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ISFSI - Financial Test for Decommissioning Funding Parent Guarantees for the Year Ending December 31, 2015, Per 10 CFR Part 30 App. a
	ML16091A389
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	03/30/2016
From:	Mccann J; Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
	ENOC-16-00007
	Download: ML16091A389 (12)
	v • d • e

Entergy Nuclear Operations, Inc 1340 Echeclon Parkway Jackson, MS 39213 Tel 601-368-5667 John F. McCann Vice President - Regulatory Assurance ENOC-16-00007 March 30, 2016 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Financial Test for Decommissioning Funding Parent Guarantees for the year ending December 31, 2015 per 10 CFR Part 30 App. A Big Rock Point ISFSI Docket Nos. 50-155 / 72-043 License No. DPR-6

Dear Sir or Madam:

This letter provides the documents to support the continued use of a parent company guarantee to provide financial assurance of decommissioning funds for the Big Rock Point Independent Spent Fuel Storage Installation (ISFSI), pursuant to 10 CFR 50.75(e)(1)(iii)(B).

The licensee requested that Entergy Corporations independent certified public accountant, Deloitte & Touche, LLP, evaluate the companys off-balance sheet transactions and provide an opinion on whether those transactions could materially adversely affect the companys ability to pay for decommissioning costs, as required by 10 CFR 30 Appendix A. Deloitte & Touche, LLP stated that it does not provide opinions of that nature. Nevertheless, Entergy Corporations management has concluded that the amount of decommissioning-related parent guarantees at issue is very small as compared to the balance sheet amounts, and in its opinion, off-balance sheet transactions would not be expected to affect the companys ability to pay for decommissioning costs. The companys off-balance sheet transactions are described in its Securities and Exchange Commission filings, in particular, its 10-Q and 10-K filings.

Entergy Corporation previously had provided a $40 million guarantee in support of Vermont Yankee decommissioning financial assurance. Because the $40 million guarantee for Entergy Nuclear Vermont Yankee, LLC, is no longer needed for financial assurance, by letter dated December 19, 2014, Entergy Corporation gave notice that it was canceling the $40 million guarantee effective 120 days after receipt of the notice by the NRC and Entergy Nuclear Vermont Yankee, LLC (Accession No. ML14358A252). In a letter from the NRC to Entergy Nuclear Operations, Inc, and Vermont Yankee Nuclear Power Station dated April 21, 2015, the NRC determined that Entergy Corporation had complied with the general requirements of 10 CFR 30 Appendix A (III)(A) and granted Entergy Corporation the right to cancel the $40 million

ENOC-16-00007 Page 2 of 6 parent company guarantee for Vermont Yankee (Accession No. ML15107A074). The Vermont Yankee parent company guarantee has been cancelled.

There are no new commitments made in this letter. If you have any questions, please contact Mr. Guy Davant, Manager, Fleet Licensing Programs, 601-368-5756.

Sincerely, JFM / ghd / ljs Attachments: 1. Entergy Corporation Parent Guarantee for Fiscal Year Ending 12/31/2015

2. Independent Accountants Report on Applying Agreed-Upon Procedures cc:

Mr. J. A. Aluise (ENT)

Mr. C. Bakken (ECH)

Mr. B. E. Green (TMBR)

Mr. D. J. Mannai (WPO)

Mr. T. G. Mitchell (ECH)

Mr. L. Jager Smith (ECH)

Mr. C. J. Wamser (VTY)

Mr. A. J. Vitale (PAL)

Mr. J. A. Ventosa (ECH)

Mr. T. Ngau (ECH)

USNRC Regional Administrator, Region I USNRC Regional Administrator, Region III USNRC Project Manager, Palisades USNRC Project Manager, Big Rock Point USNRC Project Manager, Vermont Yankee USNRC Resident Inspector, Vermont Yankee Michigan Department of Environmental Quality Michigan Public Service Commission Vermont Department of Public Service Downs Rachlin Martin PLLC / St. Johnsbury, VT

ENOC-16-00007 Attachment 1 Entergy Corporation Parent Guarantee for Fiscal Year Ending 12/31/2015

Entergy Services, Inc Entergy 639 Loyola Avenue 70113 March 24. 2016 ATTN: Document Control Desk U .S. Nuclear Regulatory Commission Washinttton DC 20555-0001

Subject:

Enterg Corporation Parent Guarantee of Funds for Decommissioning: Letter from Chief Financial Officer to I)emonstrate Financial Assurance I am the chief financial officer of Entergy Corporation. 639 Loyola Avenue, New Orleans. LA 70113, a corporation. This letter is in support of this firms use of the financial test to demonstrate financial assurance.

as specified in Title 10, Part 50. of the Code of Federal Regulations (10 CFR Part 50).

This firm guarantees. through the parent company guarantee submitted to demonstrate compliance under 10 CFR Part 50, the decommissioning of the following facility owned or operated by subsidiaries of this firm.

The current cost estimate or certified amount for decommissioning. and the amount being guaranteed, is shown for the facility:

Name of Location of Current Amount Being Facility Facility Cost Estimate Guaranteed Big Rock Point Independent Spent Fuel Storage Installation License Nos. DPR-06, SFGL-16 Charlevoix. Ml $ 2.330.000 $ 5,000,000 Entergy Corporation is required to file a Form 10-K with the U.S. Securities and Exchange Commission for the latest fiscal year.

The fiscal year of Enterg Corporation ends on December 3 f. The figures for the foIlo ing items (Financial Fest l1 marked ith an asterisk are derived from Entergv Corporations independently audited. sear-end financial statements and fonlnntes for the latest completed fiscal sear, ended December U. 2015.

