ML16090A346

Big Rock ISFSI - Financial Test for Decommissioning Funding Parent Guarantees for the Year Ending December 31, 2015, Per 10 CFR Part 30 App. a

ML16090A346
Person / Time
Site:	Big Rock Point  File:Consumers Energy icon.png
Issue date:	03/30/2016
From:	John McCann Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
ENOC-16-00007
Download: ML16090A346 (7)

Text

Entergy Nuclear Operations, Inc 1340 Echeclon Parkway Jackson, MS 39213 Tel 601-368-5667 John F. McCann Vice President

- Regulatory Assurance ENOC-1 6-000 07 March 30 , 201 6 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

-0001

SUBJECT:

Financial Test for Decommissioning Funding Parent Guarantees for the year ending December 31, 201 5 per 10 CFR Part 30 App. A Big Rock Point ISFSI Docket Nos. 50-155 / 72-043 License No. DPR

-6

Dear Sir or Madam:

This letter provides the documents to support the continued use of a parent company guarantee to provide financial assurance of decommissioning funds for the Big Rock Point Independent Spent Fuel Storage Installation (ISFSI), pursuant to 10 CFR 50.75(e)(1)(iii)(B).

The licensee requested that Entergy Corporation's independent certified public accountant, Deloitte & Touche, LLP, evaluate the company's off

-balance sheet transactions and provide an opinion on whether those transactions could materially adversely affect the company's ability to pay for decommissioning costs, as required by 10 CFR 30 Appendix A. Deloitte & Touche, LLP stated that it does not provide opinions of that nature. Nevertheless, Entergy Corporation's management has concluded that the amount of decommissioning

-related parent guarantees at issue is very small as compared to the balance sheet amounts , and in its opinion, off

-balance sheet transactions would not be expected to affect the company's ability to pay for decommissioning costs. The company's off

-balance sheet transactions are described in its Securities and Exchange Commission filings, in particular, its 10

-Q and 10-K filings.

Entergy Corporation previously had provided a $40 million guarantee in support of Vermont Yankee decommissioning financial assurance. Because the $40 million guarantee for Entergy Nuclear Vermont Yankee, LLC, is no longer needed for financial assurance, by letter dated December 19, 2014, Entergy Corporation gave notice that it was canceling the $40 million guarantee effective 120 days after receipt of the notice by the NRC and Entergy Nuclear Vermont Yankee, LLC (Accession No. ML14358A252). In a letter from the NRC to Entergy Nuclear Operations, Inc

, and Vermont Yankee Nuclear Power Station dated April 21, 2015, the NRC determined that Entergy Corporation had complied with the general requirements of 10 CFR 30 Appendix A (III)(A) and granted Entergy Corporation the right to cancel the

$40 million

ENOC-16-00007 Page 2 of 6 parent company guarantee for Vermont Yankee (Accession No. ML15107A074).

The Vermont Yankee parent company guarantee has been cancelled.

There are no new commitments made in this letter. If you have any questions, please contact Mr. Guy Davant, Manager, Fleet Licensing Programs, 601

-368-5756. Sincerely , JFM / ghd / ljs Attachments:

1. Entergy Corporation Parent Guarantee for Fiscal Year Ending 12/31/2015

2. Independent Accountant's Report on Applying Agreed

-Upon Procedures cc: Mr. J. A. Aluise (ENT) Mr. C. Bakken (ECH)

Mr. B. E. Green (TMBR)

Mr. D. J. Mannai (WPO)

Mr. T. G. Mitchell (ECH

) Mr. L. Jager Smith (ECH)

Mr. C. J. Wamser (VTY)

Mr. A. J. Vitale (PAL)

Mr. J. A. Ventosa (ECH)

Mr. T. Ngau (ECH)

USNRC Regional Administrator, Region I USNRC Regional Administrator, Region III USNRC Project Manager, Palisades USNRC Project Manager, Big Rock Point USNRC Project Manager, Vermont Yankee USNRC Resident Inspector, Vermont Yankee Michigan Department of Environmental Quality Michigan Public Service Commission Vermont Department of Public Service Downs Rachlin Martin PLLC

