ML14071A478

Response to Nrc'S Request for Cashflow Statements Regarding Application for Order Approving Transfer of Operating Authority and Conforming License Amendments

ML14071A478
Person / Time
Site:	Calvert Cliffs, Nine Mile Point, Ginna
Issue date:	02/21/2014
From:	Spina J Constellation Energy Group, EDF, Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML14071A478 (11)

Text

INCLUDES PROPRIETARY INFORMATION WITHHOLD UNDER 10 CFR 2.390 James A. Spina Office 410-470-5203 VP-Corporate Site Operations Fax 410-470-6305 E-mail: James.Spina@cengllc.com Exel On.

Generation CENG.

a joint venture of COr.. tanathem OEheWc 10 CFR 50.80 10 CFR 50.90 10 CFR 72.50 February 21, 2014 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 Docket Nos. 50-317 and 50-318 Calvert Cliffs Independent Spent Fuel Storage Installation Materials License No. SNM-2505 Docket No. 72-8 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 Docket Nos. 50-220 and 50-4 10 Nine Mile Point Nuclear Station, Independent Spent Fuel Storage Installation General License Docket No. 72-1036 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 Docket No. 50-244 R.E. Ginna Independent Spent Fuel Storage Installation General License Docket No. 72-67 Response to NRC's Request for Cashflow Statements Regarding Application for Order Approving Transfer of Operating Authority and Conforming License Amendments

REFERENCES:

(a) Email from N. S. Morgan (NRC) to E. M. Tyler (CENG), dated February 15, 2014, Additional Information Needed Constellation Energy Nuclear Group, LLC 100 Constellation Way, Suite 200C, Baltimore, MD 21202 UNRESTRICTED UPON REMOVAL OF ATTACHMENT 1A A ry

Document Control Desk February 21, 2014 Page 2 The purpose of this letter is to provide the operating cashflow statements for Constellation Energy Nuclear Group, LLC, Nine Mile Point Nuclear Station, LLC, Calvert Cliffs Nuclear Power Plant, LLC and R.E. Ginna Nuclear Power Plant, LLC requested in Reference (a). Attachment I contains a non-proprietary copy of the statements. Attachment IA is a proprietary copy to be withheld from public release. Attachment 2 is an affidavit supporting the proprietary nature of the information in Attachment IA.

This correspondence does not contain any regulatory commitments.

If there are any questions regarding this transmittal, please contact Bruce Montgomery, Manager, Nuclear Safety and Security, at (443)-532-6533.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February 21, 2014.

Sincerely, J es A. Spina JAS/EMT Attachments: (1) Projected Statements of Operating Cashflows (Non-Proprietary)

(1A) Projected Statements of Operating Cashflows (Proprietary)

(2) 10 CFR 2.390 Affidavit of James A. Spina

Document Control Desk February 21, 2014 Page 3 cc: (With Attachment 1A)

NRC Project Manager, Calvert Cliffs NRC Project Manager, Ginna NRC Project Manager, Nine Mile Point Regional Administrator, NRC Region I Susan Uttal, NRC Office of General Counsel Thomas Fredrichs, Senior Level Advisor for Financial Matters, NRR (Without Attachment 1A)

USNRC, Director, Office of Nuclear Reactor Regulation USNRC, Director, Office of Nuclear Material Safety and Safeguards NRC Resident Inspector - Calvert Cliffs NRC Resident Inspector- Nine Mile Point NRC Resident Inspector - R.E. Ginna S. Gray, Maryland DNR A. L. Peterson, NYSERDA B. Frymire, NYSDPS

ATTACHMENT (1)

PROJECTED STATEMENTS OF OPERATING CASHFLOWS (NON-PROPRIETARY)

Constellation Energy Nuclear Group, LLC February 21, 2014

ATTACHMENT (1)

PROJECTED STATEMENT OF OPERATING CASHFLOWS (NON- PROPRIETARY VERSION)

Combined Constellation Energy Nuclear Group Projected Statement of Operating Cash Flows (millions) 2014 2015 2016 2017 2018 Revenue PPA .$ $

