CP-201201424, ISFSI, Additional Information Regarding Application for Order Approving Indirect and Internal Transfer of Licenses: Difference between revisions

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| issue date = 11/26/2012
| issue date = 11/26/2012
| title = ISFSI, Additional Information Regarding Application for Order Approving Indirect and Internal Transfer of Licenses
| title = ISFSI, Additional Information Regarding Application for Order Approving Indirect and Internal Transfer of Licenses
| author name = Madden F W, Flores R
| author name = Madden F, Flores R
| author affiliation = Luminant Power, Luminant Generation Co, LLC
| author affiliation = Luminant Power, Luminant Generation Co, LLC
| addressee name =  
| addressee name =  
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:ENCLOSURE 1 (PROPRIETARY)
{{#Wiki_filter:ENCLOSURE 1 (PROPRIETARY) CONTAINS PROPRIETARY INFORMATION SUBMITTED UNDER 10 CFR 2.390 WITHHOLD FROM PUBLIC DISCLOSURE Rafael Flores                         Luminant Power Senior Vice President                 P 0 Box 1002 0                                                           & Chief Nuclear Officer             6322 North FM 56 rafael.flores@Luminant.com           Glen Rose, TX 76043 Lumminant                                                                                           T 254 897 5550 C 817 559 0403 F 254 897 6652 CP-201201424                                                                                 10 CFR 50.80 TXX-12181                                                                                     10 CFR 2.390 November 26, 2012 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Director, Office of Nuclear Reactor Regulation Washington, DC 20555
CONTAINS PROPRIETARY INFORMATION SUBMITTED UNDER 10 CFR 2.390 WITHHOLD FROM PUBLIC DISCLOSURE Rafael Flores Luminant Power Senior Vice President P 0 Box 1002 0 & Chief Nuclear Officer 6322 North FM 56 rafael.flores@Luminant.com Glen Rose, TX 76043 Lumminant T 254 897 5550 C 817 559 0403 F 254 897 6652 CP-201201424 10 CFR 50.80 TXX-12181 10 CFR 2.390 November 26, 2012 U.S. Nuclear Regulatory Commission Attention:
Document Control Desk Director, Office of Nuclear Reactor Regulation Washington, DC 20555  


==SUBJECT:==
==SUBJECT:==
Line 29: Line 27:


==Dear Sir or Madam:==
==Dear Sir or Madam:==
Luminant Generation Company LLC ("Luminant Power"), acting on behalf of Energy Future Holdings Corp. ("EFH"), Energy Future Competitive Holdings Company ("EFCH"), Texas Competitive Electric Holdings Company LLC, and Luminant Holding Company LLC, hereby submits additional information in connection with the indirect transfer of licenses requested in Reference 1.As a result of discussions with the NRC staff on November 15, 2012, Luminant Power is providing historical financial information in Enclosure 1.The requested information includes proprietary, separately bound Enclosure 1 (Proprietary), which contains confidential commercial or financial information.
 
Luminant Power, EFH, EFCH, Texas Competitive Electric Holdings Company LLC, and Luminant Holding Company LLC request that Enclosure 1 (Proprietary) be withheld from public disclosure pursuant to 10 CFR 9.17(a)(4) and the policy reflected in 10 CFR 2.390(a)(4), as described in the Affidavit of Fred W. Madden, which is provided in Enclosure 1 to the Application.
Luminant Generation Company LLC ("Luminant Power"), acting on behalf of Energy Future Holdings Corp. ("EFH"), Energy Future Competitive Holdings Company ("EFCH"), Texas Competitive Electric Holdings Company LLC, and Luminant Holding Company LLC, hereby submits additional information in connection with the indirect transfer of licenses requested in Reference 1.
A non-proprietary version of Enclosure 1 (Non-Proprietary) suitable for public disclosure is provided in the Application.
As a result of discussions with the NRC staff on November 15, 2012, Luminant Power is providing historical financial information in Enclosure 1.
The requested information includes proprietary, separately bound Enclosure 1 (Proprietary), which contains confidential commercial or financial information. Luminant Power, EFH, EFCH, Texas Competitive Electric Holdings Company LLC, and Luminant Holding Company LLC request that Enclosure 1 (Proprietary) be withheld from public disclosure pursuant to 10 CFR 9.17(a)(4) and the policy reflected in 10 CFR 2.390(a)(4), as described in the Affidavit of Fred W. Madden, which is provided in Enclosure 1 to the Application. A non-proprietary version of Enclosure 1 (Non-Proprietary) suitable for public disclosure is provided in the Application.
A member of the STARS Alliance Callaway
A member of the STARS Alliance Callaway
* Comanche Peak -Diablo Canyon
* Comanche Peak - Diablo Canyon
* Palo Verde -San Onofre -South Texas Project
* Palo Verde - San Onofre - South Texas Project
* Wolf Creek U.S. Nuclear Regulatory Commission TXX-12181 Page 2 of 2 If the NRC requires additional information concerning the enclosed application, please contact Fred Madden, Director Oversight and Regulatory Affairs, Luminant Power, tel: (224) 897-8601 and email: Fred.Madden@luminant.com.
* Wolf Creek
This letter contains no new licensing basis commitments regarding Comanche Peak Nuclear Power Plant Units 1 and 2.Sincerely, Luminant Generation Company LLC Rafael Flores By:S~/2 T~~Fred W. Madden Director, Oversight and Regulatory Affairs Affirmation Affidavit Enclosure 1 c -w/o proprietary Enclosure except * (paper copy)E. J. Leeds, Director, Office of Nuclear Reactor Regulation E. E. Collins, Region IV* B. K. Singal, NRR Resident Inspectors, Comanche Peak Affirmation TXX-12181 Page 1 Affirmation I, Fred W. Madden, being duly sworn, state that I am the Director, Oversight and Regulatory Affairs for Comanche Peak Nuclear Power Plant, Luminant Generation Company LLC ("Luminant Power"), that I am authorized to sign and file this Application with the Nuclear Regulatory Commission on behalf of Luminant Power and its affiliates, and that the statements made and the matters set forth herein pertaining to Luminant Power and its affiliates are true and correct to the best of my knowledge, information, and belief.Luminant Generation Company LLC/Fr'e W. Madden Director, Oversight and Regulatory Affairs STATE OF________
 
