ML23352A029

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Entergy - 2024 Nuclear Energy Liability Evidence of Financial Protection
ML23352A029
Person / Time
Site: Grand Gulf, Arkansas Nuclear, River Bend, Waterford  Entergy icon.png
Issue date: 12/13/2023
From: Fortner J
Stephens Insurance
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML23352A029 (1)
v • d • e


Text

December 13, 2023

. U.S. Nuclear Regulatory Commission ATTN: Document Control Desk, Director, Office of Nuclear Reactor Regulation

. Washington DC 20555-0001

)

  • stephens Jackson T. 81:eJ>llens, 1923-2005 Chairman Emeritus in Perpetuity

_s*o-313/3/e<?

So-Lf/ G/ tf I 7 St>-Lf-58' 50--3 g L RE: Entergy - 2024 Nuclear Energy Liability Evidence of Financial f>rotection

  • De$r NRC Document Control Desk:

Per140.15 Proof of Financial Protection:

Enclosed for your files are the 2024 copies of the American Nuclear Insurers (ANI) Change endorsements licensees noted in the enclosed table, which indicates ANI p*qlicy Numbets, to who the policies are issued. The original

.* Signed copies were mailed directly to ANI, as stated on the enclosed*

"MemoranduiJ, tci Brokers".* *

  • If you have any* questions, please do not hesitate to contact me.

. Regards, Jarr,es Fortner.

  • . Senior Vice President.

Stephens Insurance *

  • Little Rock; AR 72201 (501) 377-8435 {Office)

(501) 919-8047 {Mobile) james.fortner@stephens.com fvjPIJI

  • r)t~

stephens. lnc.

  • I 111 Center Street U.ttle Rock, AR 72201 501-.377-2000 t 501-377-2666 f 800-643-9691 www.stephens.com

EVIDENCE OF FINANCIAL PROTECTION To:

Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 This is to confirm that there is in force as of the effective date of this Evidence of Financial Protection, a Nuclear Energy Liability Policy (Facility Form), a certificate to the Master Worker Policy [Nuclear Energy Liability Policy (Facility Worker Form)], and one or more certificates to Master Policy No. 1 [Nuclear Energy Liability Insurance (Secondary Financial Protection)] issued by the members of American Nuclear Insurers, hereafter called the "companies 11

, to the Insured named herein, with respect to the Nuclear Facility at the Location stated below. If such policy and/or certificates are cancelled or otherwise terminated prior to the end of December 31st of the calendar year in which the Effective Date of this Evidence of Financial Protection occurs, the companies will mail written notice thereof to the United States Nuclear Regulatory Commission in accordance with policy provisions and this Evidence of Financial Protection shall thereupon terminate.

Otherwise this Evidence of Financial Protection shall terminate as of the end of such December 31st.

Name and Mailing Address of Insured Entergy Arkansas, LLC c/o Entergy Services, LLC Risk Management - Insurance P.o. Box 61000 New Orleans, LA 70161 Policy/Certificate Number Facility Form Policy No. NF -0210 Facility Worker Form Certificate No. NW -0590 SFP Certificate No. N -0048 SFP Certificate No. N -0068 Location of the Nuclear Facility Effective Date of this Evidence of Financial Protection January 1, 2024 Policy/Certificate Effective Date September 15, 1972 January 1, 1998 August 1, 1977 July 17, 1978 Limit of Liability

$500,000,000

$500,000,000*

Arkansas Nuclear One located in Pope County, State of Arkansas

  • This is an aggregate limit of liability shared by all participants to the Master Worker Policy [Nuclear Energy Liability Policy (Facility Worker Form)J of which each certificate is a part and is subject to all of the provisions of such Policy and certificate having reference thereto.
    • As per Condition 3 of Master Policy No. 1 [Nuclear Energy Liability Insurance (Secondary Financial Protection)].

Page 1 of 2 American Nuclear Insurers qs 4~!::/ BL-vtt-:, SIMA-e,300 4~!::/, CT 06033-4453 l:l Voi.ul. (860) 682.-:1.30:I. Cl FiLW- (860) 6sq-000;2.

