification of theapplicant to carry out,in accordance withregulations in this chapter,

| the activities for whichthe permit or license issought. As applicable, thefollowing should beprovided:

i

A9101003/SNLICFLR - 11.-

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p Atttchment 3'to AECM-89/0191I ,1 i

Pag 3 3 ~O a; ,

'* COMPARISON WITH INFORMATION. REQUESTED,BY,10CFR50.80(b)

INFORMATION REQUESTED LOCATION IN SERI APPLICATION

. A) _.10CFR50.30(b) (continued).

SECTION 50.33 (continued)~

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(1) If the application is This application is not for.for a construction a construction permit.

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permit,-the applicantshall submit

,' information that>demonstrates that theapplicant possessesor has reasonable

rt ' assurance of obtainingthe funds necessary tocover estimated-construction costs.The applicant shall <submit estimates of-the total constructioncosts of the facilityand related fuelcycle _ costs, and shallindicate the source (s)of funds to coverthese costs.

(2) If the application is pages 18-20, Paragraph I.G, 7'

for an operating . but as stated on Page 20, a-license, the applicant full financial review undershall submit 50.33 is not required since~information that sources of funds'for operatingdemonstrates the costs will remain theapplicant possesses or responsibility of the ownershas reasonable -- not EOI. 'assurance of obtaining :

the funds necessary-'to cover estimated

operation costs for theperiod of the license.The applicant shallsubmit estimates fortotal annual operating

,.

" ' costs for each of thefirst five years ofoperation of thefacility. The applicantshall also indicate the

source (s) of funds tocover these costs.An application to renew

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:- Atttchmcnt.3 to AECM-89/0191

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(. COMPARISON WITH INFORMATION REQUESTED By.10CFR50.80(b)c;f, '

.,INFORMATION REQUESTED LOCATION IN SERI APPLICATION '

. A)- 10CFR50.80(b) (continued)- ;,

!SECTION 50.33'(continued),

or extend the term of-an operating licensemust include the samefinancial information-as is required in anapplication for aninitial license.

(3) Each application for a Pages 18-20, Paragraph I.G ;construction permit or Also, Pages 8-9an operating license Paragraph I.C-submitted by a ,newly-formed ;entity organized forthe primarypurpose of constructingor operating a facilitymust also includeinformation showing:

(1) The legal ~andfinancial relation- -,ships it has orproposes to havewith its stock-. holders or owners; t

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(ii) Its financialability to meetany contractualobligation tothe-entity whichthey have incurredor proposed toincur; and

(iii) Any other informa-tion considerednecessary by theCommission toenable it todetermine theapplicant'sfinancialqualification.

A9101003/SNLICFLR - 13o

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Attachment 3 to AECM-89/0191Pago 5 -

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p.; COMPARISON.WITH INFORMATION REQUESTED By 10CFR50.80(b)h

-INFORMATION REQUESTED LOCATION IN SERI APPLICATION

.A)~ 10CFR50.80(b) (continuedht

Section 50'.33 (continued)'(4) The Commission may Pages 18-20, Paragraph I.G

request an established Sources of funds for,

entity or newly-formed operating costa-will remainentity to submit the responsibility of theadditional or more- owners -- not EOI.detailed information '

respecting itsfinancial arrangementsand statuc of fundsif-the Commission'considers this-information

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appropriate. Thismay includeinformation regarding-a licensee's abilitys ,to continue the conductof the activities |authorized bythe license and to,decommissionthe facility. '

(g) If the application is for Pages 21-23, Paragraph II.Aan operating license for a-nuclear power reactor, theapplicant shall submitradiological emergancy

. . .'response plans of State andlocal governmental entitiesin the United States-thatare wholly or partially ~within the plume exposure ;pathway Emergency Planning

'

Zone (EFZ), as well as theplans of State governmentswholly or partially withinthe ingestion pathway EPZ.Generally, the plumeexposure pathway EPZ fornuclear power reactorsshall consist of an areaabout 10 miles (16 km) inradius and the ingestionpathway EPZ shall consistof an area about 50 miles

A9101003/SNLICFLR - 14

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Attachment 3 to AECM-89/0191'Pag) 6

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Att chment 3 to AECM-89/0191'LL Pig 3 7P . : '-C COMPARISON WITH INFORMATION-REQUESTED By 10CFR50.80(b) .