COUNTY OF Somer\/e II Subscribed and sworn to before me, a Notary Public, in and for the County and State above named, this 26th day of November 2012.4 P. DEBRA LOUISE PILOIAN ]° Notary Publir M T----.11F My Commission Expires: -7 Affidavit TXX-12181 Page 1 10 CFR 2.390 AFFIDAVIT OF FRED W. MADDEN I, Fred W. Madden, Director, Oversight and Regulatory Affairs state that: 1. I am authorized to execute this affidavit on behalf of Luminant Generation Company LLC ("Luminant Power") and its affiliates.
U.S. Nuclear Regulatory Commission TXX-12181 Page 2 of 2 If the NRC requires additional information concerning the enclosed application, please contact Fred Madden, Director Oversight and Regulatory Affairs, Luminant Power, tel: (224) 897-8601 and email:
: 2. Luminant Power is providing information in support of its "Application for Order Approving Indirect Transfer of Licenses." The Proprietary Version of Enclosure 1 being provided in this submittal contain financial pro forma statements related to revenues from sales of energy and capacity from Comanche Peak Nuclear Power Plant (CPNPP) and confidential information regarding anticipated assets, liabilities and capital structure at the time of transfer.
Fred.Madden@luminant.com.
These documents constitute proprietary commercial and 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: a. This information is and has been held in confidence by Luminant Power and its affiliates.
This letter contains no new licensing basis commitments regarding Comanche Peak Nuclear Power Plant Units 1 and 2.
: b. This information is of a type that is held in confidence by Luminant Power and its affiliates, and there is a rational basis for doing so because the information contains sensitive financial competitive information concerning Luminant Power affiliates' anticipated revenues and operating expenses.c. This information is being transmitted to the NRC in confidence.
Sincerely, Luminant Generation Company LLC Rafael Flores By:S~/2           T~~
: d. This information is not available in public sources and could not be gathered readily from other publicly available information.
Fred W. Madden Director, Oversight and Regulatory Affairs Affirmation Affidavit c - w/o proprietary Enclosure except     * (paper copy)
: e. Public disclosure of this information would create substantial harm to the competitive position of Luminant Power by disclosing its internal financial pro forma statements and the commercial terms of a unique transaction to other parties whose commercial interests may be adverse to those of Luminant Power.
E. J. Leeds, Director, Office of Nuclear Reactor Regulation E. E. Collins, Region IV
Affidavit TXX-12181 Page 2 3. Accordingly, Luminant Power requests that the designated documents be withheld from public disclosure pursuant to the policy reflected in 10 CFR 2.390(a)(4) and 9.17(a)(4).
* B. K. Singal, NRR Resident Inspectors, Comanche Peak
Luminant Generation Company LLC Fred W. Madden Director, Oversight and Regulatory Affairs STATE OF T k 5 COUNTY OF J oer di\Subscribed and sworn to me, a Notary Public, in and for the County and State above named, this 26th day of November 2012.I ,~* ~ DEBRA LOUISE PILOIAN(1I My Commission Expires July 21, 2015 My Commission Expires: I7 -At -\
 
Affirmation TXX-12181 Page 1 Affirmation I, Fred W. Madden, being duly sworn, state that I am the Director, Oversight and Regulatory Affairs for Comanche Peak Nuclear Power Plant, Luminant Generation Company LLC
("Luminant Power"), that I am authorized to sign and file this Application with the Nuclear Regulatory Commission on behalf of Luminant Power and its affiliates, and that the statements made and the matters set forth herein pertaining to Luminant Power and its affiliates are true and correct to the best of my knowledge, information, and belief.
Luminant Generation Company LLC
                                                      /Fr'e W. Madden Director, Oversight and Regulatory Affairs STATE OF________
COUNTY OF Somer\/e                       II Subscribed and sworn to before me, a Notary Public, in and for the County and State above named, this 26th day of November 2012.
4           P. LOUISE PILOIAN DEBRA Notary Publir q*ts~t.
              ° 1l__:*
                                                  ]
M T----.11F My Commission Expires: -7
 
Affidavit TXX-12181 Page 1 10 CFR 2.390 AFFIDAVIT OF FRED W. MADDEN I, Fred W. Madden, Director, Oversight and Regulatory Affairs state that:
: 1.       I am authorized to execute this affidavit on behalf of Luminant Generation Company LLC ("Luminant Power") and its affiliates.
: 2.       Luminant Power is providing information in support of its "Application for Order Approving Indirect Transfer of Licenses." The Proprietary Version of Enclosure 1 being provided in this submittal contain financial pro forma statements related to revenues from sales of energy and capacity from Comanche Peak Nuclear Power Plant (CPNPP) and confidential information regarding anticipated assets, liabilities and capital structure at the time of transfer. These documents constitute proprietary commercial and 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:
: a.     This information is and has been held in confidence by Luminant Power and its affiliates.
: b.     This information is of a type that is held in confidence by Luminant Power and its affiliates, and there is a rational basis for doing so because the information contains sensitive financial competitive information concerning Luminant Power affiliates' anticipated revenues and operating expenses.
: c.     This information is being transmitted to the NRC in confidence.
: d.     This information is not available in public sources and could not be gathered readily from other publicly available information.
: e.     Public disclosure of this information would create substantial harm to the competitive position of Luminant Power by disclosing its internal financial pro forma statements and the commercial terms of a unique transaction to other parties whose commercial interests may be adverse to those of Luminant Power.
 
