ML071100067
| ML071100067 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos Nuclear Center, 07000754, 07200001, Vallecitos |
| Issue date: | 04/02/2001 |
| From: | Schindler W General Electric Co |
| To: | Camper L NRC/FSME |
| References | |
| Download: ML071100067 (12) | |
Text
0 GE Nuclear Energy General Electric Company 175 Curtner Avenue, San Jose, CA 95125 April 2, 2001 Mr. Larry Camper Chief LLW & Decommissioning Branch Office U.S. Nuclear Regulatory Commission 11454 Rockville Pike Rockville MD 20852
Subject:
General Electric Company's Self-Guarantee submission for 2001; 1OCRF, "Criteria Relating to Use of Financial Tests and Self-Guarantee for Proving Reasonable Assurance for Decommissioning" Enclosed please find General Electric's calendar year 2001 submission update for the Self-Guarantee. If you have any questions, please direct them to the undersigned.
Wolfgang H. Schindler, Controller GE Nuclear Energy 175 Curtner Avenue San Jose, California 95125 (408) 925-2853
Corporate Environmental Programs General Electric Company 3135 Easton Turnpike, Fairfield, CT 06431 Letter from Chief Financial Officer to Demonstrate Financial Assurance for Decommissioning March 16, 2001 Mr. Michael Weber Chief LLW & Decommissioning Branch Office U. S. Nuclear Regulatory Commission 11545 Rockville Pike Rockville, MD 20852
Subject:
General Electric Company Self-Guarantee; 10 CRF Appendix C, "Criteria Relating to Use of Financial Tests and Self-Guarantees for Proving Reasonable Assurance of Funds for Decommissioning."
I am the Chief Financial Officer of the General Electric Company (GE), 1 River Road, Schenectady, NY 12345. This letter is in support of the use of the financial test to demonstrate financial responsibility under the Self-Guarantee Rule (58 CFR 68726; 12/29/93) which became effective on January 28, 1994.
The firm identified above guarantees, as self-guaranteeing licensee, through the financial test specified in (58 FR 68726, 12/29/94), the decommissioning closure care for the following licenses held by GE. The current closure cost estimates covered by the test for decommissioning, so guaranteed, are shown for each facility/license: -- see SCHEDULE A.
This firm is required to file a Form 10K with the U.S. Securities and Exchange Commission (SEC) for the latest fiscal year; a copy of which is enclosed.
The fiscal year of this firm ends on December 31. The figures for the following items marked with an asterisk are derived from this firm's independently audited, year-end financial statements for the latest completed fiscal year, ended December 31, 2000. A copy of the GE's 2000 Annual Report is enclosed.
NRC Letter Page Two FINANCIAL TEST
- 1.
Decommissioning cost estimates for facilities as contained in SCHEDULE A.
- 2.
Tangible Net Worth at least 10 times the current decommissioning cost estimate (of the current amount required if certification is used) for all decommissioning activities for which the company is responsible as self-guaranteeing licensee and as parent-guarantor.
- 3.
Assets located in the United States amounting to at least 90 percent of total assets or at least 10 times the current decommissioning cost estimate (or the current amount required if certification is used) for all decommissioning activities for which the company is responsible as self-guaranteeing licensee and as parent-guarantor.
- 4.
Current bond rating as issued by Standard & Poor's and Moody's Date of issuance of most recent bond Date of maturity of above bond
- 5.
Is line 2 at least 10 times line 1?
- 6.
Is line 3 at least 10 times line 1?
Dollars in Thousands
$104,300
$23,051,000
$277,818,000 Aaa-Moody's 12/14/00 12/01/10 Yes Yes Further, I hereby certify that the contents of this letter and SCHEDULE A are true and correct to the best of my knowledge.
Keith S. Sherin Senior Vice President - Finance
SCHEDULE A NRC SELF-GUARANTEE RULE SCHEDULE OF LICENSES NRC License No.
GENERAL ELECTRIC COMPANY - 2001 Name & Address of Licensee Address of Licensed Activity
($in thousands)
Cost Estimate.
GE as Self-Guaranteeing Licensee:
DPR-1 R-33 TR-1 DR-10 General Electric Company GE Nuclear Energy 175 Curtner Ave.
San Jose, CA 95125 General Electric Company GE Nuclear Energy 175 Curtner Ave.
