ML20140C570

Affidavit of MD Dirmeier & Jk Madan Re Util Financial Qualification

ML20140C570
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/14/1984
From:	Dirmeier M, Madan J SUFFOLK COUNTY, NY
To:
Shared Package
ML20140C547	List: ML20140C543 ML20140C570
References
OL-4, NUDOCS 8406190383
Download: ML20140C570 (21)

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'hhD UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '84 yy Before the Atomic Safety and Licensing Board P3:37

)

In the Matter of. )

)

LONG~ ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-4

) (Low Power)

-(Shoreham~ Nuclear Power Station, )

Unit 1) )

)

AFFIDAVIT OF MICHAEL D. DIRMEIER AND JAMSHED K. MADAN Michael D. Dirmeier and Jamshed K. Madan, being duly sworn, do state under oath:

1. We are both employed bp Georgetown Consulting Group,

,Inc., located at 456. Main St., Ridgefield, CT 06877. Georgetown Consulting Group, Inc. is a financial and management consulting firm with extensive experience in the regulation of public utili-ties.: "We have been engaged by the County of Suffolk to analyze the effect of Shoreham on the rates and finances of Long Island Lighting Company ("LILCO") and to otherwise assist the County in analyzing financially related issues pertaining to Shoreham.

Statements of our professional qualifications are attached.

2. We understand that LILCO is seeking a license from the Nuclear Regulatory Commission ("NRC") to operate Shoreham at low power. Such low power operation would likely precede any NRC decision regarding LILCO's request for a full power operating license.

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.N 3.hyYe further understand' that for LILCO to receive a low s

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4 , 3 power licen'se, even fo'r'so-called Phases "I" and ,"II," there must c' ~

. . .. \ n beifindings by the NRC that LILCO has de.nonstrated'it is finan- , ,

\ 6sactivities it is cially qualified to carry out ,} . . ; low a: po.. wer' i > a and that such operati 1 is' in thd publ'ic interest.

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'4. " The purpose of ~ this Affida h ds t'o describe presently

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_t available information And , dater whid locumer e ',that/ LILCO , due to

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its deberiorating financI;al con'aitionl, is 'n6'I t financially quali-

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'fie'd to operte'Shorthamk a r

op even to carry out thy Phase I and'IX i.\

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activities, and that' the grant of>(a lice,nse to e,unduct such 7- s i . / . ' t- s' activities would not be,in( thhpu(blic interest. (g l

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5. ' 41p order to conduct the ' proposed Phase 1 and Phase II w

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activitfies,c L{ILCO will certainly n,eed(, ,to(exp ',rrn monies in ,addi

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N \ t. ( y, tion to ,athose which The y' it currently is expending,\en,Shoreham.

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tl: 3, precis 54rature and extent cf suen ' Additi'onk1' expen6ttures\cannot j .. As \,o ( o be gjbre,c/.lsa.'y quantified in thir.\)ffidavity' (Suf folk County ,has

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sought such'dsta from LILCO id discover'y requests, but has not

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yet recqi.ved/the v requested information from LILCO. We expect f , .,

1'such exptnses to include, however, at a minimum, the additional

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time reouired

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,  : and to conduct' <> gthe Phase IanNIIacthllh'5,andtheneed'for.morestringents'sturity t ) ' ,

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- onc@ fuel is actually placed'in the reactor. ,

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. t, g ,/ s  ! l \ f \' h .. T () \ N j , ./, I'\ '. ,. 1 ', , ,et ,, p,, .( 4 s ( \ ' r _ 6.-_Regardless whether Phases I and II will require addi-tional monetary expenditures by LILCO, however, in our opinion, there is nol assurance that LILCO has or will be able to obtain the financial resources necessary to complete Shoreham or to finance the proposed Phase I and II activities. 7.- Long Island Lighting Company is on the brink of finan-cial disaster. All its financial and operating resources are committed at this time. Unless additional sources of cash are made available, which we believe is unlikely, the Company will run out of cash in September 1984. If LILCO is predicted to or in fact does run out of cash, in our opinion, it is not finan-cially qualifi'ed to conduct the " proposed Phase I and II activi-ties; the grant of a license or an exemption to permit a license in these circumstances would be contrary to the public interest.