/ St. Johnsbury, VT

ENOC-16-000 07 Attachment 1 Entergy Corporation Parent Guarantee for Fiscal Year Ending 12/31/2015

March 14, 201 6 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington DC 20555

-0001

Subject:

Entergy Corporation Parent

- Guarantee of Funds for Decommissioning: Letter from Chief Financial Officer to Demonstrate Financial Assurance

I am the chief financial officer of Entergy Corporation, 639 Loyola Avenue, New Orleans, LA 70113, a corporation. This letter is in support of this firm's use of the financial test to demonstrate financial assurance, as specified in Title 10, Part 50, of the Code of Federal Regulations (10 CFR Part 50).

This firm guarantees, through the parent company guarantee submitted to demonstrate compliance under 10 CFR Part 50, the decommissioning of the following facilit y owned or operated by subsidiaries of this firm. The current cost estimate or certified amount for decommissioning, and the amount being guaranteed, is shown for the facility: Name of Location of Current Amount Being Facility Facility Cost Estimate Guaranteed Big Rock Point Independent Spent Fuel Storage Installation License Nos. DPR

-06, SFGL-16 Charlevoix, MI

$ 2,430,000 1 $ 5,000,000 Entergy Corporation is required to file a Form 10

-K with the U.S. Securities and Exchange Commission for the latest fiscal year.

The fiscal year of Entergy Corporation ends on December 31 st. The figures for the following items (Financial Test II) marked with an asterisk are derived from Entergy Corporation's independently audited, year

-end financial statements and footnotes for the latest completed fiscal year, ended December 31, 2015

. I hereby certify that the content of this letter is true and correct to the best of my knowledge.

_____________________________

Andrew S. Marsh Executive Vice President and Chief Financial Officer

________________________

Date 1 See 10 CFR §72.30 filing for Big Rock Point, dated December 17, 2015, Accession No. ML15351A524

FINANCIAL TEST: ALTERNATIVE II (10 CFR Part 30 App. A.Section II A.2.)

Entergy Corporation Parent Guarantee of Funds For Decommissioning Dollars in thousands

1. Guaranteed amount for Big Rock Point Independent Spent Fuel Storage Installation, License No s. DPR-06, SFGL-16 (total cost of all cost estimates should be stated in paragraphs above)

$5,000 2. Current rating of most recent bond issuance of this firm Rating Baa3 corpora te credit rating as of October 9, 201 5 Name of rating service Moody's 3. Date of issuance of bond July 1, 2015

4. Date of maturity of bond July 22, 2022

• 5. Tangible net worth** (if any portion of estimates for decommissioning is included in total liabilities on your firm's financial statements, you may add the amount of that portion to this line)

$9, 186,191 *6. Total assets in United States (required only if less than 90 percent of firm's assets are located in the United States) N/A Yes No 7. Is line 5 at least $21,000?

X

8. Is line 5 at least 6 times line 1?

X

9. Are at least 90 percent of firm's assets located in the United States? If not, complete line 10.

X 10. Is line 6 at least 6 times line 1?

N/A

11. Is the rating specified on line 2 "BBB" (including adjustments of + and

-) or better (if issued by Standard & Poor's) or "Baa" (including adjustments of 1, 2, or 3) or better (if issued by Moody's)? X __________

• Denotes figures derived from financial statements.

• • Tangible net worth is defined as net worth minus goodwill, patents, trademarks, and copyrights.