Market Sales Revenues $ $ $ $ $

Operating Expenses Nuclear Fuel (Capital & DOE Disposal Fees) $ $ $ $ $

O&M, Non-Outage O&M, Refueling Outage O&M, Allocated Nuclear Corporate O&M, Integration Expenses O&M, ITTransition Expenses Property Taxes O&M, Allocated CEG HQ Costs Total Operating Expenses $ $ $ $ $

Capital Project Expenditures $ $ $ $ $

Decommissioning Trust Fund Investments $ $ $ $ $

Operating Cash Flows Before Income Taxes & Financing Activities $ $ $ $ $

See the Notes to the Projected Statement of Operating Cash Flows Page 1 of 5

ATTACHMENT (1)

PROJECTED STATEMENT OF OPERATING CASHFLOWS (NON-PROPRIETARY VERSION)

Nine Mile Point Projected Statement of Operating Cash Flows (millions) 2014 Z015 2016 Z017 2018 Revenue PPA $ $ $ $ $

Market Sales Revenues $ $ $ $ $

Operating Expenses Nuclear Fuel (Capital & DOE Disposal Fees) $ $ $ $ $

O&M, Non-Outage O&M, Refueling Outage O&M, Allocated Nuclear Corporate O&M, Integration Expenses O&M, IT Transition Expenses Property Taxes O&M, Allocated CEG HQ Costs Total Operating Expenses Capital Project Expenditures Decommissioning Trust Fund Investments Operating Cash Flows Before Income Taxes & Financing Activities See the Notes to the Projected Statement of Operating Cash Flows Page 2 of 5

ATTACHMENT (1)

PROJECTED STATEMENT OF OPERATING CASHFLOWS (NON-PROPRIETARY VERSION)

Calvert Cliffs Projected Statement of Operating Cash Flows (millions) 2014 2015 2016 2017 "018 Revenue PPA $ $ $ $ $

Market Sales Revenues $ $ $ $ $

Operating Expenses Nuclear Fuel (Capital & DOE Disposal Fees) $ $ $ $ $

O&M, Non-Outage O&M, Refueling Outage O&M, Allocated Nuclear Corporate O&M, Integration Expenses O&M, IT Transition Expenses Property Taxes O&M, Allocated CEG HQ Costs Total Operating Expenses $ $ $ $ $

Capital Project Expenditures $ $ $ $ $

Decommissioning Trust Fund Investments $ $ $ $ $

Operating Cash Flows Before Income Taxes & Financing Activities $ $ $ $ $

See the Notes to the Projected Statement of Operating Cash Flows Page 3 of 5

ATTACHMENT (1)

PROJECTED STATEMENT OF OPERATING CASHFLOWS (NON-PROPRIETARY VERSION)

Ginna Projected Statement of Operating Cash Flows (millions) 2014 2015 2016 2017 2018 Revenue PPA $ $ $ $ $

Market Sales Revenues $ $ $ $ $

Operating Expenses Nuclear Fuel (Capital & DOE Disposal Fees) $ $ $ $ $

O&M, Non-Outage O&M, Refueling Outage O&M, Allocated Nuclear Corporate O&M, Integration Expenses O&M, IT Transition Expenses Property Taxes O&M, Allocated CEG HQ Costs Total Operating Expenses $ $ $ $ $

Capital Project Expenditures $ $ $ $ $

Decommissioning Trust Fund Investments $ $ $ $ $

Operating Cash Flows Before Income Taxes & Financing Activities $ $ $ $ $

See the Notes to the Projected Statement of Operating Cash Flows Page 4 of 5

ATTACHMENT (1)

PROJECTED STATEMENTS OF OPERATING CASHFLOWS (NON-PROPRIETARY VERSION)

Notes to the Projected Statement of Operating Cash Flows

1. The Combined Constellation Energy Nuclear Group (CENG) Projected Statement of Operating Cash Flows represents the summation of the three nuclear stations' projected statement of operating cash flows, presented under the combined assumptions of each individual nuclear station. The projected statements of operating cash flows for CENG and CENG sites do not include income taxes or financing activities.