Affidavit TXX-12181 Page 2
: 3.       Accordingly, Luminant Power requests that the designated documents be withheld from public disclosure pursuant to the policy reflected in 10 CFR 2.390(a)(4) and 9.17(a)(4).
Luminant Generation Company LLC Fred W. Madden Director, Oversight and Regulatory Affairs STATE OF       T       k 5 COUNTY OF J oer               di\
Subscribed and sworn to me, a Notary Public, in and for the County and State above named, this 26th day of November 2012.
I   ,~*~   DEBRA LOUISE PILOIAN(1I My Commission Expires July 21, 2015 My Commission Expires: I7-At -\
 
Enclosure 1 (Non Proprietary)
TXX-12181 Page 1 of 6 Comanche Peak Units
$ millions, unless noted YTD Sept.
2011 A      2012A 1
INCOME STATEMENT Revenues Fuel & Purchased Power Gross Margin Operations & Maintenance Expense Luminant Allocated Overhead Property Taxes Other Income / (Expense)
EBITDA Depreciation &Amortization EBIT Interest Expense Interest Income & Special Projects EBT 2
Tax Expense Net Income Fixed O&M Expense Detail Base O&M Outage O&M Special Project O&M Total O&M 1
CASH FLOW STATEMENT Net Income Depreciation & Amortization 2
Deferred Taxes Change in Working Capital Operating Cash Flow Nuclear Fuel Capital Expenditures Other Existing Asset Capital Expenditures                        3 Free Cash Flow Before Environmental Retrofit Program Environmental retrofit capital expenditures 4 Free Cash Flow 1 Financial Statements represent a management reporting view and are consistent with projections 2 EFH Corp. files a consolidated federal income tax return, and therefore, Luminant Holding, Luminant, and Comanche Peak are disregarded entities for federal income tax purposes.
EFH Corp. deferred income taxes are allocated to Luminant Holding, Luminant, and Comanche Peak consistent with management reporting view Excludes environmental retrofit capital expenditures detailed below 4 Environmental retrofit capital expenditures related to upgrading emissions control equipment at existing Luminant Holdings coal units
 
Enclosure 1 (Non Proprietary)
TXX-12181 Page 2 of 6 Comanche Peak Units
$ millions, unless noted YTD Sept.
2011 A  2012A COMPOSITION OF REVENUE PROJECTIONS Capacity (End of Year)
Coal - merchant                            [MW]
Coal - contract                            [MW]
Nuclear                                    [MW]
Total                                [MW]
Nuclear Capacity Factor                          1%]
Production, net of auxilliary load Coal - merchant                            [TWh]
Coal - contract                            [TWh]
Nuclear                                    [TWh]
Total                                [TWh]
Pricing Assumptions Settled gas price (HSC)                [$ / MMBtu]
Realized heat rate                  [MMBtu / MWh]
Realized power price                    [$/ MWh]
Commodity Exposure - Natural Gas Nuclear plant exposure              [Million MMBtu]
Forward power sales (Alcoa)          [Million MMBtu]
Natural gas hedges allocated        [Million MMBtu]
Net natural gas exposure            [Million MMBtu]
Sensitivity to +/- $1 move                [$ MM]
Commodity Exposure - Heat Rate Nuclear plant exposure                    [TWh]
Forward power sales                      [TWh]
Net heat rate exposure                    [TWh]
Sensitivity to +/- 0.25X HR change      [$ MM]
Revenue summary Nuclear plant revenues                  [$ MM]
Other deregulated revenues                [$ MM]
Regulated revenues                      [$ MM]
Intercompany eliminations                [$ MM]
Total                              [$ MM]
 
