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MONTHYEARML20323A0182020-11-18018 November 2020 Corrected Final Scenarios 1 2 3. (Folder 3) ML20177A4932020-06-25025 June 2020 Enclosure a - Redacted Owners, Officers, Directors, and Executive Personnel Forms for Energy Harbor Corp., Energy Harbor Nuclear Corp., and Energy Harbor Nuclear Generation LLC L-20-191, Energy Harbor - Enclosed May 2020 NPDES Discharge Monitoring Report, Beaver Valley Power Station & Supplemental Monitoring Data for Outfall 001 (Dissolved Oxygen)2020-06-24024 June 2020 Energy Harbor - Enclosed May 2020 NPDES Discharge Monitoring Report, Beaver Valley Power Station & Supplemental Monitoring Data for Outfall 001 (Dissolved Oxygen) ML20140A3352020-04-22022 April 2020 Steam Generator Tube Inspection Discussion Points for April 22, 2020, Teleconference with Energy Harbor Nuclear Corp. and NRC ML20008D2232020-01-0808 January 2020 NRC Region I Twitter Feeds 10-1 to 12-31-2019 ML18058A9532018-02-27027 February 2018 Comments on BVPS SE ML18058A9852018-02-27027 February 2018 BVPS-1 License Condition Page ML17305A1942017-10-23023 October 2017 Perry Nuclear Power Plant Revision 20 to Updated Final Safety Analysis Report, Master Table of Contents ML16285A1302016-06-0202 June 2016 ROP PI Frequently Asked Questions (FAQs):12-04 L-16-092, Information Pertaining to Foreign Ownership, Control, or Influence. Part 4 of 62016-04-22022 April 2016 Information Pertaining to Foreign Ownership, Control, or Influence. Part 4 of 6 ML16132A3932016-04-22022 April 2016 Davis-Besse, and Perry - Information Pertaining to Foreign Ownership, Control, or Influence. Part 2 of 6 ML16132A3942016-04-22022 April 2016 Davis-Besse, and Perry - Information Pertaining to Foreign Ownership, Control, or Influence. Part 3 of 6 ML16132A3962016-04-22022 April 2016 Information Pertaining to Foreign Ownership, Control, or Influence. Part 5 of 6 ML16102A4462016-04-0505 April 2016 E-Mail: Perry Nuclear Power Plant - Supplemental Request for Information to NRC Letter Dated February 2, 2016 (AAS) ML16090A2312016-03-21021 March 2016 Aam Open House, Sign-in Sheets, March 21, 2016 ML15104A6922015-04-0909 April 2015 Aam Attendance List, April 9 2015 ML14098A2132014-04-0303 April 2014 Aam 2014, Sign-in Sheet ML13364A2832013-12-30030 December 2013 Announcement of 2014 Generic Fundamentals Examination Administration Dates-Letter Dated Dec 30, 2013 L-14-147, ODCM: Index, Matrix and History of ODCM Changes2013-03-20020 March 2013 ODCM: Index, Matrix and History of ODCM Changes ML12230A2312012-08-15015 August 2012 Attachment 2 - L-12-287, Response to NRC Request for Additional Information Regarding 10 CFR 50.46, 30-Day Report ML12164A7992012-06-11011 June 2012 Attachment 2 to L-12-184, Response to NRC Request for Additional Information Regarding 10 CFR 50.46, 30-Day Report (Non-proprietary Version) ML12056A0522012-03-12012 March 2012 Enclosure 6 - List of Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status ML1132203552011-11-21021 November 2011 2010 DFS Report Analysis for Perry Nuclear Power Plant - Supercedes ML1127100332011-09-28028 September 2011 ROP Tabletop Examples and Results ML1117502192011-06-22022 June 2011 NRC Inspection Findings Related to Closed Cooling Water Systems (1/1/2004 to 6/22/2011) L-05-080, Exhibit D (Part 4): Excerpt from the Beaver Valley and Perry 2005 License Transfer Application2011-06-13013 June 2011 Exhibit D (Part 4): Excerpt from the Beaver Valley and Perry 2005 License Transfer Application ML1112305642011-04-28028 April 2011 Aam Attendance List, April 28, 2011 ML1106207252011-03-0303 March 2011 ISI Notification of Inspection and Request for Information ML1013303522010-05-13013 May 2010 Attendance Signing