RECONCILING SCHEDULE ENTERGY CORPORATION YEAR ENDED DECEMBER 31, 2015 Dollars in thousands Per Recon- Per Line Number in Financial ciling CFO's CFO's Letter Statements Items Letter Total Assets

$44,64 7,681 Less: Total Current Liabilities (3,089,958)

Less: Total Non

-Current Liabilities (31,982,747)

Less: Goodwill (377,172)

Less: Net Book Value of Big Rock Point (11,613) Tangible Net Worth $ 9,186,191 $ 9,186,191 ENOC-16-000 07 Attachment 2 Independent Accountant's Report on Applying Agreed

-Upon Procedures

Entergy Nuclear Operations, Inc 1340 Echeclon Parkway Jackson, MS 39213 Tel 601-368-5667 John F. McCann Vice President

- Regulatory Assurance ENOC-1 6-000 07 March 30 , 201 6 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

-0001

SUBJECT:

Financial Test for Decommissioning Funding Parent Guarantees for the year ending December 31, 201 5 per 10 CFR Part 30 App. A Big Rock Point ISFSI Docket Nos. 50-155 / 72-043 License No. DPR

-6

Dear Sir or Madam:

This letter provides the documents to support the continued use of a parent company guarantee to provide financial assurance of decommissioning funds for the Big Rock Point Independent Spent Fuel Storage Installation (ISFSI), pursuant to 10 CFR 50.75(e)(1)(iii)(B).

The licensee requested that Entergy Corporation's independent certified public accountant, Deloitte & Touche, LLP, evaluate the company's off

-balance sheet transactions and provide an opinion on whether those transactions could materially adversely affect the company's ability to pay for decommissioning costs, as required by 10 CFR 30 Appendix A. Deloitte & Touche, LLP stated that it does not provide opinions of that nature. Nevertheless, Entergy Corporation's management has concluded that the amount of decommissioning

-related parent guarantees at issue is very small as compared to the balance sheet amounts , and in its opinion, off

-balance sheet transactions would not be expected to affect the company's ability to pay for decommissioning costs. The company's off

-balance sheet transactions are described in its Securities and Exchange Commission filings, in particular, its 10

-Q and 10-K filings.

Entergy Corporation previously had provided a $40 million guarantee in support of Vermont Yankee decommissioning financial assurance. Because the $40 million guarantee for Entergy Nuclear Vermont Yankee, LLC, is no longer needed for financial assurance, by letter dated December 19, 2014, Entergy Corporation gave notice that it was canceling the $40 million guarantee effective 120 days after receipt of the notice by the NRC and Entergy Nuclear Vermont Yankee, LLC (Accession No. ML14358A252). In a letter from the NRC to Entergy Nuclear Operations, Inc

, and Vermont Yankee Nuclear Power Station dated April 21, 2015, the NRC determined that Entergy Corporation had complied with the general requirements of 10 CFR 30 Appendix A (III)(A) and granted Entergy Corporation the right to cancel the

$40 million

ENOC-16-00007 Page 2 of 6 parent company guarantee for Vermont Yankee (Accession No. ML15107A074).

The Vermont Yankee parent company guarantee has been cancelled.

There are no new commitments made in this letter. If you have any questions, please contact Mr. Guy Davant, Manager, Fleet Licensing Programs, 601

-368-5756. Sincerely , JFM / ghd / ljs Attachments:

1. Entergy Corporation Parent Guarantee for Fiscal Year Ending 12/31/2015

2. Independent Accountant's Report on Applying Agreed

-Upon Procedures cc: Mr. J. A. Aluise (ENT) Mr. C. Bakken (ECH)

Mr. B. E. Green (TMBR)

Mr. D. J. Mannai (WPO)

Mr. T. G. Mitchell (ECH

) Mr. L. Jager Smith (ECH)

Mr. C. J. Wamser (VTY)

Mr. A. J. Vitale (PAL)

Mr. J. A. Ventosa (ECH)

Mr. T. Ngau (ECH)

USNRC Regional Administrator, Region I USNRC Regional Administrator, Region III USNRC Project Manager, Palisades USNRC Project Manager, Big Rock Point USNRC Project Manager, Vermont Yankee USNRC Resident Inspector, Vermont Yankee Michigan Department of Environmental Quality Michigan Public Service Commission Vermont Department of Public Service Downs Rachlin Martin PLLC

