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Category:Financial Assurance Document
MONTHYEARPLA-8052, (Sses), Proof of Financial Protection and Guarantee of Payment of Deferred Premiums2023-02-13013 February 2023 (Sses), Proof of Financial Protection and Guarantee of Payment of Deferred Premiums PLA-7991, Proof of Financial Protection and Guarantee of Payment of Deferred Premium2022-03-24024 March 2022 Proof of Financial Protection and Guarantee of Payment of Deferred Premium ML20248H4712020-08-19019 August 2020 Independent Auditor'S Report and Consolidated Financial Statements December 31, 2019 and 2018 PLA-7843, Proof of Financial Protection and Guarantee of Payment of Deferred Premiums - 10 CFR 140.212020-02-20020 February 2020 Proof of Financial Protection and Guarantee of Payment of Deferred Premiums - 10 CFR 140.21 PLA-7763, Nuclear Property Insurance Program2019-04-0101 April 2019 Nuclear Property Insurance Program PLA-7764, Guarantee of Payment of Deferred Premiums - 10 CFR 140.21 (PLA-7764)2019-02-25025 February 2019 Guarantee of Payment of Deferred Premiums - 10 CFR 140.21 (PLA-7764) PLA-7585, Annual Financial Information for the Years Ended December 31, 2105 and 20162017-04-13013 April 2017 Annual Financial Information for the Years Ended December 31, 2105 and 2016 ML17090A3152017-03-30030 March 2017 Guarantee of Payment of Deferred Premiums 10 CFR 140.21 PLA-7580, Guarantee of Payment of Deferred Premiums (Evidence of Financial Protection)2017-03-30030 March 2017 Guarantee of Payment of Deferred Premiums (Evidence of Financial Protection) PLA-7579, Property Insurance Program2017-03-30030 March 2017 Property Insurance Program PLA-7452, Guarantee of Payment of Deferred Premiums, Per 10 CFR 140.212016-04-13013 April 2016 Guarantee of Payment of Deferred Premiums, Per 10 CFR 140.21 PLA-7449, Nuclear Property Insurance Program2016-03-31031 March 2016 Nuclear Property Insurance Program ML16074A1362016-02-0909 February 2016 Certificate of Liability Insurance for Susquehanna, Units 1 and 2 ML16042A1782016-01-11011 January 2016 Certificate of Liability Insurance PLA-6969, Submittal of Nuclear Property Insurance Program2013-03-22022 March 2013 Submittal of Nuclear Property Insurance Program PLA-6824, Property Insurance Program, PLA-62842012-03-27027 March 2012 Property Insurance Program, PLA-6284 ML1123719182011-11-14014 November 2011 2010 DFS Report Analysis for Susquehanna Steam Electric Station, Unit 2 ML1123801162011-11-14014 November 2011 2010 DFS Report Analysis for Susquehanna Steam Electric Station, Unit 1 ML11109A0462011-04-11011 April 2011 Decommissioning Report of Financial Assurance PLA-6632, Guarantee of Payment of Deferred Premiums - 10 CFR 140.212010-07-14014 July 2010 Guarantee of Payment of Deferred Premiums - 10 CFR 140.21 PLA-6602, Nuclear Property Insurance Program2010-03-16016 March 2010 Nuclear Property Insurance Program PLA-6495, Submittal of Nuclear Property Damage Insurance Program2009-03-30030 March 2009 Submittal of Nuclear Property Damage Insurance Program PLA-6491, Attachment 2 to PLA-6491, Affidavit and Site-Specific Decommissioning Cost Analysis Schedules2009-03-26026 March 2009 Attachment 2 to PLA-6491, Affidavit and Site-Specific Decommissioning Cost Analysis Schedules ML0909206012009-03-26026 March 2009 Susquehanna Steam Electric Station, Decommissioning Report of Financial Assurance, PLA-6491 ML0909104062009-03-25025 March 2009 Decommissioning Report of Financial Assurance PLA-6171, Decommissioning Report of Financial Assurance2007-03-23023 March 2007 Decommissioning Report of Financial Assurance ML0709402772007-03-21021 March 2007 Decommissioning Report of Financial Assurance PLA-5979, Decommissioning Report of Financial Assurance, Supplemental Information2005-11-0707 November 2005 Decommissioning Report of Financial Assurance, Supplemental Information PLA-5863, Decommissioning Report of Financial Assurance2005-03-21021 March 2005 Decommissioning Report of Financial Assurance ML18026A1161978-08-31031 August 1978 Letter Responding to the Letter of May 17, 1978 Enclosing Information for Antitrust Review of Operating License. ML18023B3651977-04-14014 April 1977 Letter Attaching Financial Statements for Members of Allegheny Electric Cooperative, Inc. and a Federal Register Notice Published March 8, 1977 by Rea Announcing Consideration of a Loan to Ae 2023-02-13