8. Data documenting LILCO's financial crisis include the following:

a) LILCO may be unable to continue'to provide safe and adequate electric service on Long ' Island, and unable to safely operate a nuclear unit, even at low power levels. Thus, at page 46 of LILCO's 1983 SEC Form 10-K, LILCO states: . . . little or no assurance can be given regarding the Company's abil-ity to raise additional funds in 1984 and in future yeara in order to meet its construction and other capital requirements and operation-al needs. e 4 ) 2 . N<, ; , _4_ . Similar' statements appear elsewhere in the LILCO 1983 10-K: The Company may be unable to obtain the'necessary financing or adequate rates or to conserve sufficient cash to meet its operating and ' capital requirements pending the completion, installation and test-ing of the new [ diesel]-generators. (p.*23) , The Company's ability to continue hits planned construction program, ~ including the completion of Shore-ham, depends upon the. ability of the Company to continue to obtain the funds required. (p. 45) , b) LILCO hus implemented a severe " austerity" program, canceled itd1 common stock dividends, and suspended payments on .its Nine Mile Point No. 2 obligations. LILCO's Vice President for Finance, Mr. Sideris, states in recent testimony filed before the New York Public Service Commission ("NYPSC"): Furthermore, the austerity program, the elimination of the common stock dividend, and the suspension of scheduled payments in connection with Nine Mile Point Unit No. 2 are all extraordinary measures -- measures which neither LILCO nor any other utility would consider for more than an instant except for the most critical and urgent of circumstances. (Page 16 of pre-filed NYPSC testimony), c) The 1983 LILCO SEC Form 10-K, page 58, states "At December 31, 1983, the Company had borrowed all of the-$400 million of funds available under its Revolving Credit Agreement e and its Eurodollar Revolving Credit Agreement." In a letter dated May 3, 1984, LILCO's counsel states, ". . . the Company can no longer obtain external financing for its operations." d) In February, 1984, LILCO placed at risk its $570 million investment in Nine Mile Point 2 by suspending its pay-ments toward the completion of that plant. Niagara Mohawk has ' informed LILCO that it considers LILCO to be in default of its obli~gations to the cotenants in that project. e) In March, 1984, LILCO implemented an " austerity" program designed to save $100 million in 1984. This program represents a loss of 741 positions at LILCO, 246 jobs with out-side contractdrs, and 11 percent of the budgeted 1984 construc- ~ tion-program. Page 46 of LILCO's May 30, 1984 " Position Paper -- Shoreham Nuclear Power Station" indicates that customers are subject to longer service response times and reduced customer service under the austerity plan. Thus, customer service has already been negatively-affected by the existing LILCO austerity program. f) The austerity program, itself, may lead-to further deterioration in LILCO's financial and operating position. In a letter.to NYPSC Administrative Law Judge Robinson dated May 3, 1934, LILCO's counsel stated "LILCO is now assuring safe and -adequate service for the short run -- not the long haul. It will 9 continue to do so. As a result, substantial cost increases for necessary operations-will be identified with very short lead tim'es, and their magnitude and timing simply cannot be forecast." \ g) In March, 1984, LILCO cancelled payment of its common stock dividend for the remainder of 1984. It would be difficult to overstate the importance of this action. Ready access to capital markets is a mainstay of utility financial operation, and cancellation of the common stock dividend makes  ! such access extremely difficult, if not impossible. . h) Suppliers to LILCO have tightened up the avall-ability of normal credit to the Company, increasing the Company's cash, difficulty. As Mr. Sideris, LILCO's Vice President for Finance, states at page 11 of his recently filed testimony before the NYPSC, ". . . our major oil suppliers now require payment at the time of or prior to delivery." i) LILCO had finance'd its share of the Nine Mile Point

2. construction program through a Construction Trust. After the cancellation of payments.for Nine Mile Point 2, LILCO negotiated an amendment to the Trust Agreement to the effect that the fail-ure io make construction payments would not constitute a default prior.to April 27, 1984, with additional 30 day grace periods to ,

be agreed to by banks holding two-thirds of the Construction Trust debt. A default would mean that the entire $500 million i loaned by the banks would be due and payable. In addition, due to. cross-default terms, a default on the Construction Trust is likely to lead to a default on-all of LILCO's long term debt. Thus, LILCO now finds itself subject to potential default on all its long term debt obligations at 30 day intervals, as well as possible reorganization.