San Jose, CA 95125 General Electric Company GE Nuclear Energy 175 Curtner Ave.
San Jose, CA 95125 General Electric Company GE Nuclear Energy 175 Curtner Ave.
San Jose, CA 95125 General Electric Company GE Nuclear Energy 175 Curtner Ave.
San Jose, CA 95125 General Electric Company Morris Operation 7555 East Collins Rd.
Morris, IL 60450 GE Nuclear Energy Vallecitos Nuclear Center 6705 Vallecitos Rd.
Pleasanton, CA 94566 GE Nuclear Energy Vallecitos Nuclear Center 6705 Vallecitos Rd.
Pleasanton, CA 94566 GE Nuclear Energy Vallecitos Nuclear Center 6705 Vallecitos Rd.
Pleasanton, CA 94566 GE Nuclear Energy Vallecitos Nuclear Center 6705 Vallecitos Rd.
Pleasanton, CA 94566 GE Nuclear Energy Vallecitos Nuclear Center 6705 Vallecitos Rd.
Pleasanton, CA 94566 GE Nuclear Energy Morris Operation 7555 East Collins Rd.
Morris, IL 60450 10,400 1,500 19,500 16,000 24,700 32,200 SNM-960 SNM-2500 Total Cost Estimates:
104,300 NRC_A.DOC
CERTIFICATION I, Keith S. Sherin, Senior Vice President - Finance, of the General Electric Company, do hereby certify that the attached Minute #10855 entitled "Execution of Contracts and Other Instruments" is a true and correct copy of a portion of the minutes of the meeting of the board of Directors of General Electric Company held on April 26, 1988, which minutes were approved by the Board of Directors at its meeting on May 27, 1988, and revised on December 20, 1991.
Dated this 16th day of March 2001 Keith S. Sherin Senior Vice President-Finance ATTEST:
Attesting Secretary
BOARD OF DIRECTORS MEETING April 26, 1988 (Revised December 20, 1991) 10855 EXECUTION OF CONTRACTS AND OTHER INSTRUMENTS The Chairman reminded the Board that the resolution dealing with the execution of contracts and other instruments on behalf of the Company had last been reviewed and revised by the Board in
- June, 1985, at which time the resolution had been modified to reflect changes in the Company's organization and to change its form to make periodic organization updatings unnecessary under ordinary circumstances.
The Chairman noted that the principal purpose of this resolution is to indicate to persons outside the Company the individuals within the Company who have authority to sign various documents.
In view of the Board's determination to limit the individuals elected as officers of the Company (and authorize the Chairman of the Board to appoint and remove persons as non-corporate Operational Officers),
he indicated that it would be advisable to consider revisinq and clarifyinq this resolution to take account of these clarifications and related matters.
The Chairman pointed out that, like the existing resolution.
the proposed resolution would not confer any authority to approve transactions underlying the documents to be signed over and above that which is possessed by the signer either by virtue of the April 26, 1988
powers inherent in that individual's position with the Company or
.by virtue of a delegation of authority to that individual by the Board of Directors or higher management.
Following discussion, it was RESOLVED, that (A) Any contract, lease, license, assignment, bond or other obligation, conveyance, power of attorney, guarantee,
- proxy, court pleading,
- release, tax return and related documents, or other instruments may be executed onl behalf of this Company by the Chairman of the. Board, a Vice Chairman of the Board, an Executive Vice President, a Senior Vice President, a Vice President reporting directly to the chairman or a Vice Chairman of the Board, the Comptroller, the Treasurer, the Secretary, or any vice President who is a corporate staff officer of the Company, all of the above-named individuals being hereinafter called "Authorized Persons".
In addition to the foregoing, any Operational Officer may sign any instrument of the type described in this Paragraph (A) which relates to the component or function to which such operational Officer is assigned, and any Manager, or formally designated Acting Manager, of any Division or Department level organization component may sign any such instrument which relates to that component. Each Operational Officer and each such Manager or Acting manager is authorized to delegate to others, authority to execute on behalf of the Company, the types of contracts or other instruments which relate to the function or component to which such operational Officer, Manager or Acting manager is assigned which are of the same types an the contracts and other instruments listed in Paragraph (C) below.
