ND-22-0654, Licensee Guarantees of Payment of Deferred Premiums

Licensee Guarantees of Payment of Deferred Premiums

ML22229A148
Person / Time
Site:	Vogtle
Issue date:	08/10/2022
From:	Whitley B Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML22229A147	List: ND-22-0654, Licensee Guarantees of Payment of Deferred Premiums
References
ND-22-0654
Download: ML22229A148 (7)

Text

A Southern Nuclear Brian H. Whitley Southern Nuclear Director, Regulatory Affairs Operating Company, Inc.

3535 Colonnade Parkway Birmingham, AL 35243 Tel 205.992.7079 August 10, 2022 Docket No.: 52-025 ND-22-0654 10 CFR 140.21 10 CFR 2.390 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Unit 3 Licensee Guarantees of Payment of Deferred Premiums Ladies and Gentlemen:

This submittal is made with regard to Vogtle Electric Generating Plant Unit 3 (VEGP 3), license number NPF-91, pursuant to the reporting requirements of 10 CFR 140.21. The requirements of 140.21 include, at the issuance of the license, providing evidence to the Commission that it maintains a guarantee of payment of deferred premium for each reactor the licensee is licensed to operate. Per the Price-Anderson Amendments Act, each licensee maintains a guarantee of payment of deferred premium in the amount of $20.496 million for each reactor it is licensed to operate. Southern Nuclear Operating Company (SNC) maintains nuclear liability endorsements through Marsh USA for VEGP Unit 3 under the American Nuclear Insurers (ANI) Master Policy -

Nuclear Energy Liability Insurance (Secondary Financial Protection), which became effective at the time of the 10 CFR 52.103(g) finding. contains the certificate of insurance executed by the VEGP 3 co-owners. The certificate of insurance contains Proprietary information; therefore, SNC requests that these documents be withheld from public disclosure under 10 CFR 2.390.

In the future, Marsh USA will provide certificates of insurance evidencing this coverage to the U.S.

Nuclear Regulatory Commission (NRC) Document Control Desk. The annual financial reports required by 10 CFR 140.21 for the three SNC nuclear sites are made in a single report (see SNC letter NL-22-0221 [NRC ADAMS Accession Number ML22087A499] for the most recent annual submittal). Reporting for VEGP 3 will be included in that annual report moving forward. provides the SNC affidavit for withholding proprietary information contained in . SNC requests that the proprietary information contained in Enclosure 1 continue to be withheld from public disclosure pursuant to 10 CFR 2.390.

This letter contains no NRC commitments.

If you have any questions regarding this letter, please contact Ms. Amy Chamberlain at (205) 992-6361.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 10th of August, 2022.

U.S. Nuclear Regulatory Commission ND-22-0654 Page 2 of 4 Respectfully submitted, Brian H. Whitley Regulatory Affairs Director Southern Nuclear Operating Company

Enclosures:

1) Vogtle Electric Generating Plant (VEGP) Unit 3, Certificate of Insurance

[Note: Contains Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390]

2) Vogtle Electric Generating Plant (VEGP) Unit 3, Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390

U.S. Nuclear Regulatory Commission ND-22-0654 Page 3 of 4 cc:

Southern Nuclear Operating Company / Georgia Power Company Mr. S. E. Kuczynski Mr. P. P. Sena III Mr. H. Nieh Mr. D. L. McKinney Mr. G. Chick Mr. S. Stimac Mr. P. Martino Mr. D. Pitts Mr. J. B. Williams Mr. B. H. Whitley Ms. C. A. Gayheart Ms. M. Ronnlund Mr. J. M. DeLano Ms. J. M. Coleman Mr. C. T. Defnall Ms. A. C. Chamberlain Mr. S. C. Leighty Mr. W. Garrett Ms. K. A. Roberts Mr. J. C. Haswell Mr. A. S. Parton Mr. A. Nix Mr. T.M. Drouin Document Services RTYPE: VND.LI.L00 File AR.01.02.06 Nuclear Regulatory Commission Mr. M. King Mr. G. Bowman Ms. A. Veil Mr. V. Hall Mr. G.J. Khouri Mr. G. Armstrong Mr. C. Santos Mr. B. Kemker Mr. J. Eargle Mr. C. J. Even Ms. N. C. Coovert Mr. C. Welch Mr. J. Gaslevic Mr. O. Lopez-Santiago Mr. M. Webb Mr. B. Gleaves Ms. K. McCurry

U.S. Nuclear Regulatory Commission ND-22-0654 Page 4 of 4 Nuclear Regulatory Commission Mr. B. Davis Mr. J. Parent Mr. B. Griman Mr. P. OBryan Mr. T. Fredette Mr. B. Davis State of Georgia Mr. R. Dunn (w/o enclosure)

Oglethorpe Power Corporation Mr. David Sorrick Mr. B. Brinkman Mr. E. Rasmussen Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros Westinghouse Electric Company, LLC Mr. L. Oriani, Ph.D. (w/o enclosure)

Mr. T. Rubenstein (w/o enclosure)

Mr. M. Corletti (w/o enclosure)

Mr. D. Hawkins (w/o enclosure)

Ms. S. Zwack (w/o enclosure)

Other Mr. S. W. Kline, Bechtel Power Corporation (w/o enclosure)

Ms. L. A. Matis, Tetra Tech NUS, Inc. (w/o enclosure)

Mr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc. (w/o enclosure)

Mr. S. Roetger, Georgia Public Service Commission (w/o enclosure)

Mr. R. L. Trokey, Georgia Public Service Commission (w/o enclosure)

Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Balch Bingham

Southern Nuclear Operating Company ND-22-0654 Enclosure 2 Vogtle Electric Generating Plant (VEGP) Unit 3 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (This Enclosure consists of 3 pages, including this cover page)

ND-22-0654 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 Affidavit of Brian H. Whitley

1. My name is Brian H. Whitley. I am the Regulatory Affairs Director of Southern Nuclear Operating Company (SNC). I have been delegated the function of reviewing proprietary information sought to be withheld from public disclosure and am authorized to apply for its withholding on behalf of SNC.

2. I am making this affidavit on personal knowledge, in conformance with the provisions of 10 CFR Section 2.390 of the Commissions regulations, and in conjunction with SNCs filing on docket 52-025, Vogtle Electric Generating Plant Unit 3, Licensee Guarantees of Payment of Deferred Premiums. I have personal knowledge of the criteria and procedures used by SNC to designate information as a trade secret, privileged or as confidential commercial or financial information.

3. Based on the reason(s) at 10 CFR 2.390(a)(4), this affidavit seeks to withhold from public disclosure Enclosure 1 of SNC letter ND-22-0654 for Vogtle Electric Generating Plant Unit 3, Licensee Guarantees of Payment of Deferred Premiums.

4. The following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

a. The information sought to be withheld from public disclosure has been held in confidence by SNC.

b. The information is of a type customarily held in confidence by SNC and not customarily disclosed to the public.

c. The release of the information might result in the loss of an existing or potential competitive advantage to SNC.

5. Additionally, release of the information may harm SNC because SNC has a contractual relationship with the co-owners of VEGP 3. SNC is contractually obligated to seek confidential and proprietary treatment of the information.

6. The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

7. To the best of my knowledge and belief, the information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method.

Page 2 of 3

ND-22-0654 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 I declare under penalty of perjury that the foregoing is true and correct.

___a_ _.;._u_.- - ~ - ~ - - - - - - - - - - - - - - Executed on Brian H. Whitley S(l:J/-z,:z_

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