NRCl000 (12/1/2014)

Evidence of Financial Protection Form

This Evidence of Financial Protection is not an insurance policy, is issued as a matter of information only and confers no rights upon the holder. This Evidence of Financial Protection neither affirmatively nor negatively amends, extends or alters the coverage afforded by the above stated policies and certificates.

Notwithstanding any requirement, term or condition of any contract or other document with respect to which this Evidence of Financial Protection may be issued or may pertain, the insurance afforded by the policies and certificates described herein is subject to all the terms, exclusions and conditions of the policies and certificates. The Limits of Liability shown above may have been reduced by payment of claims or claims expenses.

f Authorized Representative)

Jim Palaia - Vice President, Underwriting (Name and Title of Authorized Representative) 12/12/2023 (Date)

Page 2 of 2 NRCl000 (12/1/2014)

Evidence of Financial Protection Form

EVIDENCE OF FINANCIAL PROTECTION To:

Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 This is to confirm that there is in force as of the effective date of this Evidence of Financial Protection, a Nuclear Energy Liability Policy (Facility Form), a certificate to the Master Worker Policy [Nuclear Energy Liability Policy (Facility Worker Form)], and one or more certificates to Master Policy No. 1 [Nuclear Energy Liability Insurance (Secondary Financial Protection)] issued by the members of American Nuclear Insurers, hereafter called the "companies", to the Insured named herein, with respect to the Nuclear Facility at the Location stated below. If such policy and/or certificates are cancelled or otherwise terminated prior to the end of December 31st of the calendar year in which the Effective Date of this Evidence of Financial Protection occurs, the companies will mail written notice thereof to the United States Nuclear Regulatory Commission in accordance with policy provisions and this Evidence of Financial Protection shall thereupon terminate.

Otherwise this Evidence of Financial Protection shall terminate as of the end of such December 31st.

Name and Mailing Address of Insured Entergy Mississippi, LLC c/o Entergy Services, LLC Risk Management - Insurance P.O. Box 61000 New Orleans, LA 70161 Policy/Certificate Number Facility Form Policy No. NF -0257 Facility Worker Form Certificate No. NW -0619 SFP Certificate No. N -0079 Location of the Nuclear Facility Effective Date ofthis Evidence of Financial Protection January 1, 2024 Policy/Certificate Effective Date September 24, 1979 January 1, 1998 June 16, 1982 Limit of Liability

$500,000,000

$500,000,000*

Grand Gulf Nuclear Station located in Claiborne County, State of Mississippi

  • This is an aggregate limit of liability shared by all participants to the Master Worker Policy [Nuclear Energy Liability Policy (Facility Worker Form)] of which each certificate is a part and is subject to all of the provisions of such Policy and certificate having reference thereto.
    • As per Condition 3 of Master Policy No. 1 [Nuclear Energy Liability Insurance (Secondary Financial Protection)].

Page 1 of 2 American Nuclear Insure.rs q s c;~y Bw-tl., SIM,ift,, 300 El c;~y, C-T 06033-4453 D Vin.u;. (860) 68.2.-:1.30:1. F'11(1. (860) 6sq-ooo.2.

NRCl000 (12/1/2014)

Evidence of Financial Protection Form

I This Evidence of Financial Protection is not an insurance policy, is issued as a matter of information only and confers no rights upon the holder. This Evidence of Financial Protection neither affirmatively nor negatively amends, extends or alters the coverage afforded by the above stated policies and certificates.

Notwithstanding any requirement, term or condition of any contract or other document with respect to which this Evidence of Financial Protection may be issued or may pertain, the insurance afforded by the policies and certificates described herein is subject to all the terms, exclusions and conditions of the policies and certificates. The Limits of Liability shown above may have been reduced by payment of claims or claims expenses.