9. Based on the foregoing, our experience in utility financial matters, and our work related to LILCO, it is our opinion'that LILCO presently has no~ ability to raise cash either

. int b'orrowing or by additional sale of stock. It is unlikely that ~LILCO will have any'such ability unless the major existing un-certainties surrounding emergency planning, emergency' diesel generators, the potential reorganization due to Nine Mile Point No. 2, and rade' treatments for the Shoreham and Nine Mile Point investments are resolved in LILCO's favor. Thus, LILCO's ability to conduct Phase I-and II activities depends on whether its current revenues from operations are sufficient to cover all ' expenses. At the present time, LILCO has included in its base rates:S94.5'million of emergency rate relief granted by the NYPSC in-the. Fall _of_1983. LILCO has asked the NYPSC that the interim relief be made permanent and.that an additional $186.5 million be added to its rates effective October 1, 1984. Opponents includ-ing the County of Suffolk and the New York State Consumer Protec-tion Board have argued that none of this ' relief is proper and that, in addition, $116.million should be removed from LILCO's base rates Tsince the LILCO austerity _ program represents a " reduction in the level of service being provided. It is e impossible to predict what rate relief, if any, LILCO will ultimately receive. What is significant, however, is that LILCO  ! is -projected to run out of money by' September 1984 even if it [ receives the full rate relief requested. LILCO's Projected Cash Shortfalls (in millions or dollars) No Relief (1) Full Relief (2) ^ 1984 September S 12.8 $ 12.8 ' October 9.1 4.3 November December 59.5 39.3 1985 . January 148.5 113.7

• February 139.6 86.1 1 March 164.8 98.1

~ April 165.3 84.9 May. 210.1 114.7 June 242.7 133.0 July 258.5 133.3 August 324.0 180.8 September 341.3 179.7  ; . October 343.0 161.6 November 352.8 155.8 l December 378.9 167.3 -(1) Beyond present level of interim relief =of $94.5 million.  : I (2) Entire request of $281 million is granted on October 1, , 1984. The above schedule shows that, assuming the present level of l interim relief is made permanent, LILCO will have significant l *dditional borrowing and capital requirements during 1984 and > l 1985. . The cash necessary to satisfy these requirements appears * , . . -r- *-----c- - - to be unattainable to LILCO. Even assuming that the entire amount of LILCO's pending rate increase were granted, LILCO still faces considerable borrowing requirements during 1984 and 1985, at a time-when its borrowing capacity has already been fully utilized.

10. There is no reasonable probability that LILCO will be able to make up the cash shortfalls described in paragraph 9 via either borrowing or sale of stock. This is because the capital and debt markets are effectively closed to LILCO due to its des-perate financial situation.

- 11. Since LILCO already is in desperate financial condition and since it shortly will run ou~t of cash, we conclude that LILCO is'not financially qualified to carry out Phase I and II or other low power activities and no exemption would be in the public interest. s

12. LILCO's current financial condition is of relatively recent origin. During the last half of the 1970's and the early

'1980's (indeed until 1983), LILCO's financial condition, while perhaps not the best in the utility industry, was sufficiently healthy that there was no serious question whether it was finan-cially qualified to operate a nuclear plant. Thus, during that period LILCO paid common stock dividends regularly, and had other traditional indicia of financial health (e.g., SEC coverages, I

etc.)'so that it was able to, and did, successfully raise monies ,

in the capital markets.

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13. Beginning in-1983, LILCO's financial condition and the perception of that condition by the financial community deterior-ated rapidly. The Form 10-K data cited above document the de-cline in 1983, v5ich decline has now reached the point that we predict that LILCO is likely to run out of money very shortly.  !