Sheet for Annual Assessment Meeting 5-4-2010 ML1009103152010-03-31031 March 2010 Sign-in Sheet for FENOC Meeting 3-31-10 ML1019304602010-03-25025 March 2010 List of Historical Leaks and Spills at Us Commercial Nuclear Power Plants ML0929305002009-10-24024 October 2009 Response to Citizen Power Issues ML0911008852009-04-15015 April 2009 Independent Spent Fuel Storage Installation Inspection Document Request ML0909202522009-03-31031 March 2009 Public Meeting Sign-in Sheet, 3/31/2009 L-09-028, Response to Request for Additional Information the 2008 Steam Generator Tube Inspection Report2009-02-20020 February 2009 Response to Request for Additional Information the 2008 Steam Generator Tube Inspection Report L-08-229, Responses to a Request for Additional Information in Support of License Amendment Request No. 07-0052008-08-0101 August 2008 Responses to a Request for Additional Information in Support of License Amendment Request No. 07-005 ML0808801572008-03-25025 March 2008 Beaver Valley Annual Assessment, Sign-in Sheets ML0804603992008-02-13013 February 2008 Power Reactor Inattentive Officer Findings 2004-Present ML0735202772007-12-17017 December 2007 Ohio Natural Heritage Data Request for Beaver Valley Power Station License Renewal ML0732400242007-10-25025 October 2007 Examples of Max Thermal Power License Conditions ML0726705012007-09-18018 September 2007 EPU I&C Questions ML0726303192007-09-14014 September 2007 P. Paquin Ltr Amendment to Certificate of Compliance No. 6574 for the Model No. 3-82B Package (TAC L24116)/ Register User List ML0726301142007-09-14014 September 2007 / P. Paquin Ltr Amendment to Certificate of Compliance No. 9208 for the Model No. 10-142B Package (TAC L24117)/S121170 ML0712307312007-04-25025 April 2007 Attendance Roster from Annual Assessment Public Meeting ML0634705992006-12-14014 December 2006 Plant Service List ML0626503122006-09-0101 September 2006 Liquid Radiation Release Lessons Learned Task Force Final Report (Enclosure) ML0611603672006-04-25025 April 2006 Fenco Security Working Hours and Fatigue; Procedure No. NOP-LP-1005, Rev 0 ML0535402882005-12-16016 December 2005 Issuance of Conforming Amendments for Bv, Units 1 and 2; Perry, Unit 1 and Davis-Besse, Unit 1 Transfer of Ownership Interests to Fengenco - Amendment No. 13 to Indemnity Agreement B73 ML0611605532005-03-24024 March 2005 NRC Inspection Report 2005-004 Meeting Attendees ML0611604822005-03-22022 March 2005 NRC Inspection Report 2005-04 Meeting Attendees 2020-06-25
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Enclosure 1 L-05-080 PY-CELINRR-2880L Page 13 Accordingly, the use of a dual unit outage of both BVPS units for one year as a benchmark for the funding agreement is an appropriate assumption for purposes of meeting the criteria in the Standard Review Plan. Finally, the remaining affiliate owners of the BVPS and Perry units remain responsible to provide their pro rata shares of capital and operating costs in the event of any such shutdown.G. Decommissioning Funding At the time of the transfer, all of the decommissioning funds in Penn Power's Nuclear Decommissioning Trusts ("NDTs") will be transferred to FENGenCo.
These NDTs had a market value of approximately
$143 million as of December 31, 2004, and additional contributions are planned for 2005. Therefore, FENOC expects that the market value of the NDTs will be at least $140 million at the time of the transfer.
The FENGenCo NDTs will be held in external trust funds segregated from FENGenCo's assets and outside its administrative control. The funds will be governed by a Master NDT Agreement with Mellon Bank NA as Trustee, and the terms of that agreement will comply with the requirements of 10 CFR 50.75(h)(1).