(Signatur resentative}

Jim Palaia - Vice President, Underwriting

{Name and Title of Authorized Representative) 12/12/2023 (Date}

Page 2 of 2 NRC1000 (12/1/2014)

Evidence of Financial Protection form

EVIDENCE OF FINANCIAL PROTECTION To:

Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 This is to confirm that there is in force as of the effective date of this Evidence of Financial Protection, a Nuclear Energy Liability Policy (Facility Form), a certificate to the Master Worker Policy [Nuclear Energy Liability Policy (Facility Worker Form)], and one or more certificates to Master Policy No. 1 [Nuclear Energy Liability Insurance (Secondary Financial Protection)] issued by the members of American Nuclear Insurers, hereafter called the "companies", to the Insured named herein, with respect to the Nuclear Facility at the Location stated below. If such policy and/or certificates are cancelled or otherwise terminated prior to the end of December 31st of the calendar year in which the Effective Date of this Evidence of Financial Protection occurs, the companies will mail written notice thereof to the United States Nuclear Regulatory Commission in accordance with policy provisions and this Evidence of Financial Protection shall thereupon terminate.

Otherwise this Evidence of Financial Protection shall terminate as of the end of such December 31st.

Name and Mailing Address of Insured Entergy Louisiana, LLC c/o Entergy Services, LLC Risk Management - Insurance P.O. Box 61000 New Orleans, LA 70161 Policy/Certificate Number Facility Form Policy No. NF -0286 Facility Worker Form Certificate No. NW -0641 SFP Certificate No. N -0100 Location of the Nuclear Facility Effective Date of this Evidence of Financial Protection January 1, 2024 Policy/Certificate Effective Date April 3, 1984 January 1, 1998 August 29, 1985 Limit of Liability

$500,000,000

$500,000,000*

River Bend Station located in West Feliciana Parish, State of Louisiana

  • This is an aggregate limit of liability shared by all participants to the Master Worker Policy [Nuclear Energy Liability Policy (Facility Worker Form)] of which each certificate is a part and is subject to all of the provisions of such Policy and certificate having reference thereto.
    • As per Condition 3 of Master Policy No. 1 [Nuclear Energy Liability Insurance (Secondary Financial Protection)].

Page 1 of 2 American Nuclear Insurers qs Ci~y Bwol<, Sv-i,,/t;300 Ci~y, C-T 06033-4453 v~ (860) 68.2.-:1-30:1-Fci.-,v. (860) 6sq-ooo.2.

NRC1000(12/1/2014)

Evidence of Financial Protection Form

This Evidence of Financial Protection is not an insurance policy, is issued as a matter of information only and confers no rights upon the holder. This Evidence of Financial Protection neither affirmatively nor negatively amends, extends or alters the coverage afforded by the above stated policies and certificates.

Notwithstanding any requirement, term or condition of any contract or other document with respect to which this Evidence of Financial Protection may be issued or may pertain, the insurance afforded by the policies and certificates described herein is subject to all the terms, exclusions and conditions of the policies and certificates. The Limits of Liability shown above may have been reduced by payment of claims or claims expenses.

Jim Palaia - Vice President, Underwriting (Name and Title of Authorized Representative) 12/12/2023 (Date)

NRClO00 (12/1/2014)

Page 2 of 2 Evidence of Financial Protection Form

EVIDENCE OF FINANCIAL PROTECTION To:

Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 This is to confirm that there is in force as of the effective date of this Evidence of Financial Protection, a Nuclear Energy Liability Policy (Facility Form), a certificate to the Master Worker Policy [Nuclear Energy Liability Policy (Facility Worker Form)], and one or more certificates to Master Policy No. 1 [Nuclear Energy Liability Insurance (Secondary Financial Protection)] issued by the members of American Nuclear Insurers, hereafter called the "companies", to the Insured named herein, with respect to the Nuclear Facility at the Location stated below. If such policy and/or certificates are cancelled or otherwise terminated prior to the end of December 31st of the calendar year in which the Effective Date of this Evidence of Financial Protection occurs, the companies will mail written notice thereof to the United States Nuclear Regulatory Commission in accordance with policy provisions and this Evidence of Financial Protection shall thereupon terminate.

Otherwise this Evidence of Financial Protection shall terminate as of the end of such December 31st.