[Table view] Category:Legal-Affidavit
MONTHYEARPLA-8015, Application for Order Approving Indirect Transfer of Control of Licenses2022-09-29029 September 2022 Application for Order Approving Indirect Transfer of Control of Licenses ML20248H4702020-08-19019 August 2020 Submittal of Annual Financial Information Required by 10 CFR 50.71 PLA-7861, Submittal of Unit 2 Cycle 21 Reload Licensing Documents to Support License Amendment Requesting Application of Advanced Framatome Methodologies (PLA-7861)2020-04-0909 April 2020 Submittal of Unit 2 Cycle 21 Reload Licensing Documents to Support License Amendment Requesting Application of Advanced Framatome Methodologies (PLA-7861) PLA-7847, Submittal of Revised Topical Report to Support License Amendment Requesting Application of Advanced Framatome Methodologies2020-03-0909 March 2020 Submittal of Revised Topical Report to Support License Amendment Requesting Application of Advanced Framatome Methodologies PLA-7841, Thirty-Day Response to Request for Additional Information Regarding Proposed License Amendment Requesting Application of Advanced Framatome Methodologies2020-02-0606 February 2020 Thirty-Day Response to Request for Additional Information Regarding Proposed License Amendment Requesting Application of Advanced Framatome Methodologies PLA-7585, Annual Financial Information for the Years Ended December 31, 2105 and 20162017-04-13013 April 2017 Annual Financial Information for the Years Ended December 31, 2105 and 2016 PLA-7500, Affidavit of Timothy S. Rausch2016-06-29029 June 2016 Affidavit of Timothy S. Rausch PLA-7274, Response to Second Request for Additional Information Regarding Application for Approval of Indirect Transfer of Control PLA-72742015-01-0505 January 2015 Response to Second Request for Additional Information Regarding Application for Approval of Indirect Transfer of Control PLA-7274 ML14204A7092014-07-23023 July 2014 Enclosure 3, Affidavit of Peter M. Yandow ML13057A5932013-02-22022 February 2013 Response to Follow-up Letter on Technical Issues for Resolution Regarding Licenses Communication Submittals ML1127000682011-09-26026 September 2011 Enclosure 3, Mfn 10-245 R4, Affidavit ML0808605052008-03-20020 March 2008 MD8079 - Susquehanna 1 and 2 - Meeting on March 18, 2008, Affidavit for Proprietary Presentation Material PLA-6236, Proposed License Amendments No. 285 & 253 for Units 1 & 2, Respectively Re Extended Power Uprate Application Supplement to Instrumentation and Controls & Balance-of-Plant Safety System2007-07-13013 July 2007 Proposed License Amendments No. 285 & 253 for Units 1 & 2, Respectively Re Extended Power Uprate Application Supplement to Instrumentation and Controls & Balance-of-Plant Safety System PLA-6203, Proposed License Amendment Extended Power Uprate Application Containment and Ventilation Technical Review Request for Additional Information Responses, PLA-62032007-06-0404 June 2007 Proposed License Amendment Extended Power Uprate Application Containment and Ventilation Technical Review Request for Additional Information Responses, PLA-6203 ML0629001612006-10-11011 October 2006 Supplemental Environmental Report for Extended Power Uprate. ML0629001622006-10-11011 October 2006 Extended Power Uprate Steam Dryer Evaluation. PLA-5979, Decommissioning Report of Financial Assurance, Supplemental Information2005-11-0707 November 2005 Decommissioning Report of Financial Assurance, Supplemental Information ML0520003282005-07-14014 