Enclosure 1 (Non Proprietary)
Enclosure 1 (Non Proprietary)
TXX-12181 Page 1 of 6 Comanche Peak Units$ millions, unless noted YTD Sept.2011 A 2012A INCOME STATEMENT 1 Revenues Fuel & Purchased Power Gross Margin Operations  
TXX-12181 Page 3 of 6 Luminant Power
& Maintenance Expense Luminant Allocated Overhead Property Taxes Other Income / (Expense)EBITDA Depreciation  
$ millions, unless noted YTD Sept.
& Amortization EBIT Interest Expense Interest Income & Special Projects EBT Tax Expense 2 Net Income Fixed O&M Expense Detail Base O&M Outage O&M Special Project O&M Total O&M CASH FLOW STATEMENT 1 Net Income Depreciation  
2011 A       2012A INCOME STATEMENT' Revenues Fuel & Purchased Power Gross Margin Operations & Maintenance Expense Luminant Allocated Overhead Property Taxes Other Income / (Expense)
& Amortization Deferred Taxes 2 Change in Working Capital Operating Cash Flow Nuclear Fuel Capital Expenditures Other Existing Asset Capital Expenditures Free Cash Flow Before Environmental Retrofit Program 3 Environmental retrofit capital expenditures 4 Free Cash Flow 1 Financial Statements represent a management reporting view and are consistent with projections 2 EFH Corp. files a consolidated federal income tax return, and therefore, Luminant Holding, Luminant, and Comanche Peak are disregarded entities for federal income tax purposes.EFH Corp. deferred income taxes are allocated to Luminant Holding, Luminant, and Comanche Peak consistent with management reporting view Excludes environmental retrofit capital expenditures detailed below 4 Environmental retrofit capital expenditures related to upgrading emissions control equipment at existing Luminant Holdings coal units Enclosure 1 (Non Proprietary)
EBITDA Depreciation & Amortization EBIT Interest Expense Interest Income & Special Projects EBT 2
TXX-12181 Page 2 of 6 Comanche Peak Units$ millions, unless noted YTD Sept.2011 A 2012A COMPOSITION OF REVENUE PROJECTIONS Capacity (End of Year)Coal -merchant [MW]Coal -contract [MW]Nuclear [MW]Total [MW]Nuclear Capacity Factor 1%]Production, net of auxilliary load Coal -merchant [TWh]Coal -contract [TWh]Nuclear [TWh]Total [TWh]Pricing Assumptions Settled gas price (HSC) [$ / MMBtu]Realized heat rate [MMBtu / MWh]Realized power price [$ / MWh]Commodity Exposure -Natural Gas Nuclear plant exposure [Million MMBtu]Forward power sales (Alcoa) [Million MMBtu]Natural gas hedges allocated
Tax Expense Net Income CASH FLOW STATEMENT' Net income Depreciation & Amortization 2
[Million MMBtu]Net natural gas exposure [Million MMBtu]Sensitivity to +/- $1 move [$ MM]Commodity Exposure -Heat Rate Nuclear plant exposure [TWh]Forward power sales [TWh]Net heat rate exposure [TWh]Sensitivity to +/- 0.25X HR change [$ MM]Revenue summary Nuclear plant revenues [$ MM]Other deregulated revenues [$ MM]Regulated revenues [$ MM]Intercompany eliminations
Deferred Taxes Change in Working Capital Operating Cash Flow Existing Asset Capital Expenditures (including nuclear fuel)    3 Free Cash Flow Before Environmental Retrofit Program Environmental retrofit capital expenditures 4 Free Cash Flow Financial Statements represent a management reporting view and are consistent with projections 2 EFH Corp. files a consolidated federal income tax return, and therefore, Luminant Holding, Luminant, and Comanche Peak are disregarded entities for federal income tax purposes.
[$ MM]Total [$ MM]
EFH Corp. deferred income taxes are allocated to Luminant Holding, Luminant, and Comanche Peak consistent with management reporting view Excludes environmental retrofit capital expenditures detailed below 4 Environmental retrofit capital expenditures related to upgrading emissions control equipment at existing Luminant Holdings coal units
 
Enclosure 1 (Non Proprietary)
Enclosure 1 (Non Proprietary)
TXX-12181 Page 3 of 6 Luminant Power$ millions, unless noted YTD Sept.2011 A 2012A INCOME STATEMENT' Revenues Fuel & Purchased Power Gross Margin Operations
TXX-12181 Page 4 of 6 Luminant Power
& Maintenance Expense Luminant Allocated Overhead Property Taxes Other Income / (Expense)EBITDA Depreciation
$ millions, unless noted Y-D Sept.
& Amortization EBIT Interest Expense Interest Income & Special Projects EBT Tax Expense 2 Net Income CASH FLOW STATEMENT' Net income Depreciation
2011 A 2012A COMPOSITION OF REVENUE PROJECTIONS Capacity (End of Year)
& Amortization Deferred Taxes 2 Change in Working Capital Operating Cash Flow Existing Asset Capital Expenditures (including nuclear fuel)Free Cash Flow Before Environmental Retrofit Program 3 Environmental retrofit capital expenditures 4 Free Cash Flow Financial Statements represent a management reporting view and are consistent with projections 2 EFH Corp. files a consolidated federal income tax return, and therefore, Luminant Holding, Luminant, and Comanche Peak are disregarded entities for federal income tax purposes.EFH Corp. deferred income taxes are allocated to Luminant Holding, Luminant, and Comanche Peak consistent with management reporting view Excludes environmental retrofit capital expenditures detailed below 4 Environmental retrofit capital expenditures related to upgrading emissions control equipment at existing Luminant Holdings coal units Enclosure 1 (Non Proprietary)
Coal - merchant                           [MW]
TXX-12181 Page 4 of 6 Luminant Power$ millions, unless noted Y-D Sept.2011 A 2012A COMPOSITION OF REVENUE PROJECTIONS Capacity (End of Year)Coal -merchant [MW]Coal -contract [MW]Nuclear [MW]Total [MW]Production, net of auxilliary load Coal -merchant [TWh]Coal -contract [TWh]Nuclear [TWh]Total [TWh]Pricing Assumptions Settled gas price (HSC) [$ / MMBtu]Realized heat rate [MMBtu / MWh]Realized power price [$ / MWh]Commodity Exposure -Natural Gas Coal & nuclear plant exposure [Million MMBtu]-Forward power sales (Alcoa) [Million MMBtu]Natural gas hedges allocated  
Coal - contract                           [MW]
[Million MMBtu]Net natural gas exposure [Million MMBtu]Sensitivity to +/- $1 move [$ MM]Commodity Exposure -Heat Rate Coal & nuclear plant exposure [TWh]Forward power sales [TWh]Net heat rate exposure [TWh]Sensitivity to +/- 0.25X HR change [$ MM]Revenue summary Coal, gas & nuclear plant revenues [$ MM]Other deregulated revenues [$ MM]Regulated revenues [$ MM]Intercompany eliminations  
Nuclear                                   [MW]
[$ MM]Total [$ MM]
Total                                 [MW]
Production, net of auxilliary load Coal - merchant                           [TWh]
Coal - contract                           [TWh]
Nuclear                                   [TWh]
Total                               [TWh]
Pricing Assumptions Settled gas price (HSC)               [$ / MMBtu]
Realized heat rate                 [MMBtu / MWh]
Realized power price                   [$ / MWh]
Commodity Exposure - Natural Gas Coal & nuclear plant exposure       [Million MMBtu]
          -Forward power sales (Alcoa)         [Million MMBtu]
Natural gas hedges allocated       [Million MMBtu]
Net natural gas exposure           [Million MMBtu]
Sensitivity to +/- $1 move               [$ MM]
Commodity Exposure - Heat Rate Coal & nuclear plant exposure             [TWh]
Forward power sales                       [TWh]
Net heat rate exposure                   [TWh]
Sensitivity to +/- 0.25X HR change     [$ MM]
Revenue summary Coal, gas & nuclear plant revenues       [$ MM]
Other deregulated revenues               [$ MM]
Regulated revenues                       [$ MM]
Intercompany eliminations               [$ MM]
Total                               [$ MM]
 