Name and Mailing Address of Insured Entergy Louisiana, LLC c/o Entergy Services, LLC Risk Management - Insurance P.O. Box 61000 New Orleans, LA 70161 Policy/Certificate Number Facility Form Policy No. NF -0263 Facility Worker Form Certificate No. NW -0623 SFP Certificate No. N -0086 Location of the Nuclear Facility Effective Date of this Evidence of Financial Protection c'

January 1, 2024 Policy/Certificate Effective Date June 1, 1981 January 1, 1998 December 18, 1984 Limit of Liability

$500,000,000

$500,000,000*

Waterford 3 Nuclear Station located in St. Charles Parish, State of Louisiana

  • This is an aggregate limit of liability shared by all participants to the Master Worker Policy [Nuclear Energy Liability Policy (Facility Worker Form)] of which each certificate is a part and is subject to all of the provisions of such Policy and certificate having reference thereto.
    • As per Condition 3 of Master Policy No. 1 [Nuclear Energy Liability Insurance (Secondary Financial Protection)].

Page 1 of 2 American Nuclear Insurers qs Ci~!:J 13Lvtl., Sv..i,,/-t.,300 Ci~y, C-T 06033-445'3 Voi.ul. (860) 682-1-301-Fa.,v. (860) 6sq-0002 NRC1000 (12/1/2014)

Evidence of Financial Protection Form

Th,is Evidence of Financial Protection is not an insurance policy, is issued as a matter of information only and confers no rights upon the holder. This Evidence of Financial Protection neither affirmatively nor negatively amends, extends or alters the coverage afforded by the above stated policies and certificates.

Notwithstanding any requirement, term or condition of any contract or other document with respect to which this Evidence of Financial Protection may be issued or may pertain, the insurance afforded by the policies and certificates described herein is subject to all the terms, exclusions and conditions ofthe policies and certificates. The Limits of Liability shown above may have been reduced by payment of claims or claims expenses.

resentative)

Jim Palaia - Vice President, Underwriting (Name and Title of Authorized Representative) 12/12/2023 (Date)

Page 2 of 2 NRClOOO (12/1/2014)

Evidence of Financial Protection Form

December 12, 2023 Jason Martinez, CPCU, ARM, ARe DiKeol-or, U~wr-~

Memorandum to Brokers for all Non-Power Reactor Policyholders and Decommissioned Power Reactor Policyholders Re: 2024 Advance Premiums Packages In the e-mail is the link for your client's nuclear liability advance premium packages for the upcoming calendar year. The download via the link will be available for 90 days, after which it will expire. Packages as usual include advance premium endorsements, invoices, and premium computation sheets (negotiated or net commissions where applicable). Premiums are payable and must be ~ent to ANI no later than March 1, 2023. Please note the payment instructions on each invoice. We are encouraging you and your clients to make premium payments by ACH or Wire Transfer.

Enclosed in the link are the nuclear liability advance premium packages for the upcoming calendar year. Please find the following documents:

2024 Advance Premium Endorsements: Premiums are generally as quoted this past October for the domestic non-power reactor book of business, and reflect the premium increases announced previously. Also enclosed are the premium invoices and premium computation sheets (negotiated or net commissions where applicable). The premium computation sheets illustrate the details.

Condition 4 Endorsements: The Amendment of Condition 4 endorsements for Facility Form and domestic Supplier's and Transporter's policies amend Condition 4 to the current maximum capaci~y of $500 million effective January 1, 2024. Previously ANl's maximum capacity was $450 million.

We remind you that Condition 4 refers to the aggregate liability of ANI should an occurrence of series of occurrences result in claims under more than one ANI policy.

Amendment of Condition 4 does not increase the limits of liability under your clients'

  • policies.

Amendatory Endorsement No. 40 to Master Worker Policy (Facility Worker Form): This endorsement increases the Policy Aggregate Limit to $500 million effective January 1, 2024. This is a copy only, as we retain the original policy. Please send one copy to your client and retain one copy for your records as the broker. If your client does not American Nuclear Insurers qs c;~

BL-vt;(;., s~ 300 c;~y, er OW33-4453 j~@~~~ccw,,

Cl Voiul. (81&0) G8:2.-:L34:L F'11GI. (8GO) Gsq-000;2.

December 12, 2023 Page 2 participate in the Master Worker prograni, a copy of this endorsement is not included in I

the lmk.

I The 2023 Subscribing Companies Endor~ements are also enclosed for each of your respective clients, as follows:

Domestic Facility, S& T and Foreign S& T Forms - These endorsements are issued with respect to all ANI Domestic Facility Fotm, Domestic S& T and Foreign S& T policies reflecting the participating Subscribing cbmpanies and their percentages for Calendar Year 2024.