A form of the "Master Nuclear Decommissioning Trust Agreement" incorporating the terms required by 10 CFR 50.75(h)(1) is provided as Exhibit J.The NRC minimum amounts of decommissioning funding assurance required for BVPS and Perry, calculated pursuant to 10 CFR 50.75(c) (the "formula amount"), are provided for each unit in Exhibit K, Attachments 1, 2, and 3. The current trust fund balances and anticipated contributions for 2005, with credit for earnings taken into account using a 2 percent real rate of return, are insufficient to be considered fully "prepaid" for purposes of using the "prepayment" method specified in 10 CFR 50.75(e)(1)(i).
Enclosure 1 L-05-080 PY-CEI/NRR-2880L Page 14 Below is a table summarizing for each plant the current: (1) Penn Power's ownership interest (being transferred to FENGenCo);
(2) the current Penn Power trust fund balance (being transferred to FENGenCo);
(3) the current shortfall; (4) the amount required (when earnings are credited using a 2% real rate of return) to be considered fully "prepaid;" and (5) FENGenCo's pro rata share of the NRC minimum decommissioning amount.Decommissioning Funding Summary ($in million)Penn Trust Balance Current Pre-Paid Amount FENGenCo Power's (12/31/2004)
Shortfall Required Share of NRC Plant (Credit for Earnings)
Min.Share BVPS 1 65% $108.1 $66.8 $174.9 $231.9 BVPS 2 13.74% $25.3 $4.5 $29.8 $49.0 Perry 5.24% $9.7 $5.5 $15.2 $24.3 Total $143.1 $76.8 $219.9 $305.2 The transferred balances of approximately
$140 million are approximately
$80 million less than the $220 million required to be considered fully pre-paid.
Therefore, FENGenCo will provide additional decommissioning funding assurance by obtaining a parent guarantee, as -permitted by 10 CFR 50.75(e)(1)(iii), from FirstEnergy in the initial amount of $80 million (in year 2005 dollars).
FENGenCo will re-calculate the required decommissioning funding assurance levels each year, as required by 10 CFR 50.75(b)(2), and if necessary, each year it will either obtain an appropriate adjustment in the amount of the parent company guarantee or otherwise provide for decommissioning funding assurance in the amounts required.
Exhibit L provides a worksheet demonstrating compliance with the NRC's financial test for parent guarantees, in accordance with 10 CFR 50.75(e)(1)(iii)(C) and 10 CFR Part 30, Appendix A.
Enclosure 1 L-05-080 PY-CEI/NRR-2880L Page 15 FENGenCo has chosen to demonstrate compliance using the test in section II.A.2 of Appendix A. The form of the guarantee is provided as Exhibit M.In addition, FENGenCo expects to receive additional funding for decommissioning in the amount of $80 million from Penn Power and/or other affiliates within the next five years.FENGenCo will maintain these funds in its NDTs. In any event, the existing trust funds combined with the parent company guarantee in the amount of $80 million provide reasonable assurance that funds will be available to FENGenCo to pay for its share of the decommissioning costs attributable to the interests being transferred to it, in accordance with the requirements of 10 CFR 50.75. This provides the required financial assurance for the funding of FENGenCo's decommissioning obligations in connection with the transferred plant interests.
It is expected that when FENGenCo's NDTs have achieved higher funding levels, from funds made available by Penn Power and other sources, as well as earnings and appreciation from NDT investments, the parent company guarantee will be reduced to a lower amount or eliminated, as appropriate.
H. No Antitrust Considerations In accordance with the Commission's decision in Kansas Gas and Electric Company (Wolf Creek Generating Station, Unit 1), CLI-99-19, 49 N.R.C. 441 (1999), antitrust reviews of license transfer applications after initial licensing are not required by the AEA. The existing antitrust conditions in the licenses will continue in effect.I. Nuclear Insurance In accordance with Art. IV.2 of the NRC Price-Anderson Indemnity Agreement for BVPS and Perry, the Applicant requests NRC approval of the assignment and transfer of Penn Power's