(B) The Chairman of the Board and each of the Vice Chairmen of the. Board is authorized to delegate to others authority to execute contracts and other instruments on behalf of the Company as he considers necessary and in the best interest of the Company.
(C) Each Authorized Person is hereby authorized to delegate to others authority to execute on behalf of the company the following types of contracts and other instruments which relate to the function or component for which such Authorized Person is responsible:
- 1.
Sales, purchase and consignment contracts, bids therefor,
.(including contracts providing for or relating to a April 26, 1988-2 2 -
franchise for the distribution or resale of this Company's products) and documents in connection therewith, including bids to and contracts with any Municipal, County or State Government, or with the Government of the United States or a foreign country, or with any agency or department of any such Government and bonds to secure the performance of such bids and contracts.
- 2.
Installation, erection, and service contracts and bids therefor and documents in connection therewith (including but not limited to installation, erection, and service contracts and bids therefor with any Municipal, County or State Government, or with the Government of the United States or a foreign country, or with any agency or department of any such Government) and bonds to secure the performance of any such contract or bid.
- 3.
Assignments, waivers of
- lien, releases, guaranties, mortgages, indentures, credit agreements and such other agreements, documents or other instruments as may be necessary or advisable, relating to either direct or indirect financing in connection with sales by the Company, or the collection of debts, and proofs of claims and other instruments to be filed or used in any bankruptcy or insolvency proceedings.
- 4.
Contracts, leases, deeds, or other instruments relating to real property or to any improvements thereon.
- 5.
Powers of Attorney authorizing agents and attorneys to acquire and dispose of motor vehicles on behalf of the Company and to file all necessary applications, execute all necessary documents, and take all other necessary actions in connection therewith.
- 6.
Powers of Attorney authorizing agents and attorneys to transact business of the Company with the U.S. Customs Service and with customs authorities in other countries.
(D)
The Senior Vice President -
Finance and the Vice President and Treasurer are each severally authorized to deleqate to others authority to execute on behalf of the Company the following types of instruments and in connection therewith to establish, as appropriate, Company-wide procedures:
- 1.
Agreements or other instruments relating to (a) investment of funds of the Company, including but not limited to, instruments pertaining to the purchase, sale, exchange, assignment, conversion, transfer, custody or April 26, 1988 3
loan of any securities or properties, (b) establishment and operation of bank accounts, (c) authorizations to purchase or sell currencies (including contracts for future delivery),
(d) financial contracts (e) applications for letters of credit, (f) issuance of stock certificates and replacement of certificates that are Lost, stolen or destroyed, and (g) share owner proxies, consents, waivers and releases.
- 2.
Checks, drafts, other payment authorizations and notes payable of the Company.
Except as provided below, any such authorization shall require countersignatures and stipulate that no one individual may both sign and countersign the same instrument.
Any delegation hereunder may provide that the individual authorized to sign or countersign may effect his or her signature by means of a facsimile signature.
It shall not, however, be mandatory for any authorization hereunder to require signatures and countersignatures with respect to (a) checks or drafts drawn on dividend, payroll, or working fund accounts, (b) depositary transfers or endorsements to the account or credit of the Company or (c) transfers between Company bank accounts.
- 3.
Guarantees of indebtedness of foreign or domestic affiliates of the Company and guarantees of contingent obligations of such affiliates in connection with bank guarantees of commercial transactions.
(E)
The Senior Vice President -
Finance and the Vice President and Comptroller are each severally authorized to delegate to others authority to. execute on behalf of the
- Company, the following types of contracts and other instruments:
- 1.
- Federal, State or local tax returns and related documents, to be filed in the United States or foreign countries,
- 2.
Reports of collections from employees and taxes due from the Company under the Federal Insurance Contributions Act, Federal Unemployment Tax Act, and the unemployment compensation laws of each of the states, the District of Columbia and Puerto Rico, as well as any related claims for refunds and reports thereunder,
- 3.
Applications,
- claims, surrender and other forus in connection with the General Electric Supplemental Life Insurance Program, April 26, 1988 4
- 4.
- Annual, financial and other reports required of the Administrator under the Federal Employment Retirement Income Security Act of 1974, and any comparable report required by similar State laws,
- 5.
Such certifications,
- invoices, reports, releases and other instruments as are necessary to conform to requirements of the United States Government or any department, agency or instrumentality therefor as may be necessary or advisable in order to comply with the terms of any agreement between the Company and the United States Government or any department, agency or instrumentality thereof.
