L-19-217, ISFSI - Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments

ISFSI - Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments

ML19268B133
Person / Time
Site:	Beaver Valley, Davis Besse, Perry, 07201043, 07200069
Issue date:	09/25/2019
From:	Benyak D FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML19268B132	List: L-19-217, ISFSI - Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments
References
EPID: L-2019-LLM-0000, L-19-217
Download: ML19268B133 (21)

Text

CONFIDENTIAL FINANCIAL INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10 CFR 2.390 AND 10 CFR 9.17 FENOC First Energy Nuclear Operating Company '

Darin M. Benyak Vice President, Nuclear Support and Regulatory Affairs September 25, 2019 L-19-217 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Beaver Valley Power Station, Unit Nos. 1 and 2, ISFSI Docket No. 72-1043 Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License No. NPF-3 Davis-Besse Nuclear Power Station, Unit No. 1 ISFSI Docket No. 72-14 Perry Nuclear Power Plant, Unit No. 1 Docket No. 50-440, License No. NPF-58 Perry Nuclear Power Plant, Unit No. 1 ISFSI Docket No. 72-69 10 CFR 50.80 10 CFR 50.90 10 CFR 72.50 341 White Pond Drive Akron, Ohio 44320 Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments (EPID-L-2019-LLM-OOOO)

By letter dated April 26, 2019 (Accession No. ML19116A087), as supplemented by letters dated May 31, 2019 (Accession No. ML19151A531), August 2, 2019 (Accession No. ML19214A100), August 29, 2019 (Accession No. ML19241A462), and September 25, 2019 (Accession No. ML19268A053), FirstEnergy Nuclear Operating Company (FENOC), acting on behalf of itself and FirstEnergy Nuclear Generation, LLC (FENGen, or together with FENOC, the Applicants), submitted an application (Application) for transfer of control of to this letter contains confidential financial information. Withhold from public disclosure pursuant to 10 CFR 2.390 and 10 CFR 9.17.

Upon removal of Attachment 3, this letter is uncontrolled.

CONFIDENTIAL FINANCIAL INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10 CFR 2.390 AND 10 CFR 9.17 Beaver Valley Power Station, Unit Nos. 1 and 2 Beaver Valley Power Station ISFSI Davis-Besse Nuclear Power Station, Unit No. 1 Davis-Besse Nuclear Power Station ISFSI Perry Nuclear Power Plant, Unit No. 1 Perry Nuclear Power Plant ISFSI L-19-217 Page 2 Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1, BVPS-2, or collectively as BVPS); Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS); and Perry Nuclear Power Plant, Unit No. 1 (PNPP); and their respective generally llcensed independent spent fuel storage installation facilities (lSFSIs) (collectively referred to as the Facilities).

The transaction described in the Application would result in the transfer of control of the Applicants to a newly created ultimate parent company, referred to as New HoldCo, which would be a separate Iegal entity from the current ultimate parent company, FirstEnergy Corp. As described in the Application, the transfer of control would facilitate the Applicants' emergence from bankruptcy.

As described in the letter dated August 29, 2019, FENOC committed to providing revised anticipated operating and financial projections, and New HoldCo's opening balance sheet and opening cash position to the Nuclear Regulatory Commission (NRC) no later than at confirmation of the Plan of Reorganization (Plan) by the bankruptcy court. The current information is attached. Exhibit A contains the Revised OwnerCo and Facility Pro Forma Income Statements and Exhibit B contains the Revised New HoldCo Pro Forma Post-emergence Opening Balance Sheet and Opening Cash Position.

Certain confidential, commercially sensitive financial information is included in Exhibits A and B. lt should be noted that the New HoldCo pro forma post-emergence opening balance sheet and opening cash position provided in the Application was publicly disclosed in accordance with the requirements of the bankruptcy process. However, New HoldCo revised financial information is no longer required to be docketed in the Applicants' bankruptcy filings. As a result, the revised New HoldCo financial information in Exhibit B contains confidential, commercially sensitive financial information.

