ML12354A058

Comanche Peak Nuclear Power Plant, Unit 1 & 2, Independent Spent Fuel Storage Installation, Additional Information Regarding Application for Order Approving Indirect and Internal Transfer

ML12354A058
Person / Time
Site:	Comanche Peak
Issue date:	12/05/2012
From:	Flores R, Madden F W Luminant Generation Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
CP-201201456, TAC ME9767, TAC ME9768, TXX-12184
Download: ML12354A058 (8)

Text

ENCLOSURE 1 (PROPRIETARY) CONTAINS PROPRIETARY INFORMATION SUBMITTED UNDER 10 CFR 2.390WITHHOLD FROM PUBLIC DISCLOSURERafael Flores Luminant PowerSenior Vice President P 0 Box 1002& Chief Nuclear Officer 6322 North FM 56rafael.flores@Luminant.com Glen Rose, TX 76043LuminantT 254 897 5550C 817 559 0403F 254 897 6652CP-201201456 10 CFR 50.80TXX-12184 10 CFR 72.50(a)10 CFR 2.390December 5, 2012U.S. Nuclear Regulatory CommissionAttention: Document Control DeskDirector, Office of Nuclear Reactor RegulationWashington, DC 20555

SUBJECT:

Comanche Peak Nuclear Power Plant (CPNPP) and Independent Spent Fuel StorageInstallation (ISFSI), Docket Nos. 50-445, 50-446, 72-74Additional Information Regarding Application for Order Approving Indirect andInternal Transfer of Licenses (CPNPP Unit 1 Operating License (NPF-87) andCPNPP Unit 2 Operating License (NPF-89), and General License under Docket Number72-74) (TAC NOS. ME9767 and ME9768)REFERENCE:1. Luminant Power Letter logged TXX-12149 from Rafael Flores to the NRC datedOctober 11, 2012, Application for Order Approving Indirect and Internal Transfer ofLicenses (CPNPP Unit 1 Operating License (NPF-87), CPNPP Unit 2 OperatingLicense (NPF-89)2. Luminant Power Letter logged TXX-12161 from Rafael Flores to the NRC datedOctober 24, 2012, Additional Information Regarding Application for Order ApprovingIndirect and Internal Transfer of Licenses (CPNPP Unit 1 Operating License (NPF-87),CPNPP Unit 2 Operating License (NPF-89)3. Luminant Power Letter logged TXX-12181 from Rafael Flores to the NRC datedNovember 26, 2012, Additional Information Regarding Application for OrderApproving Indirect and Internal Transfer of Licenses (CPNPP Unit 1 OperatingLicense (NPF-87), CPNPP Unit 2 Operating License (NPF-89)

Dear Sir or Madam:

Luminant Generation Company LLC ("Luminrant Power"), acting on behalf of Energy Future HoldingsCorp. ("EFH"), Energy Future Competitive Holdings Company ("EFCH"), Texas Competitive ElectricHoldings Company LLC, and Luminant Holding Company LLC, hereby submits additional informationin connection with the indirect transfer of licenses requested in Reference 1.Section III.J of Enclosure 1 Application of Reference 1, noted "The proposed transaction does not affectthe Independent Spent Fuel Storage Installation (ISFSI) general license issued for the storage of spent fuelat CPNPP pursuant to Subpart K of 10 CFR 50.72." The last part of this sentence should reference "10CFR 72" not "10 CFR 50.72." Additionally, Luminant Power notes that the project costs for the CPNPPA member of the STARS AllianceCallaway .Comanche Peak