2. Site financial projections are based on CENG's 5 year strategic plan for the period 2014 - 2018 adjusted to reflect the impacts associated with the planned integration of CENG's nuclear plants into ExGen's nuclear fleet and ExGen's market price forecast.

3. PPA revenue includes Legacy PPA agreements (Ginna only) and Unit Contingent hedges (with ExGen and EDF Trading).

4. CENG corporate overhead costs were allocated to the CENG sites based on the INPO method.

5. CENG corporate overhead costs include infrastructure and corporate governance expenses.

6. The integration of CENG's nuclear plants into ExGen's nuclear fleet is projected to result in integration cost savings of $[ ] million in 2014 and $[ ] million per year in 2015 - 2018. Integration cost savings expected to be realized at the plant sites are reflected in O&M, Non-Outage Expense, and integration cost savings expected to be realized at corporate are reflected in O&M, Allocated Nuclear Corporate Expense.

7. Projected costs to achieve of $[ ] million relating to the integration of CENG's nuclear plants into ExGen's nuclear fleet were allocated to the CENG sites based on the INPO method and are shown as the separate line item "Integration Expense" (previously included in "O&M, Allocated Nuclear Corporate") (Notes accompanying the previous Site financial projections submitted with the Letter from CENG dated August 6, 2013 (ML13232A156 and ML13232A157) indicated integration costs of $[ ]

million; however, integration costs of $[ ] million were reflected in the financial projections).

8. IT transition costs were allocated to the CENG sites based on the INPO method and are shown as the separate line item "IT Transition Costs" (previously included in "O&M, Allocated Nuclear Corporate Expense").

9. CENG corporate overhead costs includes integration transition costs of $[ ] million.

10. O&M, Non-Outage and O&M, Allocated Nuclear Corporate reflect projected cash pension contributions (versus pension expense reflected in the Projected Income Statements previously submitted to the NRC). For the 5 year period 2014 - 2018, O&M, Non-Outage includes cash pension contributions of $[ ] million versus pension expense of $[ ] million and O&M, Allocated Nuclear Corporate includes cash pension contributions of $[ ] million versus pension expense of $[ ] million.

11. Nuclear fuel capital expenditures represent cash outflows for fabrication and capital batch costs for uranium, conversion and enrichment that are managed centrally in a fleet inventory pool and transferred to the site in the year the reload is conducted. Financial projections are from CENG's 5 year strategic plan for the period 2014 - 2018.

12. In addition to the O&M cost savings described in Note 6 above, the integration of CENG's nuclear plants into Exelon Generation's nuclear fleet is projected to result in annual capital savings for the CENG Sites of $[ ] million in 2015, $[ ] million in 2016 and 2017, and $[ ] million in 2018. Capital savings projected to be realized at each Site are reflected in Capital Project Expenditures.

Page 5 of 5

ATTACHMENT (2) 10 CFR 2.390 AFFIDAVIT OF JAMES A. SPINA Constellation Energy Nuclear Group, LLC February 21, 2014

AFFIDAVIT UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

Constellation Energy Nuclear Group, LLC, et al. )

AFFIDAVIT I, James A. Spina, VP-Corporate Site Operations of Constellation Energy Nuclear Group, LLC (CENG) do hereby affirm and state:

1. I am authorized to execute this affidavit on behalf of the Licensees.

2. CENG is providing information on behalf of itself and the other Applicants in support of their application for an Order approving license transfers. The documents being provided in Attachment IA contain proprietary financial information and financial projections related to the ownership and operation of the Licensees' generation assets. 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:

i. This information is and has been held in confidence by the Applicants.

ii. This information is of a type that is customarily held in confidence by the Applicants, and there is a rational basis for doing so because the information contains sensitive financial information concerning projected revenues and operating expenses of the Licensees.

iii. This information is being transmitted to the NRC voluntarily and 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 the Applicants by disclosing their internal financial projections.

3. Accordingly, the Applicants request 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).

James .A.Spina Subspnibed and sworn before mia Notary Public, in and otrthe State of Maryland and City of

ýý6his,2/ day of A., 2014.

WITNESS my hand and Notarial Seal: " .

Nota ry ubiic" i My Commission Expires: /"/*"*

Date I of I