FENOC requests that Exhibits A and B be withheld from public disclosure pursuant to 10 CFR 2.390 and 10 CFR 9.17. Redacted versions of Exhiblts A and B are provided in the publicly available Attachment 1. The redacted information is identified by the brackets [ ].

An affidavit supporting the request for withholding of proprietary financial information from public disclosure is provided in Attachment 2 to this submittal. An unredacted version of Exhibits A and B is provided in Attachment 3. to this letter contains confidential financial information. Withhold from public disclosure pursuant to 10 CFR 2.390 and 10 CFR 9.17.

Upon removal of Attachment 3, this letter is uncontrolled.

CONFIDENTIAL FINANCIAL INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10 CFR 2.390 AND 10 CFR 9.17 Beaver Valley Power Station, Unit Nos. 1 and 2 Beaver Valley Power Station ISFSI Davis-Besse Nuclear Power Station, Unit No. 1 Davis-Besse Nuclear Power Station ISFSI Perry Nuclear Power Plant, Unit No. 1 Perry Nuclear Power Plant ISFSI L-19-217 Page 3 As described in the letter dated April 26,2019, the Application was submitted to the NRC in advance of confirmation of the Plan in order to permit prompt implementation of the Plan upon confirmation by the bankruptcy court. NRC approval of the Application is required before the Applicants can reorganize and emerge from bankruptcy. Due to unsettled issues associated with the bankruptcy process, the Applicants have not yet received confirmation of the Plan. FENOC will inform the NRC of any significant changes in the status of the bankruptcy proceeding. Therefore, the Applicants request NRC approval of the Application as soon as practicable following the completion of commitments associated with the Application.

The information provided in this submittal does not invalidate the no significant hazards consideration analysis provided in the Application.

There are no regulatory commitments contrained in this letter. lf there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager, Nuclear Licensing and Regulatory Affairs, at (330) 315-6810.

I declare under penalty of perjury that the foregoing is true and correct. Executed on September ZS, 2019.

Sincerely, b,*^^^fn6, I Darin M. Benyak Attachments:

1. Financial Information - Non-Proprietary

2. Affidavit of Darin M. Benyak Supporting Withholding From Public Disclosure

3. Financial lnformation - Proprietary to this letter contains confidential financial information. Withhold from public disclosure pursuant to 10 CFR 2.390 and 10 CFR 9.17.

Upon removal of Attachment 3, this letter is uncontrolled.

CONFIDENTIAL FINANCIAL INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10 CFR 2.390 AND 10 CFR 9.17 Beaver Valley Power Station, Unit Nos. 1 and 2 Beaver Valley Power Station ISFSI Davis-Besse Nuclear Power Station, Unit No. 1 Davis-Besse Nuclear Power Station ISFSI Perry Nuclear Power Plant, Unit No. 1 Perry Nuclear Power Plant ISFSI L-19-217 Page 4 cc: Director, NRR (without Attachment 3)

NRC Region I Administrator (without Attachment 3)

NRC Region lll Administrator (without Attachment 3)

NRC Project Manager - FENOC Fleet (without Attachment 3)

NRC Resident lnspector - Beaver Valley Power Station (without Attachment 3)

NRC Resident lnspector - Davis-Besse Nuclear Power Station (without Attachment 3)

NRC Resident lnspector - Perry Nuclear Power Plant (without Attachment 3)

Director BRP/DEP (without Attachment 3)

Site Representative BRP/DEP (without Attachment 3)

Branch Chief, Ohio Emergency Management Agency, State of Ohio (NRC Liaison) (without Attachment 3)

Utility Radiological $afety Board (without Attachment 3) to this letter contains confidential financial information. Withhold from public disclosure pursuant to 10 CFR 2.390 and 10 CFR 9.17.

Upon removal of Attachment 3, this letter is uncontrolled.