July 2005 Surveillance Program for Channel-Control Blade Interference PLA-5920, Transmittal of Susquehanna - Guarantee of Payment of Deferred Premiums - 10 CFR 140.212005-06-28028 June 2005 Transmittal of Susquehanna - Guarantee of Payment of Deferred Premiums - 10 CFR 140.21 ML19186A1231979-01-17017 January 1979 Amended Petition for Leave to Intervene ML18023A7421978-09-18018 September 1978 Letter Attaching an Affidavit of Service for Amendment No. 2 to Ses Operating License Application Containing Revision No. 2 to the Final Safety Analysis Report ML18024A1451978-09-18018 September 1978 Letter Enclosing an Affidavit of Service for Amendment No. 2 of Operating License Application ML19184A5341978-07-20020 July 1978 Affidavit of Service: Environmental Report - Operating License Stage 2022-09-29
[Table view] Category:Letter type:PLA
MONTHYEARPLA-8096, Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval2024-01-0404 January 2024 Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval PLA-8077, Emergency Plan Revision 67 (PLA-8077)2023-12-27027 December 2023 Emergency Plan Revision 67 (PLA-8077) PLA-8089, Submittal of Revision to Inservice Testing Program Plan2023-12-0505 December 2023 Submittal of Revision to Inservice Testing Program Plan PLA-8084, Application to Revise Technical Specifications to Adopt TSTF-568, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.22023-11-29029 November 2023 Application to Revise Technical Specifications to Adopt TSTF-568, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2 PLA-8091, Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inseervice Inspection Interval (PLA-8091)2023-11-0808 November 2023 Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inseervice Inspection Interval (PLA-8091) PLA-8082, Proposed Amendment to Licenses NPF-14 and NPF-22: Application to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program2023-11-0202 November 2023 Proposed Amendment to Licenses NPF-14 and NPF-22: Application to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program PLA-8080, Proposed Relief for Valve 251130 (PLA-8080)2023-08-14014 August 2023 Proposed Relief for Valve 251130 (PLA-8080) PLA-8074, Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval2023-08-0303 August 2023 Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval PLA-8076, Unit 2 - 21st Refueling Outage Owner'S Activity Report (PLA-8076)2023-07-20020 July 2023 Unit 2 - 21st Refueling Outage Owner'S Activity Report (PLA-8076) PLA-8078, Submittal of Unit 2 Cycle 22 Core Operating Limits Report, Revision 1, PLA-80782023-07-0505 July 2023 Submittal of Unit 2 Cycle 22 Core Operating Limits Report, Revision 1, PLA-8078 PLA-8054, Proposed Amendment to Licenses NPF-14 and NPF-22: Remove Control Rod Operability Separation Criteria and Replace Reference to Banked Position Withdrawal Sequence with the Analyzed Rod Position Sequence2023-06-0808 June 2023 Proposed Amendment to Licenses NPF-14 and NPF-22: Remove Control Rod Operability Separation Criteria and Replace Reference to Banked Position Withdrawal Sequence with the Analyzed Rod Position Sequence PLA-8073, Proposed Relief Request for the Fifth 10-Year Inservice Inspection Interval2023-06-0101 June 2023 Proposed Relief Request for the Fifth 10-Year Inservice Inspection Interval PLA-8064, Response to NRC Regulatory Issue Summary 2023-01 (PLA-8064)2023-05-17017 May 2023 Response to NRC Regulatory Issue Summary 2023-01 (PLA-8064) PLA-8067, Notification of Completion of Emergence from Bankruptcy (PLA-8067)2023-05-17017 May 2023 Notification of Completion of Emergence from Bankruptcy (PLA-8067) PLA-8066, Notification of Planned Closing Date and Information Identified in March 30, 2023 Order, PLA-80662023-05-0808 May 2023 Notification of Planned Closing Date and Information Identified in March 30, 2023 Order, PLA-8066 PLA-8053, Radiation Exposure Information and Reporting System2023-04-27027 April 