/ St. Johnsbury, VT

ENOC-16-000 07 Attachment 1 Entergy Corporation Parent Guarantee for Fiscal Year Ending 12/31/2015

March 14, 201 6 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington DC 20555

-0001

Subject:

Entergy Corporation Parent

- Guarantee of Funds for Decommissioning: Letter from Chief Financial Officer to Demonstrate Financial Assurance

I am the chief financial officer of Entergy Corporation, 639 Loyola Avenue, New Orleans, LA 70113, a corporation. This letter is in support of this firm's use of the financial test to demonstrate financial assurance, as specified in Title 10, Part 50, of the Code of Federal Regulations (10 CFR Part 50).

This firm guarantees, through the parent company guarantee submitted to demonstrate compliance under 10 CFR Part 50, the decommissioning of the following facilit y owned or operated by subsidiaries of this firm. The current cost estimate or certified amount for decommissioning, and the amount being guaranteed, is shown for the facility: Name of Location of Current Amount Being Facility Facility Cost Estimate Guaranteed Big Rock Point Independent Spent Fuel Storage Installation License Nos. DPR

-06, SFGL-16 Charlevoix, MI

$ 2,430,000 1 $ 5,000,000 Entergy Corporation is required to file a Form 10

-K with the U.S. Securities and Exchange Commission for the latest fiscal year.

The fiscal year of Entergy Corporation ends on December 31 st. The figures for the following items (Financial Test II) marked with an asterisk are derived from Entergy Corporation's independently audited, year

-end financial statements and footnotes for the latest completed fiscal year, ended December 31, 2015

. I hereby certify that the content of this letter is true and correct to the best of my knowledge.

_____________________________

Andrew S. Marsh Executive Vice President and Chief Financial Officer

________________________

Date 1 See 10 CFR §72.30 filing for Big Rock Point, dated December 17, 2015, Accession No. ML15351A524

FINANCIAL TEST: ALTERNATIVE II (10 CFR Part 30 App. A.Section II A.2.)

Entergy Corporation Parent Guarantee of Funds For Decommissioning Dollars in thousands

1. Guaranteed amount for Big Rock Point Independent Spent Fuel Storage Installation, License No s. DPR-06, SFGL-16 (total cost of all cost estimates should be stated in paragraphs above)

$5,000 2. Current rating of most recent bond issuance of this firm Rating Baa3 corpora te credit rating as of October 9, 201 5 Name of rating service Moody's 3. Date of issuance of bond July 1, 2015

4. Date of maturity of bond July 22, 2022

• 5. Tangible net worth** (if any portion of estimates for decommissioning is included in total liabilities on your firm's financial statements, you may add the amount of that portion to this line)

$9, 186,191 *6. Total assets in United States (required only if less than 90 percent of firm's assets are located in the United States) N/A Yes No 7. Is line 5 at least $21,000?

X

8. Is line 5 at least 6 times line 1?

X

9. Are at least 90 percent of firm's assets located in the United States? If not, complete line 10.

X 10. Is line 6 at least 6 times line 1?

N/A

11. Is the rating specified on line 2 "BBB" (including adjustments of + and

-) or better (if issued by Standard & Poor's) or "Baa" (including adjustments of 1, 2, or 3) or better (if issued by Moody's)? X __________

• Denotes figures derived from financial statements.

• • Tangible net worth is defined as net worth minus goodwill, patents, trademarks, and copyrights.

RECONCILING SCHEDULE ENTERGY CORPORATION YEAR ENDED DECEMBER 31, 2015 Dollars in thousands Per Recon- Per Line Number in Financial ciling CFO's CFO's Letter Statements Items Letter Total Assets

$44,64 7,681 Less: Total Current Liabilities (3,089,958)

Less: Total Non

-Current Liabilities (31,982,747)

Less: Goodwill (377,172)

Less: Net Book Value of Big Rock Point (11,613) Tangible Net Worth $ 9,186,191 $ 9,186,191 ENOC-16-000 07 Attachment 2 Independent Accountant's Report on Applying Agreed

-Upon Procedures