L-19-217 FI NANCIAL !NFORMATION - NON.PROPRIETARY (Thirteen pages follow)

Exhibit A Revised OwnerCo and Facility Pro Forma lncome Statements NON-PROPRIETARY (Ten pages follow)

Page 1 of 10 Nuclear Resource Credits Charges per the PSA Operating Revenuesl OwnerCo Pro Forma lncome Statement - Consoli6sls6s' 10 NON-PROPRIETARY

($ in millions) 2020 2021 2022 2023 2024 t

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Operating Expensesz Fuel Expense3 Nuclear Operating Costs Property Taxes Capital Expensea Bankruptcy Separation Costsl 1

Other Operating Costss Total Operating Expenses Operating lncome Other lncome / (Expenses) lnterest Expense6 Capitalized lnterestl 1

Debt Service - Principal PaymentsT Otherll Total Other lncome / (Expenses) lncome Before lncome Taxes lncome Taxes Net Income Key Employee Retention Program8 t Contributions to NDTs11 tI I II It

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Net Cash Flow

Page 2 of 10 Notes:

1. Operating Revenues are based on i) projected revenue from nuclear resource credits from Ohio House Bill 6 and ii) projected revenue from the post-emergence Nuclear Power Supply Agreement (PSA) described in the original Application and updated as provided in letter dated August 29,2019 (Accession No. ML19241A462),

Exhibit D. Based on the cost recovery structure of the post-emergence PSA, the net cash flow is [ ] for 2020 and beyond.

2. Fixed Operating Expenses are conservatively assumed to be the combination of Nuclear Operating Costs, Property Taxes, and Other Operating Costs.

3. Fuel Expense is based on the projected purchases for the units.

4. Capital Expense includes projected capital expenditures for the Facilities for the operating term.

5. Other Operating Costs refers to allocated overhead and fleet support services assigned to the Facilities.

6. lnterest Expense comprises the projected interest payments for the secured debt issued by OwnerCo. This excludes any interest income related to the Facilities' nuclear decommissioning trusts (NDTs).

7. Debt Service - Principal Payments comprises the projected payments for the full principal amount of the secured debt at the maturity dates.

8. Key Employee Retention Program (KERP) costs reflect accruals or cash payments related to the OpCo retention program approved by the Bankruptcy Court on November 30, 2018. On July 26,2019, the KERP was terminated to Davis-Besse Nuclear Power Station, Perry Nuclear Power Plant, and corporate employees due to the rescission of the decommissioning notices for those two facilities. The KERP continues for the Beaver Valley Power Station employees.

9. Values within t ] are considered proprietary.

10. Mathematical rounding was performed during the development of the supporting calculations.

1 1. Cost category was listed in the Application but has no projected costs for the five-year period through 2024. Regarding "Bankruptcy Separation Costs," these costs are expected to be addressed prior to 2020. Regarding "Contributions to the NDTs," BVPS-1 had a contribution projected in 2020. The contribution is expected to be made in 2019. There are no additional contributions to the NDTs projected.

Page 3 of 10 Nuclear Resource Credits Charges per the PSA Operating Revenuesl Operating Expenses2 Fuel Expense3 Nuclear Operating Costs Property Taxes Capital Expensea Bankruptcy Separation Costsl 1

Other Operating Costss Total Operating Expenses Operating lncome Other lncome / (Expenses) lnterest Expense6 t

Capitalized I nterestl 1

Debt Service - Principal PaymentsT I Otherl l Total Other Income / (Expenses) lncome Before Income Taxes lncome Taxes Net Income Key Employee Retention Program8 [

Contributions to NDTsl 1

Net Gash Flow Beaver Valley Power Station, Unit No. 1 Pro Forma lncome Stats11gp1e, 1o NON,PROPRIETARY

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Page 4 of 10 Notes:

1. Operating Revenues are based on projected revenue from the post-emergence Nuclear Power Supply Agreement (PSA) described in the original Application and updated as provided in letter dated August 29,2019 (Accession No. ML19241A462),

Exhibit D. Based on the cost recovery structure of the post-emergence PSA, the net cash flow is [ ] for 2A20 and beyond.

2. Fixed Operating Expenses are conservatively assumed to be the combination of Nuclear Operating Costs, Property Taxes, and Other Operating Costs.