2023 Radiation Exposure Information and Reporting System PLA-8058, Annual Radiological Environmental Operating Report (PLA-8058)2023-04-26026 April 2023 Annual Radiological Environmental Operating Report (PLA-8058) PLA-8041, Radioactive Effluent Release Report and Offsite Dose Calculation Manual (PLA-8041)2023-04-25025 April 2023 Radioactive Effluent Release Report and Offsite Dose Calculation Manual (PLA-8041) PLA-8047, 2022 Annual Environmental Operating Report (Nonradiological), PLA-80472023-04-19019 April 2023 2022 Annual Environmental Operating Report (Nonradiological), PLA-8047 PLA-8062, Supplement to Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 252F007B, PLA-80622023-04-11011 April 2023 Supplement to Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 252F007B, PLA-8062 PLA-8061, Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 25F007B, PLA-80612023-04-10010 April 2023 Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 25F007B, PLA-8061 PLA-8060, Submittal of Unit 2 Cycle 22 Core Operating Limits Report (PLA-8060)2023-03-30030 March 2023 Submittal of Unit 2 Cycle 22 Core Operating Limits Report (PLA-8060) PLA-8057, Application for Order Approving Indirect Transfer of Control of Licenses and Approving Conforming License Amendments- Supplemental Information, PLA-80572023-03-15015 March 2023 Application for Order Approving Indirect Transfer of Control of Licenses and Approving Conforming License Amendments- Supplemental Information, PLA-8057 PLA-8052, (Sses), Proof of Financial Protection and Guarantee of Payment of Deferred Premiums2023-02-13013 February 2023 (Sses), Proof of Financial Protection and Guarantee of Payment of Deferred Premiums PLA-8048, Response to Request for Additional Information Regarding License Amendment Requesting Temporary Addition of Analyzed Rod Position Sequence2023-01-14014 January 2023 Response to Request for Additional Information Regarding License Amendment Requesting Temporary Addition of Analyzed Rod Position Sequence PLA-8042, Proposed Emergency Amendment to License NPF-22: Temporary Addition of Analyzed Rod Position Sequence2023-01-10010 January 2023 Proposed Emergency Amendment to License NPF-22: Temporary Addition of Analyzed Rod Position Sequence PLA-8039, Application for Order Approving Indirect Transfer of Control of License Amendments - Supplemental Information2022-12-22022 December 2022 Application for Order Approving Indirect Transfer of Control of License Amendments - Supplemental Information PLA-8038, Notification of Petition for Bankruptcy (PLA-8038)2022-12-14014 December 2022 Notification of Petition for Bankruptcy (PLA-8038) PLA-8036, Registration for the Use of Spent Fuel Storage Casks 203, 202, and 204, PLA-80362022-11-30030 November 2022 Registration for the Use of Spent Fuel Storage Casks 203, 202, and 204, PLA-8036 PLA-8035, Registration for the Use of Spent Fuel Storage Casks 205, 200, and 201, PLA-80352022-11-0808 November 2022 Registration for the Use of Spent Fuel Storage Casks 205, 200, and 201, PLA-8035 PLA-8031, Emergency Plan Revision 66 (PLA-8031)2022-11-0707 November 2022 Emergency Plan Revision 66 (PLA-8031) PLA-8032, Application for Order Approving Indirect Transfer of Control of Licenses and Approving Conforming License Amendments - Supplemental Information (PLA-8032)2022-10-28028 October 2022 Application for Order Approving Indirect Transfer of Control of Licenses and Approving Conforming License Amendments - Supplemental Information (PLA-8032) PLA-8026, Biennial 10 Crf 50.59 and 72.48 Summary Report and Changes to Regulatory Commitment (PLA-8026)2022-10-19019 October 2022 Biennial 10 Crf 50.59 and 72.48 Summary Report and Changes to Regulatory Commitment (PLA-8026) PLA-8015, Application for Order Approving Indirect Transfer of Control of Licenses2022-09-29029 September 2022 Application for Order Approving Indirect Transfer of Control of Licenses PLA-8030, Evacuation