~ Michael D. Dirmeier , i l Jamshed K. Madan qw __-- Subscribedandsworntobeforemethis/ City of ' b,d. state of day of June, 1984, in the 05EE ) /$ . Notar?'Publfc My commission expires : [Comun!sdesi2*dIres 75ary 31,I;c P l 3 STATEMENT OF QUALIFICATIONS 2 3 Q. WOULD YOU STATE YOUR NAME AND ADDRESS? 4 A. My name is Michael D. Dirmeier and my business address is 456 5 Main' Street, Ridgefield, Connecticut. I am a member of the 6 firm of Georgetown Consulting Group, Inc.. 7 8 Q. WHAT IS THE BACKGROUND OF YOUR FIRM? 9 A .' ' Georgetown Consulting Group, Inc. is a financial management 10 consulting firm specializing in utility regulation. Members 11 of our firm have analyzed petitioner's testimonies, and have 12 testified, before numerous commissions in regulatory cases for 13 telephone,. water, elec'tric and gas utility companies 14 throughout the United States. 15 16 .Q. WHAT REGULATORY EXPERIENCE HAVE YOU HAD? 37 A. I . have analyzed Company testimony, managed the preparation of 18 accounting testimony or testified in the followl.ng 39 jurisdictions: 20 21 Colorado . 22 Public Service Company of Colorado (1981) I&S 1525 (1983) I&S 1640 1 23 - Mountain Bell Telephone (1982) IES 1575 24 (1984) IsS 1655 25