Enclosure 1 (Non Proprietary)
TXX-12181 Page 5 of 6 Luminant Holdings
$ millions, unless noted YTD Sept.
2011 A      2012A INCOME STATEMENT' Revenues Fuel & Purchased Power Gross Margin Operations & Maintenance Expense General & Administrative Other Income / (Expense)
EBITDA Depreciation & Amortization EBIT Interest Expense Interest Income & Special Projects EBT 2
Tax Expense Net Income 1
CASH FLOW STATEMENT Net Income Depreciation & Amortization 2
Deferred Taxes Change in Working Capital Operating Cash Flow Existing Asset Capital Expenditures (including nuclear fuel)    3 Free Cash Flow Before Environmental Retrofit Program Environmental retrofit capital expenditures 4 Free Cash Flow Financial Statements represent a management reporting view and are consistent with projections 2 EFH Corp. files a consolidated federal income tax return, and therefore, Luminant Holding, Luminant, and Comanche Peak are disregarded entities for federal income tax purposes.
EFH Corp. deferred income taxes are allocated to Luminant Holding, Luminant, and Comanche Peak consistent with management reporting view Excludes environmental retrofit capital expenditures detailed below 4 Environmental retrofit capital expenditures related to upgrading emissions control equipment at existing Luminant Holdings coal units
 
Enclosure 1 (Non Proprietary)
Enclosure 1 (Non Proprietary)
TXX-12181 Page 5 of 6 Luminant Holdings$ millions, unless noted YTD Sept.2011 A 2012A INCOME STATEMENT' Revenues Fuel & Purchased Power Gross Margin Operations
TXX-12181 Page 6 of 6 Luminant Holdings
& Maintenance Expense General & Administrative Other Income / (Expense)EBITDA Depreciation
$ millions, unless noted YTD Sept.
& Amortization EBIT Interest Expense Interest Income & Special Projects EBT Tax Expense 2 Net Income CASH FLOW STATEMENT 1 Net Income Depreciation
2011 A   2012A COMPOSITION OF REVENUE PROJECTIONS Capacity (End of Year)
& Amortization Deferred Taxes 2 Change in Working Capital Operating Cash Flow Existing Asset Capital Expenditures (including nuclear fuel)Free Cash Flow Before Environmental Retrofit Program 3 Environmental retrofit capital expenditures 4 Free Cash Flow Financial Statements represent a management reporting view and are consistent with projections 2 EFH Corp. files a consolidated federal income tax return, and therefore, Luminant Holding, Luminant, and Comanche Peak are disregarded entities for federal income tax purposes.EFH Corp. deferred income taxes are allocated to Luminant Holding, Luminant, and Comanche Peak consistent with management reporting view Excludes environmental retrofit capital expenditures detailed below 4 Environmental retrofit capital expenditures related to upgrading emissions control equipment at existing Luminant Holdings coal units Enclosure 1 (Non Proprietary)
Coal - merchant                           [MW]
TXX-12181 Page 6 of 6 Luminant Holdings$ millions, unless noted YTD Sept.2011 A 2012A COMPOSITION OF REVENUE PROJECTIONS Capacity (End of Year)Coal -merchant [MW]Coal -contract [MW]Nuclear [MW]Total [MW]Production, net of auxilliary load Coal -merchant [TWh]Coal -contract [TWh]Nuclear [TWh]Total [TWh]Pricing Assumptions Settled gas price (HSC) [$ / MMBtu]Realized heat rate [MMBtu / MWh]Realized power price [$ / MWh]Commodity Exposure -Natural Gas Coal & nuclear plant exposure [Million MMBtu]Forward power sales (Alcoa) [Million MMBtu]Natural gas hedges allocated  
Coal - contract                           [MW]
[Million MMBtu]Net natural gas exposure [Million MMBtu]Sensitivity to +/- $1 move [$ MM]Commodity Exposure -Heat Rate Coal & nuclear plant exposure [TWh]Forward power sales [TWh]Net heat rate exposure [TWh]Sensitivity to +/- 0.25X HR change [$ MM]Revenue summary Coal & nuclear plant revenues [$ MM]Other deregulated revenues [$ MM]Regulated revenues [$ MM]Intercompany eliminations  
Nuclear                                   [MW]
[$ MM]Total [$ MM]}}
Total                               [MW]
Production, net of auxilliary load Coal - merchant                           [TWh]
Coal - contract                           [TWh]
Nuclear                                   [TWh]
Total                               [TWh]
Pricing Assumptions Settled gas price (HSC)               [$ / MMBtu]
Realized heat rate                 [MMBtu / MWh]
Realized power price                   [$ / MWh]
Commodity Exposure - Natural Gas Coal & nuclear plant exposure       [Million MMBtu]
Forward power sales (Alcoa)         [Million MMBtu]
Natural gas hedges allocated       [Million MMBtu]
Net natural gas exposure           [Million MMBtu]
Sensitivity to +/- $1 move             [$ MM]
Commodity Exposure - Heat Rate Coal & nuclear plant exposure             [TWh]
Forward power sales                     [TWh]
Net heat rate exposure                   [TWh]
Sensitivity to +/- 0.25X HR change       [$MM]
Revenue summary Coal & nuclear plant revenues           [$ MM]
Other deregulated revenues               [$ MM]
Regulated revenues                     [$ MM]
Intercompany eliminations               [$ MM]
Total                             [$ MM]}}