Time Estimate Report PLA-80302022-09-15015 September 2022 Evacuation Time Estimate Report PLA-8030 PLA-8025, Supplement to License Amendment to Revise Reactor Steam Dome Pressure - Low Instrumentation Function Allowable Value2022-08-10010 August 2022 Supplement to License Amendment to Revise Reactor Steam Dome Pressure - Low Instrumentation Function Allowable Value PLA-8019, Nd Refueling Outage Owner'S Activity Report, PLA-80192022-07-13013 July 2022 Nd Refueling Outage Owner'S Activity Report, PLA-8019 PLA-8013, Response to Request for Additional Information Regarding License Amendment Requesting Adoption of TSTF-505, Revision 2 PLA-80132022-06-27027 June 2022 Response to Request for Additional Information Regarding License Amendment Requesting Adoption of TSTF-505, Revision 2 PLA-8013 PLA-8012, 10 CFR 50.46 Annual Report2022-06-10010 June 2022 10 CFR 50.46 Annual Report PLA-8005, Response to Request for Additional Information Regarding License Amendment to Revise Reactor Steam Dome Pressure - Low Instrumentation Function Allowable Value (PLA-8005)2022-05-23023 May 2022 Response to Request for Additional Information Regarding License Amendment to Revise Reactor Steam Dome Pressure - Low Instrumentation Function Allowable Value (PLA-8005) PLA-8001, Radiation Exposure Information and Reporting System - PLA-80012022-04-28028 April 2022 Radiation Exposure Information and Reporting System - PLA-8001 PLA-7986, 2021 Annual Environmental Operating Report (Nonradiological) Docket No. 50-387, PLA-79862022-04-26026 April 2022 2021 Annual Environmental Operating Report (Nonradiological) Docket No. 50-387, PLA-7986 PLA-7987, Radioactive Effluent Release Report and Offsite Dose Calculation Manual - (PLA-7987)2022-04-26026 April 2022 Radioactive Effluent Release Report and Offsite Dose Calculation Manual - (PLA-7987) PLA-7985, Annual Radiological Environmental Operating Report2022-04-22022 April 2022 Annual Radiological Environmental Operating Report PLA-7883, Proposed Amendment to Licenses NPF-14 and NPF-22: Relocate Technical Specification Unit Staff Qualification Requirements to Quality Assurance Program (PLA-7883)2022-03-31031 March 2022 Proposed Amendment to Licenses NPF-14 and NPF-22: Relocate Technical Specification Unit Staff Qualification Requirements to Quality Assurance Program (PLA-7883) PLA-7995, Property Insurance Program (PLA-7995)2022-03-30030 March 2022 Property Insurance Program (PLA-7995) PLA-7998, Submittal of Unit 1 Cycle 23 Core Operating Limits Report and Reload Safety Analysis Report2022-03-29029 March 2022 Submittal of Unit 1 Cycle 23 Core Operating Limits Report and Reload Safety Analysis Report PLA-7991, Proof of Financial Protection and Guarantee of Payment of Deferred Premium2022-03-24024 March 2022 Proof of Financial Protection and Guarantee of Payment of Deferred Premium PLA-7984, Supplement to License Amendment Requesting Adoption of TSTF-505, Revision 22022-03-0808 March 2022 Supplement to License Amendment Requesting Adoption of TSTF-505, Revision 2 PLA-7962, Application to Revise Technical Specifications to Adopt TSTF-564, Safety Limit MCPR PLA-79622022-01-0505 January 2022 Application to Revise Technical Specifications to Adopt TSTF-564, Safety Limit MCPR PLA-7962 2024-01-04
[Table view] |
Text
P kI I Britt T. McKlnney PPL Susquohanna, LLC ' % ai '*$
Sr. Vice President & Chief Nuclear Officer 769 Salem Boulevard %$m *a -
Berwick, PA 18603 . # -
Tel. 570.542.3149 Fax 570.542.1504 v.
btmckinney@pplweb.com
NOV 0 7 2005 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station OP1-17 Washington, DC 20555 Submitted pursuant SUSQUEHANNA STEAM ELECTRIC STATION to 10 CFR 2.390 DECOMMISSIONING REPORT OF FINANCIAL ASSURANCE SUPPLEMENTAL INFORMATION Docket Nos. 50-387 PLA-5979 and 50-388
Reference:
- 1) PLA-5863, B. T. McKinney (PPL) to Document ControlDesk (USNRC),
"Decommnissioning Report of FinancialAssurance, "dated March 21, 2005.