• Diablo Canyon

• Palo Verde -San Onofre

• South Texas Project

• Wolf CreekAd"~

U.S. Nuclear Regulatory CommissionTXX-12184Page 2 of 312/05/2012ISFSI that are incurred by Luminant Power are accounted for in both the historical (Enclosure 1(Proprietary) to Reference 3) and projected (Enclosure 1 Addendum Exhibit D (Proprietary) to Reference1) financial information documents.A relatively small amount of the CPNPP ISFSI costs (less than 1%) are considered operations andmaintenance expenses in the forecast period, and these CPNPP ISFSI costs are included in the"Operations & Maintenance Expense" line items in the projections for the Comanche Peak Unitsprovided in Enclosure 1 Addendum Exhibit D (Proprietary) of Reference 1. The vast majority of theCPNPP ISFSI costs is considered capital expenditures, and therefore is not included as "Operations &Maintenance Expense" in the income statements. The net cash costs of the ISFSI costs are included in the"Other Existing Asset Capital Expenditures" in the Cash Flow Statement of the projections. Moreover, themajority of these CPNPP ISFSI capital expenditures are being recovered each year from the U.S.Department of Energy pursuant a settlement of claims for damages in connection with the "Contract forDisposal of Spent Nuclear Fuel and/or High-level Radioactive Waste" for CPNPP. Due to the expectedreimbursement of the majority of these capital expenses, they are not forecast to have a material impacton Luninant Power's Consolidated Balance Sheet, which is provided in Enclosure 1 Addendum ExhibitD (Proprietary) of Reference 1. In summary, the CPNPP ISFSI costs, both O&M and capital, areaccounted for in the financial projections, but they have very little actual impact on the projections.Luminant Power's last biennial 50.75(f) report (Accession number ML110960274) and an update to thatreport (Reference 2) provides information regarding the Site Specific Cost Estimate for thedecommissioning of CPNPP, and this estimate includes costs associated with the decommissioning of theCPNPP ISFSI.Luminant Power is providing updated historical and projected financial information in Enclosure 1 toclarify revenues provided in References 1 and 3. Enclosure 1 provides additional backgroundinformation regarding certain revenues that result from activities other than nuclear and non-nuclearelectric power generation.The requested information includes proprietary, separately bound Enclosure 1 Exhibit A (Proprietary),which contains confidential commercial or financial information. Luminant Power, EFH, EFCH, TexasCompetitive Electric Holdings Company LLC, and Luminant Holding Company LLC request thatEnclosure 1 (Proprietary) be withheld from public disclosure pursuant to 10 CFR 9.17(a)(4) and the policyreflected in 10 CFR 2.390(a)(4), as described in the Affidavit of Fred W. Madden, which is provided inEnclosure 1 to the Application. A non-proprietary version of Enclosure 1 (Non-Proprietary) suitable forpublic disclosure is provided in the Application.If the NRC requires additional information concerning this license transfer, please contact Fred Madden,Director Oversight and Regulatory Affairs, Luminant Power, tel: (254) 897-8601 and email:Fred.Madden@luminant.com.

U.S. Nuclear Regulatory CommissionTXX-12184Page 3 of 312/05/2012This letter contains no new licensing basis commitments regarding Comanche Peak Nuclear Power PlantUnits 1 and 2.Sincerely,Luminant Generation Company LLCRafael FloresFred W. MaddenDirector, Oversight and Regulatory AffairsAffirmationAffidavitEnclosure 1c -w/o proprietary Enclosure 1 except * (paper copy)E. J. Leeds, Director, Office of Nuclear Reactor RegulationE. E. Collins, Region IV* B. K. Singal, NRRResident Inspectors, Comanche Peak Affirmation to TXX-12184Page 1 of 1AffirmationI, Fred W. Madden, being duly sworn, state that I am the Director, Oversight and RegulatoryAffairs for Comanche Peak Nuclear Power Plant, Luminant Generation Company LLC("Luminant Power"), that I am authorized to sign and file this Application with the NuclearRegulatory Commission on behalf of Luminant Power and its affiliates, and that the statementsmade and the matters set forth herein pertaining to Luminant Power and its affiliates are true andcorrect to the best of my knowledge, information, and belief.Luminant Generation Company LLCred .MaddenDirector, Oversight and Regulatory AffairsSTATECOUNTYSubscribed and sworn to before me, a Notary Public, in and for the and S ate abovenamed, this 5th day of December 2012.JANICE STOKESMY COMMISSION Ii M Co ission Expires:FEBRUARY 19, 2013 I Affidavit to TXX- 12184TXX-12184Page 1 of 210 CFR 2.390AFFIDAVIT OF FRED W. MADDENI, Fred W. Madden, Director, Oversight and Regulatory Affairs state that:1. I am authorized to execute this affidavit on behalf of Luminant Generation CompanyLLC ("Luminant Power") and its affiliates.2. Luminant Power is providing information in support of its "Application for OrderApproving Indirect Transfer of Licenses." The Proprietary Version of Enclosure 1 beingprovided in this submittal contain financial pro forma statements related to revenues fromsales of energy and capacity from Comanche Peak Nuclear Power Plant (CPNPP) andconfidential information regarding anticipated assets, liabilities and capital structure atthe time of transfer. These documents constitute proprietary commercial and financialinformation that should be held in confidence by the NRC pursuant to the policy reflectedin 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 itsaffiliates.b. This information is of a type that is held in confidence by Luminant Power and itsaffiliates, and there is a rational basis for doing so because the informationcontains sensitive financial competitive information concerning Luminant Poweraffiliates' 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 gatheredreadily from other publicly available information.e. Public disclosure of this information would create substantial harm to thecompetitive position of Luminant Power by disclosing its internal financial proforma statements and the commercial terms of a unique transaction to otherparties whose commercial interests may be adverse to those of Luminant Power.