. INFORMATION REQUESTED LOCATION IN SERI APPLICATION

I;.. .A)" 10CFR50.80(b) (continuedlc ':

Section 50.53 (Continued)

p activity, and a list of .F . trade and news publications

which circulate in the4 area where.the proposed().L . activity will be

conducted and which are' considered appropriate to'give reasonable notice of .

the application to those ;

municipalities, privateutilities, public bodies, :and cooperatives, whichmight have a potential !interest in the facility.

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(j) If the application contains- Page 21, Paragraph I.IRestricted Data or other However, application does notdefense information, it contain Restricted Data,

shall be prepared in such. manner,that all Restricted-

Data and other defenseinformation are' separatedfrom the unclassifiedinformation.

(k) (1) For an application for Decommissioning reportan operating license -required by 50.33(k) andfor-a production or described in.50.75 will beutilization facility,- submitted on or before'information in form of July 26,'1990. See |

a report, as described 50.33(k)(2).In Section 50.75 ofthis part, indicatinghow reasonable assurancewill be provided thatfunds will be available

7

to decommission thefacility. 1

(2) On or before See above.July 26, 1990, eachholder of an operatinglicense for aproduction orutilization facility

A9101003/SNLICFLR - 16

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Atttchment:3 to AECM-89/0191,

pig 3 8.e,

COMPARISON WITH INFORMATION REQUESTED.BY 10CFR50.80(b)

INFORMATION REQUESTED LOCATION IN SERI APPLICATION

A)7-10CFR50.80(b) (continued).1

Section 50.33 (cont'inued).

'in effect onJuly 27, 1990, shallsubmit information in '.the form of a reportas described in Section50.75 of this part,indicating how'

reasonable assurancewill-be provided that-funds will be availableto decommission thefacility.

.B)- JO_qR50.80(b)-(continued)

. and 50.34 of.this part with respect See below.. .Eto the identification and technical andfinancial qualifications of the proposedtransferee as would be required by thosesections if the application were for aninitial license, and-if the license to beissued is a class 103 license, the

-information required by Section'50.33a.

'Section 50.33a'

Contains requirements relating to Pages 20-21, Paragraph I.Hinformation requested by the Attorney. See also, AECM-89/0199 ;General for antitrust review dated October 27, 1989

Section 50.34

Contains requirements for PSAR and FSAR UFSAR will remain unchangedsubmittals. except for areas.specifically

discussed in application and-other conforming changes.See Page 28, Paragraph II.F.See also Pages 12 - 16,,Paragraph I.E; and Pages18-20, Paragraph I.G

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Attichment 3 to AECM-89/0191; _ P:ga 9

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COMPARISON WITH INFORMATION REQUESTED By 10CFR50.80(b)

INFORKATION REQUESTED LOCATION IN SERI APPLICATION4

.C) 10CFR50.80(b) (continued)

The Commission may require additional Safeguards data and programsinformation such as data respecting proposed in UFSAR will remainsefeguards against hazards from radioactive unchanged. See Page 28,materials and-the applicant's qualifications Paragraph II.F. Also seeto protect against such hazards. Pages 12-16, Paragraph I.E

regarding E0I's Technical

Qualifications.

D); ICCFR50.80(b) (continued)<

The application shall include also a -Statement of Purpose -

statement'of the purposes for which the Pages 16-18, Paragraph I.F.transfer of the license is requested, thenature of the transaction necessitating Nature of transaction makingor making desirable the transfer of the the transfer desirable - i

license,-and an agreement to limit access Pages 16-18, Paragraph I.F,to Restricted Data pursuant to 550.37. also Pages 12-16,The' Commission may require any person who Paragraph I.E.submits an application for licensa pursuantto the provisions of this section to file a Agreement to Limit Restricted

. written consent from the existing licensee Data - Page 21,or a certified copy of an order or judgment. Paragraph I.I'of.a court of competent jurisdiction attesting ' Written consent filed for-to the person's right (subject to the licensing SERI and SMEPA in AECM-89/0178requirements of-the'Act and these regulations) dated September 27, 1989.to possession of the facility involved.

A9101003/SNLICFLR - 18

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