3. Fuel Expense is based on the projected purchases for the unit.

4. Capital Expense includes projected capital expenditures for the Facility for the operating term.

5. Other Operating Costs refers to allocated overhead and fleet support services assigned to the Facility.

6. lnterest Expense comprises the projected interest payments for the secured debt issued by OwnerCo. This excludes any interest income related to the Facilities' nuclear decommissioning trusts (N DTs).

7. Debt Service - Principal Payments comprises the projected payments for the full principal amount of the secured debt at the maturity dates.

8. Key Employee Retention Program costs reflect accruals or cash payments related to the OpCo retention program approved by the Bankruptcy Court on November 30, 2018.

9. Values within [ ] are considered proprietary.

10. Mathematical rounding was performed during the development of the supporting calcu lations.

1 1. Cost category was listed in the Application but has no projected costs for 202A through 2021. Regarding "Bankruptcy Separation Costs," these costs are expected to be addressed prior to 2020. Regarding "Contributions to the NDTs,"

BVPS-1 had a contribution projected in 2020. The contribution is expected to be made in 2019. There are no additional contributions to the NDT projected.

Page 5 of 10 Nuclear Resource Credits Charges per the PSA Operating Revenuesl Operating Expenses2 Fuel Expense3 Nuclear Operating Costs Property Taxes Capital Expensea Bankruptcy Separation Costsl 1

Other Operating Costss Total Operating Expenses Operating lncome Other Income / (Expenses) lnterest Expense6 Capitalized ! nterestl 1

Debt Service - Principal PaymentsT Otherl l Total Other lncome / (Expenses) lncome Before Income Taxes lncome Taxes Net lncome t

Key Employee Retention Program8 t Contributions to NDTs11 Net Cash Flow Beaver Valley Power Station, Unit No. 2 Pro Forma lncome Statemenle' 10 NON.PROPRIETARY

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Page 6 of 10 Notes:

1. Operating revenues are based on projected revenue from the post-emergence Nuclear Power Supply Agreement (PSA) described in the original Application and updated as provided in letter dated August 29,2019 (Accession No. ML19241A462),

Exhibit D. Based on the cost recovery structure of the post-emergence PSA, the net cash flow is I J for 2020 and beyond.

2. Fixed Operating Expenses are conservatively assumed to be the combination of Nuclear Operating Costs, Property Taxes, and Other Operating Costs.

3. Fuel Expense is based on the projected purchases for the unit.

4. Capital Expbnse includes projected capital expenditures for the Facility for the operating term.

5. Other Operating Costs refers to allocated overhead and fleet support services assigned to the Facility.

6. lnterest Expense comprises the prolected interest payments for the secured debt issued by OwnerCo. This excludes any interest income related to the Facilities' nuclear decommissioning trusts (N DTs).

7. Debt Seruice - Principal Payments comprises the projected payments for the full principal amount of the secured debt at the maturity dates.

8. Key Employee Retention Program costs reflect accruals or cash payments related to the OpCo retention program approved by the Bankruptcy Court on November 30, 2018.

9. Values within I ] are considered proprietary.

10. Mathematical rounding was performed during the development of the supporting calculations.

1 1. Cost category was listed in the Application but has no projected costs for 2020 through 20?1. Regarding "Bankruptcy Separation Costs," these costs are expected to be addressed prior to 2020. There are no contributions to the NDT projected.

Page 7 of 10 Nuclear Resource Credits Charges per the PSA Operating Revenuesl Operating Expenses2 Fuel Expense3 Nuclear Operating Costs Property Taxes Capital Expensea Bankruptcy Separation Costsl 1

Other Operating Costss Total Operating Expenses Operating lncome Other Income / (Expenses) lnterest Expense6 Capitalized lnterestl 1

Debt Service - Principal PaymentsT Otherl l Total Other Income / (Expenses) lncome Before lncome Taxes lncome Taxes Net Income Key Employee Retention Programs Contributions to NDTsl 1

Davis-Besse Nuclear Power Station, Unit No. 1 Pro Forma lncome Statemeple' 1o NON.PROPRIETARY

($ in millions) 2020 2021 2022 2023 2024 t

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Page B of 10 Notes:

1. Operating Revenues are based on i) projected revenue from nuclear resource credits from Ohio House Bill 6 and ii) projected revenue from the post-emergence Nuclear Power Supply Agreement (PSA) described in the original Application and updated as provided in letter dated August 29,2019 (Accession No. ML19241A462),

Exhibit D. Based on the cost recovery structure of the post-emergence PSA, the net cash flow is [ ] for 2OZA and beyond.

