L-12-090, Annual Financial Test for a Parent Company Guarantee

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Annual Financial Test for a Parent Company Guarantee
ML12090A494
Person / Time
Site: Beaver Valley, Perry
Issue date: 03/30/2012
From: Sena P
FirstEnergy Nuclear Operating Co
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
L-12-090
Download: ML12090A494 (6)


Text

FENOC

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FirstEnergy Nuclear Operating Company 76 South Main Street Akron, Ohio 44308 Pet6r P. S$a ill President and Chief Operating Ofticer March 30,2012 L-12-090 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Annual Financial Test for a Parent Companv Guarantee 10 cFR 30 FirstEnergy Nuclear Operating Company hereby submits the annual FirstEnergy Corp.

(FE) financial test that was prepared in accordance with 10 CFR 30, Appendix A,

"Criteria Relating to Use of Financial Tests and Parent Company Guarantees for Providing Reasonable Assurance of Funds for Decommissioning."

This test provides assurance that FE can maintain a parent company guarantee to support the decommissioning funding for Beaver Valley Power Station, Unit No. 1 and Perry Nuclear Power Plant.

There are no regulatory commitments contained in this submittal. lf there are any questions or if additional information is required, please contact Mr. Phil H. Lashley, Supervisor

- Fleet Licensing, at (330) 315-6808.

Sincerely,

/tM*-

M u Peter P. Sena lll

Beaver Valley Power Station, Unit No. 1 Perry Nuclear Power Plant L-1 2-090 Page 2

Enclosure:

FirstEnergy Corp. Parent - Guarantee of Funds for Decommissioning:

Letter from Chief Financial Officer to Demonstrate Financial Assurance cc: NRC Region lAdministrator NRC Region lll Administrator NRC Resident Inspector (Beaver Valley)

NRC Resident Inspector (Perry)

NRC Project Manager (Beaver Valley)

NRC Project Manager (Perry)

Director BRP/DEP Site BRP/DEP Representative

76 South Main Street Akron. Ohio 44308 Mark T. Clark Executive Vice President and Chief Financial Officer Location of Facility Shippingport, PA Current Cost Estimate

$469,135,776 330-3U-5817 Fax: 330-252-1415 E-Mail : cl a*m@firstene rgycorp.com Guarantee March 21,2012 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington DC 20555-000 I

Subject:

FirstEnergy Corp. Parent - Guarantee of Funds for Decommissioning:

Letter from Chief Financial Officer to Demonstrate Financial Assurance I am the Executive Vice President and Chief Financial Officer of FirstEnergy Corp., 76 South Main Street, Akron, Ohio 44308, an Ohio corporation. This letter is in support of this firm's use of the financial test to demonstrate financial assurance, as specified in 10 CFR Part 50.

This firm guarantees, through the parent company guarantee submitted to demonstrate compliance under 10 CFR Part 50, up to $95 million of the decommissioning costs of the following facilities owned or operated by a subsidiary of this firm. The current cost estimate or amount of decommissioning funding assurance required, and the amount being guaranteed, are shown for the facilities:

Name of Facility Beaver Valley Power Station, Unit No. I License No. DPR-66 Perry Nuclear Power Plant License No. NPF-58

$68,000,000 Perry, OH

$626,940,465

$27,000,000 FirstEnergy Corp. is required to file a Form l0-K with the U.S. Securities and Exchange Commission for the latest fiscal year. These annual financial reports are available to NRC and need not be submitted separately in accordance with 10 CFR 50.71(b).

The fiscal year of FirstEnergy Corp. ends on December 3l't. The figures for the following items (Financial Test II: Alternative II) marked with double asterisks are derived from this FirstEnergy Corp.'s independently audited, year-end financial statements and footnotes for the latest completed fiscal year ended December 3 l, 201I.

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

March 27,2012

FINANCIAL TEST: ALTERNATIVE II (f0 CFR Part 30 App. A.Section II A.2.)

FirstEnergy Corp. Parent Guarantee of Funds For Decommissioning Dollars in Millions

l.

