ML20013G680
| ML20013G680 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/31/1998 |
| From: | Charnoff G SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20013G681 | List: |
| References | |
| NYN-96031, NUDOCS 9804030388 | |
| Download: ML20013G680 (13) | |
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e wy aJIP SHAW PITTMAN POTTSeTROWBPdDGE A rmwtue rwaumwc racetmow cxs rcwiows i
2300 N street, N.W.
Washington D.C. 20037-1128 202.663.8030 Facamule 202.663.8007 CERALD CHARNOTT, P.C.
2M.663.8032 gerald _tharnoffSshewrittman.com l
March 31,1998 NRC Operatine License No. NPF-86 Docket No. 50-443 NYN.%031 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Re:
Seabrook Station, Unit No.1 Response To Request For Additional Information - Great Bay Power Corporation's Request To Provide Reasonable Assurance Of Decommissioning Funds Through Accelerated Trust Fund Contributions Ladies and Gentlelen:
I am enclosing Great Bay's response to your request for additional information regarding Great Bay's request for a determination by the NRC that its proposed acceleration of decommissioning funding for its ownership share of the Seabrook Station will provide reasonable assurance of decommissioning funding under the applicable NRC regualtions.
Because Great Bays's response contains sensitive commercial and financial information, I am also enclosing a Declaration of Frank W. Getman, Jr. requesting the NRC to maintain Great Bay's response as proprietary commercial information under 10 C.F.R. G 2.790 not subject to public disclosure. Also enclosed is a redacted version of Great Bay's response deleting the sensitive commercial and financial information which can be made publicly available.
Si cerely,
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A Gerald Chamoff 9004030388 900331' PDR ADOCK 05000443 Counsel for I-PDR.
Great Bay Power Corporation f), Di )
Enclosures cc:
Craig W. Smith Project Manager Project Directorate I-3 e
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SHAW PflThiAN -
POTISeTBOWBRIDGE A PARTN[L3HW FNCLtICENC FLOFESSONAL CDB POLAT1095 I
i United States Nuclear Regulatory Commission March 31,1998 Page 2 -
II. J. Miller (Cover letter, Declaration and Tab B only) j RegionI Administrator l
R. W. Lorson (Cover letter, Declaration and Tab B only)
Sr. Resident Inspector Seabrook j
t Alben W. DeAgazio Senior NRC Project Manager l
Steven R. Hom, Esq.
NRC Office of General Counsel Roben S. Wood NRC Oflice of Nuclear Reactor Regulation i
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l UNITED STATES OF AMERICA I
NUCLEAR REGULATORY COMMISSION i
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in the Matter of
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North Atlantic Energy Service Corporation,
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Docket No. 50-443 el al
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NYN-96031
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l (Seabrook Station, Unit 1)
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I Declaration Of Frank W. Getman Jr.
Pursuant to 10 C.F.R. 6 2.790 Frank W. Getman sr. states as follows under penalties of perjury:
1.
I am Vice President and Chief Operating Officer for Great Bay Power Cor-poration (" Great Bay") located in Dover, New Hampshire. In that capacity, I am respon-sible for operational and managerial matters of Great Bay.
j 2.
Great Bay is filing with the NRC a response for request for additional infor-mation regarding Great Bay's request for a determination by the NRC that its proposed acceleration of decommissioning funding for its ownership share of the Seabrook Sta-tion will provide reasonable assurance of decommissioning funding under the applica-ble NRC regulations. Most of the information contained in Great Bay's response is sensitive confidential commercial and financial information that could cause great harm to Great Bay if it were made publicly available. Accordingly, Great Bay requests the NRC to withhold this information from public disclosure pursuant to 10 C.F.R S 2.790 of its regulations. This declaration supplies the reasons why this information should be
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withheld from public disclosure as required by the regulation.
3.-
The complete unredacted version of Great Bay's response containing the sensitive, confidential commercial and financial information for which Great Bay l
l requests the Commission to treat as proprietary and to withhold from public disclosure is attached behind Tab A to this declaration. A redacted version of Great Bay's re- -
sponse deleting the sensitive, confidential commercial and financial information is at-tached behind Tab B to this declaration. The redacted version behind Tab B can be
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made publicly'available without competitive harm to Great Bay.
4.
I am familiar with the sensitive commercial and financial information con-tained in Great Bay's response attached at Tab A to this declaration. I am authorized to i
speak to Great Bay's practice of maintaining such information confidential and tha harm that would befall Great Bay if it were publicly disclosed.
L 5.
Great Bay's response contains cash flow, balance sheet and income statement projections reflecting Great Bay's budget and forecast of revenues from the
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l sale of electricity, and cash outlays for the cost of generatir', alectricity, for the years l
1998 through 2002. Great Bay's response also contains assumptions conceming Great
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1 Bay's price for short term sales of electricity and the capacity factors for Seabrook, on which these projections are based. Great Bay holds in confidence such revenue and l
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cash flow projections as well as projected sales price information. Great Bay does not disclose this type of information to the public and it is not available from public sources.
This information is commercially sensitive to the conduct of Great Bay's sale of power.
If the information contained in Great Bay's response became available to Great Bay's competitors or customers (both current and potential), those parties would leam of sen-sitive pricing and cost information which could be used against Great Bay in the nego-tiation of current and future power sales. Such a result would place Great Bay at a significant competitive disadvantage in the negotiations of current and future power sales and cause it substantial commercial harm.