I l

Lastly, enclosed are the appropriate Rating lnfotmation Forms (if applicable) for your clients.

These forms are to be completed by the insured Jnd returned to ANI no later than May 1, 2024.

Your clients should provide their actual closing figures for their calendar or fiscal year 2023. We I

are not looking for estimates for 2024. The forms are required for both Domestic and Foreign S& Ts on an annual basis. These audit forms are essential in order to price the exposure presented I

by the insured's activities. If the Rating Information Forms are not received by May 1, 2024, a minimum of a 10% surcharge will be added to thJ insured's Advance Premium for 2025.

I Please send the completed form(s) electronically to Brandi Phelps at bphelps@amnucins.com.

I Please note the payment instructions on each imroice. Again, all premiums are payable to ANI I

no later than March 1. 2024. For those of you who must conduct security evaluations on AN l's subscribing members, please note that our subsc 1ribers are licensed to write business in all fifty states and in the District of Columbia. Membei;ship in ANI requires, in part, that a company maintain an A.M. Best rating of at least A-and !policyholder surplus of at least $100 million.

I Although some subscribers might change from tear-to-year, rest assured that all subscribers satisfy the requirements described. For your infbrmation, there have been no changes to the I

_ current subscribing companies. However, some of the subscribing companies' shares did change in comparison to 2023.

1 Please let us know if you have any questions or comments.

You can direct both to the underwriter whose name is on each premium corrputation sheet. We at ANI want to wish you and your clients a happy and very safe holiday season.

Regards, Jason Martinez, CPCU, ARM, Are Director, Underwriting

December 12, 2023 Jason Martinez, CPCU, ARM, ARe Du--uA-or, U~wir~

Memorandum to Brokers for all Operating Power Reactor Policyholders Re: 2024 Advance Premiums Packages In the e-mail is the link for your client's nuclear liability advance premium packages for the upcoming calendar year. The download via the link will be available for 90 days, after which it will expire. Packages as usual include advance premium endorsements, invoices, and premium computation sheets (negotiated or net commissions where applicable). Premiums are payable.

and must be sent to ANI no later than March 1, 2023. Please note the payment instructions on each invoice. We are encouraging you and your clients to make premium payments by ACH or Wire Transfer.

Enclosed in the link are the nuclear liability advance premium packages for the upcoming calendar year. Please find the following documents:

2024 Advance Premium Endorsements: Premiums generally are as quoted this past July, and reflect the premium increases announced previously. Also enclosed are the premium invoices and premium computation sheets {negotiated or net commissions where applicable). The premium computation sheets illustrate the details.

Condition 4 Endorsements: The Amendment of Condition 4 endorsements for Facility Form and Domestic Supplier's and Transporter's policies amend Condition 4 to the current maximum capacity of $500 million effective January 1, 2024.

We remind you that Condition 4 refers to the aggregate liability of ANI should an occurrence of series of occurrences result in claims under more than one ANI policy.

Amendment of Condition 4 does not increase the limits of liability under your clients' policies.

Increase in Limit of Liability Endorsements for Operating Power Reactor Facility Form Policies: These endorsements increase each policy's limit of liability to $500 million effective January 1, 2024. All operating reactor insureds have requested that limit to comply with the primary financial protection obligations of the Price-Anderson Act.

American Nuclear Insurers q s Ci~!:I 13~, S!M;fe., 300 Ci~!:/, c;r 06033-4453 j~@~~~CAWvv Voiu.J. (8GO) 68.2.-:1-34:1-Fll1</. (860} 6sq-000.2.

December 12, 2023 Page 2 Amendatory Endorsement No. 40 to Master Worker Policy (Facility Worker Form}: This endorsement increases the Policy Aggregate Limit to $500 million effective January 1, 2024. This is a copy only, as we retain the original policy. Please send one copy to your client and retain one copy for your records as the broker.

Endorsement No. 73 to the Master Secondary Financial Protection (SFP) Policy: This endorsement amends the primary financial protection limit to $500 million and the Contingent Liability of the Companies to $35 million for both the underlying Facility Form policies and Facility Worker Form Policy. The Master policy is a copy, as the NRC retains the original. Again, please send a copy to your client and retain one copy for your records as the broker.