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j h 3 Delaware ' 2 Diamond State Telephone Company (1982) nocket No. 82-32 3  ! Maryland 4  ! Delmarva Power & Light Company Case No. 7734 l 5 Baltimore Gas and Electric Company ' i 6 (1977) Docket No. 7070 ' (1983) ' Docket No. 7695 7 Potomac Electric Power Company (1982) Docket No. 7662  ! 8 9 Minnesota l 10 Northwestern Bell Telephone Company Docket No. P-421/ . (1981) GR-80-911 , 11 Northwestern Bell Telepohone Company Docket No. P-421/ 12 (1983/4 divestiture- case) GR-83-600 13 Mississippi South Central Bell Telephone Company Docket No. U-4415 ! 15 Accounting and Divestiture i New Jersey l - l 17 l Atlantic City Electric Company (1982) Docket No. 822-116 , I - Elizabethtown Gas Company (LPGA, 1981) 19 L Hackensack Water Company (1980) Docket No. 804-275 20 (1981) Docket No. 815-447 (1982) Docket No. 815-447 2I - Jersey Central Power & Light Co. Docket No. 795-427 22 (2 cases: 1979,1980) L '23 Middlesex Water Company Docket No. 793-269  ; (2 cases: 1979, 1980) 24 25 j - New Jersey Bell-Telephone Co. (1978) Docket No. 7711-1136 2 (1981) Docket No. 815-458, Expensing Station Connections Various Dockets 3 New Jersey Bell Telephone Co. Docket No. -- 4 (1983 divestiture case) 5 New Jersey Natural Gas Company (1982) BPU Docket No. 815-459 , (Phase II) i 6 - PURPA ratemaking standards (1980) i 7 - i - Rockland Electric Co. (LEAC, 1979 Docket Nos. 7911-920 8 and 1980) & 7611-1100 [ _9 South Jersey Gas Company (Overearnings Docket No. 808-517 case, 1981) 10 West Keansburg Water Co. (1978) Docket No. 7710-1026 ' 11 12 New Mexico ' 33 Mountain States Telephone and Docket No. 877  : Telegraph Co. (1979) i l14  ; 15 New York 16 - Consolidated Edison Company (1980) Docket No. R-800- t 11069 , 17 Long island Lighting Company  ! l 18 (1980) Rate Case Docket No. 27774  ! t-(1982/3 Shoreham Phase-In) Docket No. 28252 l 19 l New York Telephone Company Docket Nos. 27469 & (2 cases: 1979, 1980) 27710 20 I Ohio l l 22 - Columbus and Southern Ohio Electric  : p~ Co. (1977/8) Docket No. 77-545-EL-AIR l (1978/9) Docket No. 78-1439-I 24 EL-AIR 25 l t e , , , , , ,,,m .,,,+.-w,-.,.e - ----.-n,,,, . - . _ , , , . - , , . , - ,c-----,---,a m.g. r 3 Toledo Edison Electric Co. (1979) Docket No. 79-143-EL-AIR 2 3 Pennsylvania 4 Bell of Pennsylvania RID 1819 (1982 accounting) S Bell of Pennsylvania (1983) Docket R-811319 6 (Accounting & Divestiture) 7 Duquesne Light Company (1982) Docket No. R-21945 g - Metropolitan Edison and Pennsylvania Docket Nos.I-79040308 . Electric Co. (2 cases: 1979, 1980) & M-79040129 9 Metropolitan Edison Company (1980) Docket No. R-80051196 10 (1981) Docket No. R-800ll601 . (1983) Docket No. R-822249 11 Pennsylvania Electric Company (1980) Docket No. R-80051197 12 (1981) Docket No. R-800ll602 (1983) Docket No. R-822250 13 UGI-Luzerne Electric Division (1979) Docket No. R-78030572 Pennsylvania Bell Telephone Co. 1982) Docket No. 811819 15 16 Rhode Island 17 Newport Electric _ Company (1979) Docket No. 1410 I8 South Carolina PURPA ratemaking standard (1980) 20 21 U.S. Virgin Islands 22 Virgin Islands Telephone Company Docket No. 180 (1978) 23 - Virgin Islands Water & Power Authority 24 25 g Q. WHAT OTHER PROFESSIONAL EXPERIENCE HAVE YOU HAD? 2 A. Prior to joining Georgetown Consulting Group, Inc., I was ' 3 employed by Touche Ross and Co. My consulting experience 4 includes operations reviews, system implementation and 5 Product-line analysis. 6 Before joining Touche Ross, I was a financial analyst 7 with the Bendix Corporation. My work included capital 8 budgeting, investment analysis, financial modeling and 9 planning, analysis of acquisitions and divestments, and  ; i 10 Preparation of financial reports for the Board of Directors. 11 12 0. WHAT IS YOUR EDUCATIONAL BACKGROUND? l 13 A. I hold a Master of Business Administration degree in finance , 14 from the University of Chicago, received in 1973, and a 15 Bachelor of Science degree in Physics, received from Texas A&M 16 University in 1971. ' i 37 I hold a Certificate in Management Accounting, which is a Professional certification for management accountants and f 18 39 financial managers awarded by the Institute of Management 20 Accounting of the National Association of Accountants. 21 l l 22 23 24 25 e e vv, - - -- __-_____m _ I STATEMENT OF QUALIFICATIONS 2 3 Q. WOULD YOU PLEASE STATE YOUR NAME AND ADDRESS? 4 A. My name is Jamshed K. Madan and my' business address is 456 5 Main Street, Ridgefield, Connecticut. l 6 7 Q. BY WHOM ARE YOU EMPLOYED? 8 A. I am a principal in the management consulting firm of 9 Georgetown Consulting Group, Inc. 10 , 11 Q. WOULD YOU DESCRIBE THE GENERAL NATURE OF YOUR FIRM'S 12 SERVICES? , -13 A. Our-firm offers services in financial and management 14 consulting with special emphasis on utility regulation. t 15 Members of our firm have performed or are performing analyses 16 of Petitioners' testimonies and have presented testimony i 17 before many commissions and boards in regulatory cases 18 involving telephone companies, air carriers, pipeline j j9 companies, and electric, gas and water utility companies. 20 21 Q. WHAT IS YOUR EDUCATIONAL BACKGROUND? 22 A. 'I graduated from the Massachusetts Institute of Technology in 23 1966 with a Bachelor of Science Degree in Electrical 24 Engineering. I continued my graduate studies at M.I.T. and in 25 1968 I graduated with a Master of Science Degree in Management , - - - - , - , - . . - , ...-..,.,,,.--n, . , , , . - , . . . , - . , _ . - - 6 E j from the Alfred P. Sloan School of Management. During my 2 graduate studies, I held the position of research assistant 3 and teaching assistant in areas related to financial  ; 4 management. j 5 6 Q. WHAT IS YOUR EMPLOYMENT EXPERIENCE? 7 A. From August of 1968 through April 1979 I was primarily 8 . employed by Touche Ross & Co., an international public 9 accounting firm. I was promoted to principal in September 10 1977 and held the position of National Director of Regulatory 11 Consulting. I lef t Touche Ross & Co. to become a principal -in , j7 Georgetown Consulting Gro,up in May of 197'9. 13 ' 14 Q. PLEASE PROVIDE A BRIEF