This letter provides supplemental information requested in a teleconference held between PPL and NRC on October 19, 2005. This supplemental information was requested to support NRC's review of the PPL Susquehanna LLC decommissioning report of financial assurance submitted on March 21, 2005 [Reference 1].
During the teleconference, NRC requested PPL to provide additional information related to the SAFSTOR decommissioning option. The information requested is included herein as Attachments 1 and 2. consists of the "Nuclear Trust Fund Earnings Rate" discussion from Section M, "Nuclear Decommissioning Costs," of the 1995 Pennsylvania Public Utility Commission (PUC) order. contains proprietary information and therefore PPL requests that this information be withheld from public disclosure pursuant to 10 CFR §9.17(a)(4) and the policy reflected in 10 CFR §2.390, as described in my enclosed Affidavit. The information provided on Attachment 2 is only related to the SAFSTOR decommissioning option. Also, note that the cash disbursements are for 100% of the units with the PPL share being 90%.
Af1
Document Control Desk PLA-5979 Should you have any questions regarding this submittal or require additional information, please contact Mr. Duane L. Filchner at (610) 774-7819.
Sincerely, B. T. MeKinney Attachments: 1995 PUC Order Section M Nuclear Decommissioning Costs, Part 5 Affidavit and Cost Estimate Summary Copy: Regional Administrator - Region I Mr. B. A. Bickett, NRC Sr. Resident Inspector Mr. R. V. Guzman, NRC Project Manager Mr. R. Janati, DEP/BRP
ATTACHMENT 1 TO PLA-5979 1995 PUC ORDER SECTION M, Part 5 NUCLEAR TRUST FUND EARNINGS RATE
Consequently, the OTS concludes that the proper approach is to allow for recovery of prior accruals over the life U of the plant and to remove the inflation factor from PP&L's decommissioning expense claim. (OTS Exc., p. 17). This, in OTS' view, would result in a $18,297,000 decommissioning expense, as opposed to $30,042,000, which, in Pennsylvania, would translate into a $8,5s1,000 adjustment and a $9,040,000 revenue requirement. (OTS Exc., p. 17, n. 8).
After examination of the parties' position, we affirm the AL3's recommendation that the decommissioning expense be recovered using PP&L's annual annuity accrual method. (R.D. p.
99; PP&L M.B., p. 124). We do so here for several reasons.
First, the use of the OTS' truncated amortization recovery period, unlike PP&L's annual annuity accrual method, would result in significant cost increases if either a one year period, consistent with the approach taken in the 1985 rate case, or a multiple year period approach were taken. In addition, PP&L's approach reasonably tries to mitigate "back-end load" expense recovery that could unfairly burden customers in the future with ever-increasing revenue requirements for decommissioning prior plants. Finally, we :share PP&L's fundamental concern that cost escalation is.a significant consideration, which PP&L accounts for in its inflation estimate, precisely because future earnings may not necessarily keep pace with the general inflation rate or, even more importantly, industry-specific decommissioning costs. Taken in toto, we conclude that affirming the ALJ's recommendation is in the public interest in this case.
- 5. Nuclear Trust Fund Earnings Rate.
The last issue concerns the appropriate earnings rate 94
imputed to the nuclear decommissioning trust created by virtue of this Opinion and Order. (R.D., pp.81-107).