Latest revision as of 19:28, 11 November 2019

ISFSI, Additional Information Regarding Application for Order Approving Indirect and Internal Transfer of Licenses
ML12340A446
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 11/26/2012
From: Madden F, Flores R
Luminant Power, Luminant Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation, Office of Nuclear Material Safety and Safeguards
References
CP-201201424, TXX-12181, TAC ME9767, TAC ME9768
Download: ML12340A446 (11)


Text

ENCLOSURE 1 (PROPRIETARY) CONTAINS PROPRIETARY INFORMATION SUBMITTED UNDER 10 CFR 2.390 WITHHOLD FROM PUBLIC DISCLOSURE Rafael Flores Luminant Power Senior Vice President P 0 Box 1002 0 & Chief Nuclear Officer 6322 North FM 56 rafael.flores@Luminant.com Glen Rose, TX 76043 Lumminant T 254 897 5550 C 817 559 0403 F 254 897 6652 CP-201201424 10 CFR 50.80 TXX-12181 10 CFR 2.390 November 26, 2012 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Director, Office of Nuclear Reactor Regulation Washington, DC 20555

SUBJECT:

Comanche Peak Nuclear Power Plant (CPNPP) and Independent Spent Fuel Storage Installation (ISFSI), Docket Nos. 50-445, 50-446, 72-74 Additional Information Regarding Application for Order Approving Indirect and Internal Transfer of Licenses (CPNPP Unit 1 Operating License (NPF-87) and CPNPP Unit 2 Operating License (NPF-89)) (TAC NOS. ME9767 and ME9768)

REFERENCE:

1. Luminant Power Letter logged TXX-12149 from Rafael Flores to the NRC dated October 11, 2012, Application for Order Approving Indirect and Internal Transfer of Licenses (CPNPP Unit 1 Operating License (NPF-87) and CPNPP Unit 2 Operating License (NPF-89))

Dear Sir or Madam:

Luminant Generation Company LLC ("Luminant Power"), acting on behalf of Energy Future Holdings Corp. ("EFH"), Energy Future Competitive Holdings Company ("EFCH"), Texas Competitive Electric Holdings Company LLC, and Luminant Holding Company LLC, hereby submits additional information in connection with the indirect transfer of licenses requested in Reference 1.

As a result of discussions with the NRC staff on November 15, 2012, Luminant Power is providing historical financial information in Enclosure 1.

The requested information includes proprietary, separately bound Enclosure 1 (Proprietary), which contains confidential commercial or financial information. Luminant Power, EFH, EFCH, Texas Competitive Electric Holdings Company LLC, and Luminant Holding Company LLC request that Enclosure 1 (Proprietary) be withheld from public disclosure pursuant to 10 CFR 9.17(a)(4) and the policy reflected in 10 CFR 2.390(a)(4), as described in the Affidavit of Fred W. Madden, which is provided in Enclosure 1 to the Application. A non-proprietary version of Enclosure 1 (Non-Proprietary) suitable for public disclosure is provided in the Application.

A member of the STARS Alliance Callaway

  • Comanche Peak - Diablo Canyon
  • Palo Verde - San Onofre - South Texas Project
  • Wolf Creek

U.S. Nuclear Regulatory Commission TXX-12181 Page 2 of 2 If the NRC requires additional information concerning the enclosed application, please contact Fred Madden, Director Oversight and Regulatory Affairs, Luminant Power, tel: (224) 897-8601 and email:

Fred.Madden@luminant.com.

This letter contains no new licensing basis commitments regarding Comanche Peak Nuclear Power Plant Units 1 and 2.

Sincerely, Luminant Generation Company LLC Rafael Flores By:S~/2 T~~

Fred W. Madden Director, Oversight and Regulatory Affairs Affirmation Affidavit c - w/o proprietary Enclosure except * (paper copy)

E. J. Leeds, Director, Office of Nuclear Reactor Regulation E. E. Collins, Region IV

  • B. K. Singal, NRR Resident Inspectors, Comanche Peak

Affirmation TXX-12181 Page 1 Affirmation I, Fred W. Madden, being duly sworn, state that I am the Director, Oversight and Regulatory Affairs for Comanche Peak Nuclear Power Plant, Luminant Generation Company LLC

("Luminant Power"), that I am authorized to sign and file this Application with the Nuclear Regulatory Commission on behalf of Luminant Power and its affiliates, and that the statements made and the matters set forth herein pertaining to Luminant Power and its affiliates are true and correct to the best of my knowledge, information, and belief.