6.
Accordingly, the information included in Great Bay's response attached at Tab A to this declaration is being submitted to the Commission in confidence under the 2,
i provisions of 10 C.F.R. $ 2.790 with the understanding that it is to be received in confi-dence by the Commission and withheld from public disclosure.
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I declare under penalty of perjury that the foregoing is true and correct.
l Executed on March 28,1998 Fralnk VI. Getman Jr. ' '
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Response to NRC's Request for Additional Information Re:
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Great Bay Power Corporation's Request to Provide i
Reasonable Assurance of Decommissioning Funds i
Through Accelerated Trust Fund Contributions
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Request No.1: Provide projectedproforma cash flow, balance sheet, and in-come statement projections for the next 5 years showing both current and pro posed accelerated projections for decommissioning trust fund payments. (These
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projections should be similar in format to those provided as Exhibit 1 of Great j
Bay's submittal datedJune 4,1977).
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Great Bay's Response: Tables I-IV attached to this response provide the pro-jections requested for the next 5 years (1998-2002). Table Iis a summuy which reflects forecasted " Decommissioning Fund Payments" (developed in confor-mance with the investment guidelines established by the New Hampshire Nu-clear Decommissioning Finance Committee), " Total Decomminioning Trust
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Fund" moneys, " Net Income," and " Total Cash - End of Period" for each of the i
five years assuming (1) current decomminioning funding with contributions through, and full funding by,2026; (2) Great Bay's proposed acceleration of de-commissioning funding with accelerated contributions through 2015 sufficient to accumulate thereafter and to provide full funding by 2026; and (3) accelera-tion of decommissioning contributions through 2008 sufficient to accumulate r
thereafter and to provide full funding by 2026 (in response NRC Request No. 3 below). Tables II, III, and IV provide Great Bay's projected " Income State-ment," " Cash Flow," and " Balance Sheet" respectively for the years 1998-2002 for each of the three assumptions.
Request No. 2: Provide current assumptions regarding the market price of electric power that Great Bay expects to sell Seabrook power at for the next five years. If there is no change from those projections provided in Exhibit 1 to Great Bay's June 4,1997, submittal, please so state.
- Great Bay's Response: Table V sets forth the spot and short term market sale price and capacity factor assumptions underlying the net income and cash flow 1
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projeciions in Tables II-IV. Great Bay believes that the price and capacity factor projections set fonh in the Table V are reasonable, conservative and achievable.
I Great Bay has experienced market price increases of 6.5% in 1996,10.5% in 1997 and projects a-increase in 1998. Based on this experience and its cur-rent 1998 projections, Great Bay has conservatively assumed i
tor its projected spot and shon term market pnces set forth in Table V.
-l With respect to the==nmad capscity factor for Seabrook, Great Bay has as-i sumed day refueling outages for the each of the three refueling outages cur-I rently scheduled for Seabrook in 1999,2000, and 2002. Great Bay has also-
. assumed a non-refueling capacity of (which is lower than the it as-
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sumed in Exhibit 1 to its June 4,1997 submittal).
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.I Request No. 3: Provide an analysis of the impact on Great Bay's income, cash flow, and balance sheet statements if decomminioning trust fund payments were accelerated to fully fund Great Bay's projected decommiesioning cost obli-gation for Seabrook by the end of 2008.
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Great Bay's Response: Tables II-IV provide the information requested as al-i ready described in G eat Bay's Response to Request No.1.~
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1 Request No. 4: Provide a sensitivity analysis of the impact on Great Bay's in-come, cash flow, and balaare sheet statements if decomminnioning trust fund
- payments, accelerated to complete inading by 2015 as Great Bay proposes, were increased to reflect increased cost estimates established by'the New Hampshire Nuclear Decommissioning Finance Committee. Please indicate the amount of such increases that Great Bay believes it could not meet Gaaarially.
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Great Bay's Response: - The current site specific decomminioning cost esti-
~ mate for Seabrook is approximately $473 million (1998 dollars).- The escalated -
NRC minimum value - as provided in 10 CFR $ 50.75(c) -is $489 million.
As shown by the Gaaartal information in Table I, Great Bay can meet its re-1 sponsibility to fund either of these estimates, i
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BAYCORPitOLDtNCS, LTD.
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. l .e s + + i I GREAT BAY POWER CORPORATION i i l Spot and Short Term Market Sale Price and Capacity Factor Assumptions Underlyleg j Net locome and Cash Flow n :: - - I 4 PROJECTED A >ERAGEPRKEFORSPOTAND PROJECTEDSEABROCK YEAR ' SHOET-TERMMAREETSALES CAPAQTTTACTOR I i. 1990 i l 1999 2000 i e 2001 1 i' 2002 j i 1 Great Bay believes that the sales price and capacity ibeter pr:' :^'::: set forth above are reasonable, conservative and achievable. Great Bay has experleeced market price leeresses of 6.5% le 1996,10.5% la 1997 and projected in 1990. Is its F: : ^' -. Great Bay assumes a With respect to capacity factor, there are refseling ostages at Seabrook scheduled to occur le 1999,2000 and 2002. Great Bev has assumed 4 ~ TDM V ' 'S NRC much 98.zis SALES PIGCE ~3/2$50 9A4 Ah4 : ,,.--}}