2. Fixed Operating Expenses are conservatively assumed to be the combination of Nuclear Operating Costs, Property Taxes, and Other Operating Costs.

3. Fuel Expense is based on the projected purchases for the unit.

4. Capital Expense includes projected capital expenditures for the Facility for the operating term.

5. Other Operating Costs refers to allocated overhead and fleet support services assigned to the Facility.

6. lnterest Expense comprises the projected interest payments for the secured debt issued by OwnerCo. This excludes any interest income related to the Facilities' nuclear decommissioning trusts (NDTs).

7. Debt Service - Principal Payments comprises the projected payments for the full principal amount of the secured debt at the maturity dates.

8. Key Employee Retention Program terminated for Davis-Besse Nuclear Power Station employees on July 26, 2019.

9. Values within t ] are considered proprietary.

10. Mathematical rounding was performed during the development of the supporting calculations.

1 1. Cost category was listed in the Application but has no projected costs for the five-year period through 2024. Regarding "Bankruptcy Separation Costs," these costs are expected to be addressed prior to 2020. There are no contributions to the NDT projected.

Page I of 10 Nuclear Resource Credits Charges per the PSA Operating Revenuesl Operating Expensesz Fuel Expense3 Nuclear Operating Costs Propefty Taxes Capital Expensea Bankruptcy Separation Costsl 1

Other Operating Costss Total Operating Expenses Operating lncome Other lncome / (Expenses) lnterest Expenseo Capitalized lnterestl 1

Debt Service - Principal PaymentsT Otherl l Total Other Income / (Expenses) lncome Before lncome Taxes lncome Taxes Net Income Key Employee Retention Program8 t Contributions to NDTs11 Perry Nuclear Power Plant, Unit No. 1 Pro Forma lncome Statemeplle, 1o NON-PROPRIETARY

($ in millions) 2024 2021 2022 2023 2024 tlttt Ittr l

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Page 10 of 10 Notes:

1. Operating Revenues are based on i) projected revenue from nuclear resource credits from Ohio House Bill 6 and ii) projected revenue from the post-emergence Nuclear Power Supply Agreement (PSA) described in the original Application and updated as provided in letter dated August 29,2O19 (Accession No. ML19241A462),

Exhibit D. Based on the cost recovery structure of the post-emergence PSA, the net cash flow is [ ] for 2020 and beyond.

2. Fixed Operating Expenses are conservatively assumed to be the combination of Nuclear Operating Costs, Propefty Taxes, and Other Operating Costs.

3. Fuel Expense is based on the projected purchases for the unit.

4. Capital Expense includes projected capital expenditures for the Facility for the operating term.

5. Other Operating Costs refers to allocated overhead and fleet support seruices assigned to the Facility.

6. lnterest Expense comprises the projected interest payments for the secured debt issued by OwnerCo. This excludes any interest income related to the Facilities' nuclear decommissioning trusts (NDTs).

7. Debt Service - Principal Payments comprises the projected payments for the full principal amount of the secured debt at the maturity dates.

8. Key Employee Retention Program terminated for Perry Nuclear Power Plant employees on July 26,2019.

9. Values within [ ] are considered proprietary.

10. Mathematical rounding was performed during the development of the supporting calculations.

1 1. Cost category was listed in the Application but has no projected costs for the five-year period through 2024. Regarding "Bankruptcy Separation Costs," these costs are expected to be addressed prior to 2020. There are no contributions to the NDT projected.