Luminant Generation Company LLC

/Fr'e W. Madden Director, Oversight and Regulatory Affairs STATE OF________

COUNTY OF Somer\/e II Subscribed and sworn to before me, a Notary Public, in and for the County and State above named, this 26th day of November 2012.

4 P. LOUISE PILOIAN DEBRA Notary Publir q*ts~t.

° 1l__:*

]

M T----.11F My Commission Expires: -7

Affidavit TXX-12181 Page 1 10 CFR 2.390 AFFIDAVIT OF FRED W. MADDEN I, Fred W. Madden, Director, Oversight and Regulatory Affairs state that:

1. I am authorized to execute this affidavit on behalf of Luminant Generation Company LLC ("Luminant Power") and its affiliates.
2. Luminant Power is providing information in support of its "Application for Order Approving Indirect Transfer of Licenses." The Proprietary Version of Enclosure 1 being provided in this submittal contain financial pro forma statements related to revenues from sales of energy and capacity from Comanche Peak Nuclear Power Plant (CPNPP) and confidential information regarding anticipated assets, liabilities and capital structure at the time of transfer. These documents constitute proprietary commercial and 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:
a. This information is and has been held in confidence by Luminant Power and its affiliates.
b. This information is of a type that is held in confidence by Luminant Power and its affiliates, and there is a rational basis for doing so because the information contains sensitive financial competitive information concerning Luminant Power affiliates' anticipated revenues and operating expenses.
c. This information is being transmitted to the NRC in confidence.
d. This information is not available in public sources and could not be gathered readily from other publicly available information.
e. Public disclosure of this information would create substantial harm to the competitive position of Luminant Power by disclosing its internal financial pro forma statements and the commercial terms of a unique transaction to other parties whose commercial interests may be adverse to those of Luminant Power.

Affidavit TXX-12181 Page 2

3. Accordingly, Luminant Power requests that the designated documents be withheld from public disclosure pursuant to the policy reflected in 10 CFR 2.390(a)(4) and 9.17(a)(4).

Luminant Generation Company LLC Fred W. Madden Director, Oversight and Regulatory Affairs STATE OF T k 5 COUNTY OF J oer di\

Subscribed and sworn to me, a Notary Public, in and for the County and State above named, this 26th day of November 2012.

I ,~*~ DEBRA LOUISE PILOIAN(1I My Commission Expires July 21, 2015 My Commission Expires: I7-At -\

Enclosure 1 (Non Proprietary)

TXX-12181 Page 1 of 6 Comanche Peak Units

$ millions, unless noted YTD Sept.

2011 A 2012A 1

INCOME STATEMENT Revenues Fuel & Purchased Power Gross Margin Operations & Maintenance Expense Luminant Allocated Overhead Property Taxes Other Income / (Expense)

EBITDA Depreciation &Amortization EBIT Interest Expense Interest Income & Special Projects EBT 2

Tax Expense Net Income Fixed O&M Expense Detail Base O&M Outage O&M Special Project O&M Total O&M 1

CASH FLOW STATEMENT Net Income Depreciation & Amortization 2

Deferred Taxes Change in Working Capital Operating Cash Flow Nuclear Fuel Capital Expenditures Other Existing Asset Capital Expenditures 3 Free Cash Flow Before Environmental Retrofit Program Environmental retrofit capital expenditures 4 Free Cash Flow 1 Financial Statements represent a management reporting view and are consistent with projections 2 EFH Corp. files a consolidated federal income tax return, and therefore, Luminant Holding, Luminant, and Comanche Peak are disregarded entities for federal income tax purposes.

EFH Corp. deferred income taxes are allocated to Luminant Holding, Luminant, and Comanche Peak consistent with management reporting view Excludes environmental retrofit capital expenditures detailed below 4 Environmental retrofit capital expenditures related to upgrading emissions control equipment at existing Luminant Holdings coal units

Enclosure 1 (Non Proprietary)

TXX-12181 Page 2 of 6 Comanche Peak Units

$ millions, unless noted YTD Sept.

2011 A 2012A COMPOSITION OF REVENUE PROJECTIONS Capacity (End of Year)

Coal - merchant [MW]

Coal - contract [MW]

Nuclear [MW]

Total [MW]

Nuclear Capacity Factor 1%]

Production, net of auxilliary load Coal - merchant [TWh]

Coal - contract [TWh]

Nuclear [TWh]

Total [TWh]

Pricing Assumptions Settled gas price (HSC) [$ / MMBtu]

Realized heat rate [MMBtu / MWh]

Realized power price [$/ MWh]

Commodity Exposure - Natural Gas Nuclear plant exposure [Million MMBtu]

Forward power sales (Alcoa) [Million MMBtu]

Natural gas hedges allocated [Million MMBtu]

Net natural gas exposure [Million MMBtu]

Sensitivity to +/- $1 move [$ MM]

Commodity Exposure - Heat Rate Nuclear plant exposure [TWh]

Forward power sales [TWh]

Net heat rate exposure [TWh]

Sensitivity to +/- 0.25X HR change [$ MM]

Revenue summary Nuclear plant revenues [$ MM]

Other deregulated revenues [$ MM]

Regulated revenues [$ MM]

Intercompany eliminations [$ MM]

Total [$ MM]

Enclosure 1 (Non Proprietary)

TXX-12181 Page 3 of 6 Luminant Power

$ millions, unless noted YTD Sept.