(F)
The General Counsel is authorized to delegate to others authority to execute on behalf of the Company, the following types of instruments:
- 1.
- Licenses, contracts, assignments,
- releases, court pleadings and other instruments relating to inventions and technology and to patent, trademark and copyright matters.
- 2.
Petitions, powers of attorney, authorizations, verifica-tions, nominations of representatives, declarations, and other instruments relating to proceedings in the Patent, Trademark Registration or Copyright Offices servicing any country or region of the world, or to related appeal proceedings, or relating to maintenance and-defense of the resulting industrial property rights, assignments of rights to apply for and acquire patents and trademark registrations, evidence of such assignments, requests for the registration of patents as available for licensing, reports of inventions and petitions for waiver of patent rights to any department or agency of the United States Government and assignments, licenses and other instru-ments confirmatory of Government rights in patents and inventions.
(G) Any contract,
- lease, deed or other instrument relatinq to real property or to any improvements located or to be located thereon may be executed on behalf of this Company by the Manager-Real Estate and Construction operation or by AnAe or te Manager-Fnancial Section or sa ea site and onstruction Operation.
(H)
Any delegations (including revocations and revisions) as authorized by this Resolution shall be in writing.
Authority delegated pursuant to the last sentence of April 26, 1988 5 -
(Rev. 12/20/91)
Paragraph (A) or pursuant to Paragraphs (B),
(C),
(D),
(E) or (F) above may be redelegated by the persons to whom such delegations are made who in turn may authorize further redelegation;
- provided, however, that no such initial or subsequent redelegation shall be made except in conformity with the limitations imposed thereon by the initial delegation plus any restrictions contained in subsequent redelegations.
(I)
The Secretary, the Associate Corporate Secretary and any Attesting Secretary are each severally authorized to affix the Corporate Seal to and attest to contracts and other instruments executed by persons acting pursuant to the authority granted by Paragraphs (A) or (G) above or pursuant to authority delegated in accordance with Paragraphs (A),
(B),
(C),
(D),
(E),
(F) or (H) above.
The Secretary, the Associate Corporate Secretary and any Attesting Secretary are also each severally authorized to certify as to the provisions of this Resolution, as to the incumbency of any person in any position within the Company and as to the terms of any delegation under this Resolution.
(J)
Resolution #10502 dated June 28, 1985 is superseded effective as of April 26, 1988.
April 26, 1988 6 -
Stamford Square 3001 Summer Street Stamford, CT 06905 Independent Accountants' Report on Applying Agreed-Upon Procedures The Board of Directors General Electric Company:
We have performed the procedures listed below, which were agreed to by the Board of Directors and Management of General Electric Company ("the Company"), solely to assist you in connection with the filing of certain financial information included in the "Financial Test" section of your letter dated March 16, 2001 to the United States Nuclear Regulatory Commission. This engagement to apply agreed-upon procedures was performed in accordance with the standards established by the American Institute of Certified Public Accountants. The sufficiency of these procedures is solely the responsibility of the Board of Directors and Management of General Electric Company.
Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose.
The procedures and associated findings are as follows:
Tangible Net Worth - We compared the dollar amount of tangible net worth, $23,051,000 thousand, as shown in Item 2, to the difference between Total Share Owners' Equity,
$50,492,000 thousand, and Intangible Assets, $27,441,000 thousand, each reflected in the Statement of Financial Position on page 36 of the Company's 2000 Annual Report, and found such amounts to be in agreement.
Total Assets in the United States - We compared the Company's Total Assets in the United States, $277,818,000 thousand, as shown in Item 3, to the Company's Total Assets in the United States, reflected in Note 29 - Geographic Segment Information on page 74 of the Company's 2000 Annual Report, and found such amounts to be in agreement.
We were not engaged to, and did not, perform an audit, the objective of which would be the expression of an opinion on the specified elements, accounts, or items. Accordingly, we do not express such an opinion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you.
This report is intended solely for the use of the Board of Directors and Management of General Electric Company, and should not be used by those who have not agreed to the procedures and taken responsibility for the sufficiency of the procedures for their purposes.
March 16, 2001 a member of KPMG International, a Swiss association,