Endorsements to SFP Certificates:

Under each individual SFP Certificate, these endorsements amend the primary financial protection limit to $500 million for both the underlying Facility Form policies and Facility Worker Form policy.

Increase in Limit of Liability Endorsements for Supplier's and Transporter's (Operating Power Reactors Only) Policies: These endorsements increase each policy's limit of liability to $500 million effective January 1, 2024 for all operating power reactors that have Supplier's and Transporter's policies. This is optional and must have been requested by the insured.

Secondary Financial Protection (SFP) Endorsements: New state approved Secondary Financial Protection (SFP) endorsement which is attached to the Master SFP Policy and a new endorsement to each SFP certificate. The new endorsements were necessary predominantly in response to federally mandated changes to the SFP program. Please note the endorsement to the SFP Master Policy is a copy. The original endorsement is sent to the Nuclear Regulatory Commission which is the custodian of the SFP Master Policy. The following is a description of the new endorsements:

1) Copy of Endorsement No. 72 (Form NE-S-40) to Master Policy No. 1 (Secondary Financial Protection): This endorsement revises Form NE-S-38. It is identical to Form NE-S-38 except that it increases the maximum annual retrospective premium from the $20,496,000 figure contained in Form NE-S-38 to $24,714,000 as mandated by recent changes to the NRC regulations on October 5, 2023.
2) An Endorsement to each SFP Certificate (Form NE-S-41): This endorsement revises form NE-S-39. It is identical to Form NE-S-39 except that is increases the maximum total retrospective premium with respect to each nuclear incident from the

December 12, 2023 Page3

$137,608,800 figure contained in Form NE-S-39 to $165,927,300 as mandated by recent changes to NRC regulations on October 5, 2023.

The 2023 Subscribing Companies Endorsements are also enclosed for each of your respective clients, as follows:

Domestic Facility. S&T and Foreign S&T Forms - These endorsements are issued with respect to all ANI Domestic Facility Form, Domestic S&T and Foreign S&T policies reflecting the participating Subscribing Companies and their percentages for Calendar Year 2024.

Secondary Financial Protection {SFP) Policy and Facility Worker Form Policy - If your clients are participating in the SFP program and/or Master Worker program, enclosed is Endorsement No. 74 which has been attached to the SFP Master Policy and/or a copy of Endorsement No. 41 which has been attached to the Master Worker Policy. The original endorsement to the SFp Master Policy will be sent directly to the Nuclear Regulatory Commission {NRC) because they are custodian of such policy. A copy of the endorsement to the Master Worker Policy, which is in the custody of ANI, will also be sent to the NRC.

Lastly, enclosed are the appropriate Rating Information Forms {if applicable) for your clients.

These forms are to be completed by the insured and returned to ANI no later than May 1, 2024.

Your clients should provide their actual closing figures for their calendar or fiscal year 2023. We are not looking for estimates for 2024. The forms are required for both Domestic and Foreign S& Ts on an annual basis. These audit forms are essential in order to price the exposure presented by the insured's activities. If the Rating Information Forms are not received by May 1, 2024, a minimum of a 10% surcharge will be added to the insured's Advance Premium for 2025.

Please send the completed form(s) electronically to Brandi Phelps at bphelps@amnucins.com.

Please note the payment instructions on each invoice. Again, all premiums are payable to ANI no later than March 1, 2024. For those of you who must conduct security evaluations on AN l's subscribing members, please note that our subscribers are licensed to write business in all fifty states and in the District of Columbia. Membership in ANI requires, in part, that a company maintain an A.M. Best rating of at least A-and policyholder surplus of at least $100 million.

Although some subscribers might change from year-to-year, rest assured that all subscribers satisfy the requirements described. For your information, there have been no changes to the current subscribing companies. However, some of the subscribing companies' shares did change in comparison to 2023.

December 12, 2023 Page4 Please let us know if you have any questions or comments.

You can direct both to the underwriter whose name is on each premium computation sheet. We at ANI want to wish you and your clients a happy and very safe holiday season.

Regards, Jason Martinez, CPCU, ARM, ARe Director, Underwriting
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