SUMMARY

OF YOUR EXPERIENCE IN UTILITY 15 REGULATION.

t 16 A. I have presented testimony on accounting and related matters l 17 on behalf of Rate Counsel, the public or intervenors before ,

! 18 various public utility commissions in the following rate 39 proceedings:

20 7; Alabama [

l 22 Continental Telephone of Docket No. 17968 l l the South - Alabama l *3 -

South Central Bell Case Nos'. 10875 &

g 10876 25 e

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.3 Arkansas 2 -

Southwestern Bell Telephone ,

Company Docket No. 83-045-U' l 3

4 Colorado i

5 Mountain States Telephone & Docket Nos. 1400 l Telegraph Company and 1575 -

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Public Service Company Docket Nos. 1425 t 7 of Colorado and 1525 i

-g Connecticut -

9 -

Southern New England Telephone Docket Nos. 770526 & i Company 800418  !

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.j; Delaware i

12 Delmarva Power and Light Company Docket No. 41-79 l a  !

13

.Delmarva Power and Light Company Complaint Docket No. [

279-80  !

14 Delmarva Power and Light Company Docket Nos. 80-29 15 Delmarva Power and Light Company Docket No. 81-23, 16 81-13, 61-12 l

17

= Georgia 18 -

Southern Bell Telephone Company Docket No. 3393-U  !

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20 Maryland

' 21 Baltimore Gas and Electric l Company Case No. 6985  !

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Potomac Electric Power Company Case No. 7348  ;

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Chesapeake and Potomac Telephone Case Nos. 7467

! 24 Company and 7591 l

25 Delmarva Power and Light Company Case No. 7427 i

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} Massachusetts i

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Boston Edison Company DPU-906 3

Minnesota 4

Northwestern Bell Company Docket No. P-421/GR80-911 5

6 New Jersey i

7 --

Atlantic City Electric Company Docket Nos. 701-641 &

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772-113 8

Elizabethtown Gas Company Docket No. 727-624  ;

9 Elizabethtown_ Water Company Docket No. 727-606 [

10 Backensack Water Company Docket No. 744-315 11  !

Jersey Central Power and Light Docket Nos. 743-184 & i l' ,

7610-1021  !

13 -

' New Jersey Bell Telephone Docket No. 747-522, Company 7512-1251,7711-1136, i 14 802-135 and 815-458 (

15 Public Service Electric and Docket Nos. 744-335 &

Gas Company 794-310 and 812-76 16 i 17 New York [

18 Long Island Lighting. Company . Case Nos. 27374 &

27375 19 Case No. 2777.4 20 New York Telephone Company Case Nos. 27100 & ,

27469 21 22 Ohi_o l 23 Columbus and Southern Ohio Docket No. 76-1439 3 Electric Company EL-AEM  !

Ohio Bell Telephone Company Case No. 79-1184 25 TR-AIR  !

Cleveland Electric Illuminating Case No.81-146 i EL-AIR 9

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) Pennsylvania. -

2 Bell Telephone Company of R.I.D. 367 and 811819 Pennsylvania 3

- . Metropolitan Edison Company R.I.D. 434, 626 &  !

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308 r

5 Pennsylvania Electric Company R.I.D. 392, 599 & ,

308  !

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i Philadelphia Electric Company R.I.D. 295, et al.  :

7 i Vermont i 8

l 9 -

New England Telephone and Docket No. 3806  ;

, Telegraph Company 10 -

11 Virgin Islands i 12 Abramson Bus Lines 13

.Manassah Bus Lines Docket No. 150 ,

14 Virgin Islands Telephone Docket Nos. 104, 105,  ;

! Company 108, 126, 121, and 180 15 '

Virgin Islands Water & Power Docket No. 193 16 Authority

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l Q. PLEASE DESCRIBE YOUR OTHER EXPERIENCE..  ;

!' 19 '

A. Besides regulatory consulting, I have been the project leader 20 on other projects, including:

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operations reviews 22 financial feasibility studies

'3 economic studies '

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marketing studies 25 r

1 cash flow analyses 2

cost reduction studies ,

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system planning studies r r

4 5 I have given talks before American Management Association  !

6 meetings entitled, Rate of Return Concept - A Management t

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10 11 12  ; ,

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