Affidavit to TXX-12184TXX-12184Page 2 of 23. Accordingly, Luminant Power requests that the designated documents be withheld frompublic disclosure pursuant to the policy reflected in 10 CFR 2.390(a)(4) and 9.17(a)(4).Luminant Generation Company LLCe/Pi~d W. Madden'Director, Oversight and Regulatory AffairsSCTAT OFUNTCOUNTYSubscribed and sworn to me, a Notary Public, in and for the County and State5th day of December 2012.JANICE S KES ission"y COMANSSIONj EXPiRESFEBRU&J~y 19. 2013 (Non-Proprietary)TXX-12184Page 1 of 2Page 8 -Luminant Power: Base CaseOther deregulated revenue included in the table below bridges the Revenue Summary on p. 8 with the Income Statement Revenues shown on p. 7of document TXX-12149 Enclosure 1 Addendum Exhibit D (Proprietary)COMPOSITION OF REVENUE PROJECTIONS 2013 E 2014 E 2015 E 2016 E 2017 ERevenue summaryOther deregulated revenues[$ MM]Page 10 -Luminant Holding: Base CaseOther deregulated revenue and hedge revenue included in the table below bridges the Revenue Summary on p. 10 with the Income StatementRevenues shown on p. 9 of document TXX-12149 Enclosure 1 Addendum Exhibit D (Proprietary)COMPOSITION OF REVENUE PROJECTIONS 2013 E 2014 E 2015 E 2016 E 2017 ERevenue summaryOther deregulated revenues [$ MM]Hedge revenue [$ MM]Page 15 -Luminant Power: Capacity Factor CaseOther deregulated revenue included in the table below bridges the Revenue Summary on p. 15 with the Income Statement Revenues shown on p. 14of document TXX-12149 Enclosure 1 Addendum Exhibit D (Proprietary)COMPOSITION OF REVENUE PROJECTIONS 2013 E 2014 E 2015 E 2016 E 2017 ERevenue summaryOther deregulated revenues [$ MM]Page 17 -Luminant Holding: Capacity Factor CaseOther deregulated revenue and hedge revenue included in the table below bridges the Revenue Summary on p. 17 with the Income StatementRevenues shown on p. 16 of document TXX-12149 Enclosure 1 Addendum Exhibit D (Proprietary)COMPOSITION OF REVENUE PROJECTIONS 2013 E 2014 E 2015 E 2016 E 2017 ERevenue summaryOther deregulated revenues [$ MM]Hedge revenue [$ MM]Page 22 -Luminant Power: Power Price CaseOther deregulated revenue included in the table below bridges the Revenue Summary on p. 22 with the Income Statement Revenues shown on p. 21of document TXX-12149 Enclosure 1 Addendum Exhibit D (Proprietary)COMPOSITION OF REVENUE PROJECTIONS 2013 E 2014 E 2015 E 2016 E 2017 ERevenue summaryOther deregulated revenues [$ MM]Page 24 -Luminant Holding: Power Price CaseOther deregulated revenue and hedge revenue included in the table below bridges the Revenue Summary on p. 24 with the Income StatementRevenues shown on p. 23 of document TXX-12149 Enclosure 1 Addendum Exhibit D (Proprietary)COMPOSITION OF REVENUE PROJECTIONS 2013 E 2014 E 2015 ERevenue summary2016 E 2017 EOther deregulated revenuesHedge revenue[$ MM][$ MM] (Non-Proprietary)TXX-12184Page 2 of 2Page 4 -Luminant PowerOther deregulated revenue included in the table below bridges the Revenue Summary on p. 4 with theIncome Statement Revenues shown on p. 3 of document TXX-12181 Enclosure 1 (Proprietary)YTD Sept.COMPOSITION OF REVENUE PROJECTIONS 2011 A 2012ARevenue summaryOther deregulated revenues [$ MM]Page 6 -Luminant HoldingOther deregulated revenue and hedge revenue included in the table below bridges the Revenue Summaryon p. 6 with the Income Statement Revenues shown on p. 5 of document TXX-12181 Enclosure 1 (Proprietary)YTD Sept.COMPOSITION OF REVENUE PROJECTIONS 2011 A 2012ARevenue summaryOther deregulated revenues [$ MM]Hedge revenue [$ MM]