PP&L proposes a four percent (4%) annual escalation of cost offset by estimated earnings of five and one-half (5 1/2%)
percent to derive a sum of money PP&L must accrue by the time the Susquehanna plants are retired. (R.D., pp. 81-82). PP&L claims that their trust fund earnings estimate is premised on an interrelationship between its proposed earnings rate on trust fund assets and the projected cost of decommissioning the nuclear plants. PP&L also claims that their 5.5 percent trust fund earnings rate represents its attempt to make sure that sufficient funds are available to decommission the plants, at retirement, using a cautious and conservative investment strategy. PP&L bases this approach on the fact that funds will be needed over a relatively brief period of time, when decommissioning occurs, and that the funds must be adequate. (R.D., pp. 83-84, 94). PP&L disagrees with the OCA' s proposal .of a 7.5 percent trust fund earnings rate as a consequence of the OCA's investment strategy which assumes an eight percent return on bonds and 12 percent on equities. PP&L claims that the ratios and returns will evolve over time. (R.D., pp.81-106).
The OCA presses for an earnings rate of 7.5 percent on the funds set aside to meet the total decommissioning cost estimate of $804 million. (R.D., p. 86). The OCA notes that it will take 10 to 12 years to decommission the units, that interest will accrue on those funds in the interim and during decommissioning, and that PP&L's proposal is not overly aggressive. (R.D., pp. 86-87). In particular, the OCA counters PP&L's claims concerning an investment strategy by noting the conservative 30% equity premise in the OCA's earnings analysis.
(R.D., p. 90).
95
The OTS would support a 5.5 percent earnings figure but, unlike PP&L, the OTS would also begin with a lower $18 million allowance (as opposed to PP&L's $30 million allowance) by factoring out contingencies. (R.D., pp. 84-85). The OTS prefers to use the Commission methodology used in the last PP&L rate case proceeding. (R.D., p. 85).
PPLICA states that the 5.5 percent figure is well below the return the Company claims on its own rate base. PPLICA would increase the estimate. PPLICA suggests a rate of return equal to that requested by the Company, 10.23 percent. (R.D., pp. 90-91).
The DOD and Mr. Epstein briefly discuss the issues generically without proposing a specific trust fund earnings rate. (R.D.,
pp.90-106).
The ALJ, based on the earlier recommendation on eliminating the contingency factor, recommended a cautious approach to the earnings estimate. -While noting that PP&L might well do better than their proposed 5.5 percent earnings rate, the ALJ went on to recommend retention 6f PP&L's reasonable, if conservative, 5.5 percent proposal. (R.D., pp.99-100).
PP&L dismisses the parties challenges to the recommendation. (PP&L R. Exc., p. 17). PP&L claims that the OCA's and PPLICA's proposals to increase the earnings rate above 5.5 percent are not sustainable because it is inappropriate to equate the earnings rate on a trust fund with claimed returns on equity. (PP&L R. Exc., p. 17). PP&L further claims that the OCA and PPLICA ignore the complex interrelationship between the inflation and earnings rates in the annuity calculation. (PP&L R. Exc., p. 17).
The OCA contests the AUJ's recommendation for a 5.5 percent earnings rate on the trust fund. (OCA Exc., pp. 36-37).
The OCA explains that PP&L will be placing the decommissioning 96
S funds collected from ratepayers into an external Nuclear Decommissioning Trust Fund. This Fund will then generate earnings which will be incorporated into the fund. The OCA reiterates their claim that PP&L's estimate of trust fund earnings is too low, particularly in light of PP&L's request to utilize a prudent person standard for fund investment as a result of a change in federal law. (OCA Exc., pp. 36-37 citing OCA M.B., pp. 169-176; OCA R.B., pp. 85-86). The OCA further claims that use of PP&L's "conservative" estimate is inappropriate --
especially in light of the additional recommendation to remove the "black lung" restrictions on investments. The OCA further claims that allowing PP&L to understate the return on the Trust Fund results in a significant increase in the decommissioning revenue requirements sought from ratepayers in this case. (OCA Exc., pp. 36-37 citing OCA M.B., pp. 169-176).