Exhibit B Revised New HoldCo Pro Forma Post-Emergence Opening Balance Sheet and Opening Cash Position NON-PROPRIETARY (One page follows)

New HoldCo Consolidated Balance Sheet - as Projected as of December 31, 20191,2 NON.PROPRIETARY

($ in millions)

Assets Cash and Cash Equivalents Accounts Receivable, Net lvlaterials and Supplies Provisional Trust (BVPS-1 NDT Shortfall)

Other Current Assets Total Current Assets Property, Plant & Equipment, Net Nuclear Decommissioning Trust Other Long-Term Assets Total Assets Liabilities and Equitv Current Portion of Long-Term Debt New Credit Facility Accounts Payable Other Current Liabilities Total Gurrent Liabilities Long Term Debt Asset Retirement Obligation Total Liabilities Equity Total Liabilities and Equity

1. Values within [ ] are considered proprietary.

2. Mathematical rounding was performed during the development of the su pporting calcu lations.

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L-19-217 Affidavit of Darin M. Benyak Supporting Withholding from Public Disclosure (Two pages follow)

10 cFR 2.390 AFFIDAVIT OF DARIN M. BENYAK l, Darin M. Benyak, Vice President, Fleet Nuclear Support and RegulatoryAffairs, for FirstEnergy Nuclear Operating Company (FENOC), state that:

1.

I am authorized to execute this affidavit on behalf of FENGen and FENOC (collectively referred to as the Applicants).

2.

The Applicants are providing information in support of their "supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments." The proprietary versions of Exhibits A (Revised OwnerCo and Facility Pro Forma lncome Statements), and B (Revised New HoldCo Pro Forma Post-emergence Opening Balance Sheet and Opening Cash Position) being provided separately in Attachment 3 of this submittal contains financial information, including pro forma income statements, related to anticipated revenues from sales of electricity and capacity from Beaver Valley Power Station, Ufiit Nos, 1 and 2; Davis-Besse Nuclear Power Station, Unit No. 1; and Perry Nuclear Power Plant, Unit No. 1, as well as plant operating and maintenance costs. These documents constitute proprietary, commercially sensitive financial information that should be held in confidence by the NRC pursuant to the policy reflected in 10 CFR 2.390(aX4) and 10 CFR 9.17(a)(4), because:

a. The information described in Exhibits A and B is and has been held in confidence by the Applicants and their affiliates. lt should be noted that the New HoldCo Pro Forma Post-emergence Opening Balance Sheet and Opening Cash Position was publicly disclosed in accordance with the requirements of the bankruptcy process in the Disclosure Statement for the Foufth Amended Plan associated with the Applicants' bankruptcy process.

However, ceilain revised financial information for New HoldCo as required specifically for this Nuclear Regulatory Commission (NRC) license transfer proceeding is not expected to be provided publicly as part of the Applicants' bankruptcy filings. As a result, the information described in Exhibits A and B is and has been held in confidence by the Applicants and their affiliates.

b. This information is of a type that is held in confidence by the Applicants and their affiliates, and there is a rational basis for doing so because the information contains confidential, commercially sensitive financial information concerning the Applicants' anticipated revenues and operating expenses.

New HoldCo will be a privately held company and does not plan to publicly disclose financial information.

c. This information is being transmitted to the NRC in confidence.

d. This information is not available in public sources and could not be gathered readily from other publicly available information.

e. Public disclosure of this information would create substantial harm to the competitive position of the Applicants and their affiliates by disclosing their internal financial pro forma statements and commercial information to other parties whose commercial interests may be adverse to those of the Applicants.

3.

Accordingly, the Applicants request that Attachment 3 to the "supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments" be withheld from public disclosure pursuant to 10 CFR 2.390(a)(4) and 9.1 7(a)(4).

FirstEnergy Nuclear Generation, LLC FirstEnergy Nuclear Operating Company Darin M. Benyak Vice President, Nuclear Support and Regulatory Affairs FirstEnergy Nuclear Operating Company STATE OF OlUO COUNTY OF 5"mmit Subscribed and swprn to me, a Notary Public, above named, tnis J.5rt day of Septemnei aafi"'

in and the County and State I{MBERLY D. AI.lDERS Hotarv R bl'tc, SEb of 0lti0 ijtv thmmlsdon E$res

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