2011 A 2012A INCOME STATEMENT' Revenues Fuel & Purchased Power Gross Margin Operations & Maintenance Expense Luminant Allocated Overhead Property Taxes Other Income / (Expense)

EBITDA Depreciation & Amortization EBIT Interest Expense Interest Income & Special Projects EBT 2

Tax Expense Net Income CASH FLOW STATEMENT' Net income Depreciation & Amortization 2

Deferred Taxes Change in Working Capital Operating Cash Flow Existing Asset Capital Expenditures (including nuclear fuel) 3 Free Cash Flow Before Environmental Retrofit Program Environmental retrofit capital expenditures 4 Free Cash Flow Financial Statements represent a management reporting view and are consistent with projections 2 EFH Corp. files a consolidated federal income tax return, and therefore, Luminant Holding, Luminant, and Comanche Peak are disregarded entities for federal income tax purposes.

EFH Corp. deferred income taxes are allocated to Luminant Holding, Luminant, and Comanche Peak consistent with management reporting view Excludes environmental retrofit capital expenditures detailed below 4 Environmental retrofit capital expenditures related to upgrading emissions control equipment at existing Luminant Holdings coal units

Enclosure 1 (Non Proprietary)

TXX-12181 Page 4 of 6 Luminant Power

$ millions, unless noted Y-D Sept.

2011 A 2012A COMPOSITION OF REVENUE PROJECTIONS Capacity (End of Year)

Coal - merchant [MW]

Coal - contract [MW]

Nuclear [MW]

Total [MW]

Production, net of auxilliary load Coal - merchant [TWh]

Coal - contract [TWh]

Nuclear [TWh]

Total [TWh]

Pricing Assumptions Settled gas price (HSC) [$ / MMBtu]

Realized heat rate [MMBtu / MWh]

Realized power price [$ / MWh]

Commodity Exposure - Natural Gas Coal & nuclear plant exposure [Million MMBtu]

-Forward power sales (Alcoa) [Million MMBtu]

Natural gas hedges allocated [Million MMBtu]

Net natural gas exposure [Million MMBtu]

Sensitivity to +/- $1 move [$ MM]

Commodity Exposure - Heat Rate Coal & nuclear plant exposure [TWh]

Forward power sales [TWh]

Net heat rate exposure [TWh]

Sensitivity to +/- 0.25X HR change [$ MM]

Revenue summary Coal, gas & nuclear plant revenues [$ MM]

Other deregulated revenues [$ MM]

Regulated revenues [$ MM]

Intercompany eliminations [$ MM]

Total [$ MM]

Enclosure 1 (Non Proprietary)

TXX-12181 Page 5 of 6 Luminant Holdings

$ millions, unless noted YTD Sept.

2011 A 2012A INCOME STATEMENT' Revenues Fuel & Purchased Power Gross Margin Operations & Maintenance Expense General & Administrative Other Income / (Expense)

EBITDA Depreciation & Amortization EBIT Interest Expense Interest Income & Special Projects EBT 2

Tax Expense Net Income 1

CASH FLOW STATEMENT Net Income Depreciation & Amortization 2

Deferred Taxes Change in Working Capital Operating Cash Flow Existing Asset Capital Expenditures (including nuclear fuel) 3 Free Cash Flow Before Environmental Retrofit Program Environmental retrofit capital expenditures 4 Free Cash Flow Financial Statements represent a management reporting view and are consistent with projections 2 EFH Corp. files a consolidated federal income tax return, and therefore, Luminant Holding, Luminant, and Comanche Peak are disregarded entities for federal income tax purposes.

EFH Corp. deferred income taxes are allocated to Luminant Holding, Luminant, and Comanche Peak consistent with management reporting view Excludes environmental retrofit capital expenditures detailed below 4 Environmental retrofit capital expenditures related to upgrading emissions control equipment at existing Luminant Holdings coal units

Enclosure 1 (Non Proprietary)

TXX-12181 Page 6 of 6 Luminant Holdings

$ millions, unless noted YTD Sept.

2011 A 2012A COMPOSITION OF REVENUE PROJECTIONS Capacity (End of Year)

Coal - merchant [MW]

Coal - contract [MW]

Nuclear [MW]

Total [MW]

Production, net of auxilliary load Coal - merchant [TWh]

Coal - contract [TWh]

Nuclear [TWh]

Total [TWh]

Pricing Assumptions Settled gas price (HSC) [$ / MMBtu]

Realized heat rate [MMBtu / MWh]

Realized power price [$ / MWh]

Commodity Exposure - Natural Gas Coal & nuclear plant exposure [Million MMBtu]

Forward power sales (Alcoa) [Million MMBtu]

Natural gas hedges allocated [Million MMBtu]

Net natural gas exposure [Million MMBtu]

Sensitivity to +/- $1 move [$ MM]

Commodity Exposure - Heat Rate Coal & nuclear plant exposure [TWh]

Forward power sales [TWh]

Net heat rate exposure [TWh]

Sensitivity to +/- 0.25X HR change [$MM]

Revenue summary Coal & nuclear plant revenues [$ MM]

Other deregulated revenues [$ MM]

Regulated revenues [$ MM]

Intercompany eliminations [$ MM]

Total [$ MM]