PPLICA supports an increase in trust fund earnings rates for several reasons. (PPLICA.Exc., pp. 30-32). PPLICA S claims that PP&L should be required to manage their trust fund investments, at levels comparable to those approaches taken to manage their own rate base investments. From an investor's perspective, PPLICA claims that the ratepayers are essentially providing advance funding for this known expense and that, as advance investors of these funds, they are entitled to a return on their investment similar to that which PP&L proposes for PP&L's investments. PPLICA, unlike the OCA, proposes an even higher rate of 9.26% based on the fact that this figure is the rate of return recommended by the ALJ for PP&L's own investment.
(PPLICA Exc., pp. 30-32).
After due consideration of the positions, we determine that the 7.5% figure proposed by the OCA is an appropriate earnings rate for the decommissioning trust fund that will be funded as a result of today's decision. We do so for several ML reasons. First, we agree with the parties that this known 97
expense also contains components whose exact costs may not exactly be established at this time. Consequently, the holder of the funds expected to meet this known and measurable, but not precisely quantifiable, expense should be encouraged to exercise their market sophistication in order to generate an adequate return to meet this expense. By holding PP&L to 7.5%, we underscore the importance attached to generating returns adequate to help meet this obligation. This figure also strikes a balance between the higher 9.26% proposed by PPLICA and the overly cautious 5.5 percent rate proposed by PP&L. Furthermore, we have also approved removal of the black lung restrictions even as we hold PP&L to ERISA standards. This additional flexibility will provide PP&L with more opportunities to meet this 7.5% rate notwithstanding our approval of the AIJ's recommendation that PP&L be held to ERISA standards on these funds.
N. Fossil Decommissioning Expense PP&L proposes to establish an annuity, similar to the one used for nuclear decommissioning, to recover the cost of dismantling and demolishing its fossil-fired generating plants, following their retirement from service. (R.D., p. 100). This would include 14 units in service and two units that are now deactivated. (R.D., pp. 100). The jurisdictional expense claim would be $45 million and payments to a fossil decommissioning trust are not deductible for federal income tax purposes. (R.D.,
pp. 100-101).
PP&L's estimate was developed by Mr. LaGuardia. PP&L concedes this approach represents a departure from the conventional method of de-commissioning non-nuclear units.
Absent commission approval of the proposal, the costs would continue to be recoverable as a form of net negative salvage.
(R.D., pp. 100-102).
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ATTACHMENT 2 TO PLA-5979 COST ESTIMATE
SUMMARY
AFFIDAVIT OF BRITT T. McKINNEY I, Britt T. McKinney, Senior Vice President & Chief Nuclear Officer of PPL Susquehanna, LLC (PPL), do hereby affirm and state:
I am an officer of PPL authorized to execute this affidavit on its behalf. I am further authorized to review information submitted to the Nuclear Regulatory Commission and apply for the withholding of information from disclosure.
- 2. PPL is providing information which constitutes proprietary financial information that should be held in confidence by the NRC pursuant to the policy reflected in 10 CFR §§ 2.390(a)(4) and 9.17(a)(4), because:
- i. This information is and has been held in confidence by PPL.
ii. This information is of a type that is held in confidence by PPL, and there is a rational basis for doing so because the information contains sensitive financial information.
iii. This information is being transmitted to the NRC in confidence.
iv. This information is not available in public sources and could not be gathered readily from other publicly available information.
- v. Public disclosure of this information would create substantial harm to the competitive position of PPL by disclosing PPL's internal cost projections to other parties whose commercial interests may be adverse to those of PPL.
- 3. Accordingly, PPL requests that the designated documents be withheld from public disclosure pursuant to the policy reflected in 10 CFR §§ 2.390(a)(4) and 9.1 7(a)(4)-
9.17(-a)(4'.,PPL Susquehanna, LLC Britt T. McKinney Senior Vice President &
Chief Nuclear Officer Subscribed and sworn before me, a Notary Public in and for the Commonwealth of Pennsylvania this r1 day of aovember, 2005 Notaral Sea]
a JLaurie Minto, Notary Public A 0 allw Vd-OSalem Twp.. Luzerne County06 My Commission Expires July 24. 2006 MemberPennsynla Assoadonof Notanes