Guaranteed amount for the followins Units:

$95 Beaver Valley Power Station, Unit No. 1, License No. DPR-66 Perry Nuclear Power Plant, License No. NPF-58

2.

Current bond or credit rating of most recent unsecured issuance of this firrn Rating Baa3 Name of rating service Moody's

3.

Date of issuance of bond:

1111512001

4.

Date of maturity of bond:

l1ll5l203l

5.

Tangible net worth*

$5,941

6.

Total assets in United States** (required only if less than 90 percent of firm's assets are located in the United States)

See Line 9 Below

7.

Is line 5 at least $10?

8.

Is line 5 at least 6 times line l?

9.

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

10.

Is line 6 at least 6 times line l?

Yes No X

X X

N/A I I.

Is the rating specified on line 2 "BBB" or better (if issued by Standard & Poor's) or "Baa" or better (if issued by Moody's)?

X

- f*gtUt" Net Worth is defined as FirstEnergy Corp. total equity minus goodwill, patents, trademarks and copyrights; and FirstEnergy Nuclear Generation Corp.'s net book value for Beaver Valley Power Station, Unit No. I and Perry Nuclear Power Plant; plus the amount of decommissioning liability of the nuclear units assured under this parental guarantee.

    • Denotes fisures derived from financial statements.

FIRSTENERGY CORP.

YEAR ENDED DECEMBER 3I,2OII Dollars in Millions Line Number in CFO's Letter Total Equity Less: Goodwill, Patents, Trademarks and Copyrights Net Book Value Beaver Valley Unit I Net Book Value Perry Nuclear Plant Plus: Beaver Valley Unit I Decommissioning Liability Perry Nuclear Plant Decommissioning Liability 5 - Tansible Net Worth Per Financial Statements

$13,299

$ 6,441

$ 410 974

$ 206

$ 261

$-5p41

}

pwc Report of Independent Accountants To FirstEnergr Corp.:

We have performed the procedures enumerated below, which were agreed to by management of FirstEnerry Corp. (the Company) solely to assist you in evaluating the Company's compliance with the financial test as of December 3r, 2o1r performed in accordance with the U.S. Nuclear Regulatory Commission (the "NRC") Regulation ro C.F.R, Section So.ZS(eXrXiiiXB) as mandated by the Parent Company Guaranty dated December 19, 2or1. Management is responsible for the Company's compliance with those requirements. This agreed-upon procedures engagement was conducted in accordance with attestation standards established bv the American Institute of Certified Public Accountants. The sufficiency of these procedures is solely the responsibility of those parties specified in this report.

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.

For the purpose ofthis report, we have:

1. Read the letter, dated March 27, zotz, from your Executive Vice President and Chief Financial Officer to the NRC regarding the $gS Million Parental Guaranty and performed the following procedures, which were applied as explained below:

A. Traced and agreed the amounts in the column "Per Financial Statements", to a schedule prepared by the Company from its audited financial statements noting no differences.

B. Traced and agreed the amount in the column "Per CFO's Letter" to line item +5 in the Company's Financial Test: Alternative IL C. Recomputed the Tangible Net Worth by subtracting the Company's goodwill, patents, trademarks, copyrights; and FirstEnerry Nuclear Generation Corp.'s net book value of Beaver Valley Power Station, Unit No. r and Perry Nuclear Power Plant; plus the amount of decommissioning liability of the nuclear units assured under this parental guaranty from the Company's stockholders'equity noting no differences.

We were not engaged to and did not conduct an examination, the objective of which would be the expression of an opinion on compliance. 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 information and use of management of the Company and is not intended to be and should not be used by anyone other than these specified parties.

Cwo?Q'r'L LLF PricewaterhouseCoopers LLP March 2Z,2or2 PricewaterhouseCoopers LLP, zoo Public Square, tSth Floor, Cleueland, OH 44tt4-z3ot T: (zt6) B7g gooo, F: (zt6) 566 2846, www.pwc.com/us