I hcreh certify that the content of tiJtter is true a d co ct to the best of mx knoss ledge 7

\ifdr S \iarh F \ecuti% e \ ice Prcidcnt and Chief Financial Office, Date M1il I r11 R ckPLr Iated[ mh r

FINANCIAL TEST: ALTERNATIVE II (10 CFR Part 30 App. A. Section II A.2.)

Entergy Corporation Parent Guarantee of Funds For Decommissioning Dollars in thousands

1. Guaranteed amount for Big Rock Point Independent Spent Fuel Storage Installation, License Nos. DPR-06, SFGL-16 (total cost of all cost estimates should be stated in paragraphs above) $5.000

2. Current rating of most recent bond issuance of this firm Rating Name of rating service Moodys

3. Date of issuance of bond July 1,2015

4. Date of maturity of bond jj5022

5, Tangible net worth** (if any portion of estimates for decommissioning is included in total liabilities on your firms financial statements. you ma add the amount of that portion to this line) $9,186,191

6, Total assets in United States (required only if less than 90 percent of firms assets arc located in the United States) N/A Yes No

7. Is line Sat least $21,000? X 8 Is line 5 at least 6 times line 1? X 9 Are at least 90 percent of lirnis assets located in the United Stales? If not. complete line 10.

10. Is line 6 at least 6 times line 1? N/A 1 k thc. ai rn pci ikd m inc B B B rn.. udinz 1d 1 u%tmnt I and 1 ni nU .r i if h\ ta dai d & Poui ) i Baa inL udin, ad t stmL,n 1 2 a oi iUiei it Moods)?

derived from financial statements.

Tangible net . orth is defined as net worth minus goodwill, patents. trademarks, and cops rights.

RECONCILING SCHEDULE ENTERGY CORPORATION YEAR ENDED DECEMBER 31, 2015 Dollars in thousands Per Recon- Per Line Number in Financial cuing CFOs CFOs Letter Statements Items Letter Total Assets $44.647681 Less: Total Current Liabilities (3.O89958)

Less: Total NonCurrent Liabilities (31.982.747)

Less: Goodwill (377.172)

Less: Net Book Value of Big Rock Point (1 1.613)

Tangible Net Worth $ 9.186.191 $ 9,1 86.191

ENOC-16-00007 Attachment 2 Independent Accountants Report on Applying Agreed-Upon Procedures

Deloitte. Deloitte & Touche ILl Suite 4200 701 Poydras Street New Orleans, LA 70139-4200 USA Tel: +1 504 581 2727 Fax: +1 504 561 7293 www.deloftte.com INDEPENDENT ACCOUNTANTS REPORT ON APPLYING AGREED-UPON PROCEDURES To the Board of Directors Entergy Corporation New Orleans. Louisiana We have performed the procedures enumerated below, which were agreed to by Entergy Corporation (the Company), solely to assist the Company in connection with the Companys and the U.S. Nuclear Regulatory Commissions (NRC) evaluation of the Companys compliance with the requirements specified in Appendix A. Section ii A.2 to Part 30 of 10 CFR, the Financial Test: Alternative El (the Financial Test) as of December 31, 2015, included in the accompanying letter from the Chief Financial Officer of the Company dated March 24, 2016 to the NRC. The Companys management is responsible for compliance with those requirements. This agreedupon procedures engagement was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants. The sufficiency of these procedures is solely the responsibility of those parties specified in this report. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose.

It should be understood that (1) we make no representations regarding the Companys determination and presentation of non-GAAP measures (such as tangible net worth), and (2) the non-GAAP measures presented may not be comparable to similarly titled measures reported by other companies. However, the following procedures were applied to the attached Schedules on pages 2 and 3 of Appendix A as indicated with respect to the symbols explained below.

A. We compared these amounts to tile Companys audited consolidated financial statements for the year ended December 3 1. 201 5 and found such amounts to be in agreement.

B. We compared tile Tangible Net Worth amount as shown in the column Per CFOs Letter included in the Reconciling Schedule on page 3 of Appendix A to the Tangible net worth amount presented on line 5 of tile Financial Test on page 2 of Appendix A and found such amounts to be in atreement.

C. We proved tile arithmetic accuracy and noted no exception after giving effect to rounding.

D. We compared the Net Book Value of Big Rock Point as shown in tile column Per Financial Statements illcltlded ill tile Reconciling Schedule on page 3 of Appendix A to internal accounting records prepared by employees of the Cornpan and found such amounts to he in agreement. We make no comment witil respect to the assumptions used in the preparation of the internal accounting records or schedules.

Member of Deloitte Thuche Tohmatsu

E. We compared the Current rating of most recent bond issuance of this firm in relation to the July 1,2015 bond issuance on line 2 of the Financial Test on page 2 of Appendix A to the Moodys Investors Service Report fhr Entergy Corporation dated June 30, 2015 provided to us by employees of the Company and noted no differences.

We inquired of the Chief Accounting Officer and Chief Financial Officer of the Company as to whether any off-balance sheet transactions exist that could materially adversely affect the ability of the Company to pay decommissioning costs. These Officers responded that they had no knowledge of any off-balance sheet transactions that could materially adversely affect the Companys ability to pay decommissioning costs other than those that may be disclosed in Entergys 1934 Act SEC filings.

We were not engaged to, and did not, conduct an examination, the objective of which would be the expression of an opinion on compliance. Accordingly, we do not express such an opinion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you.

This report is intended solely for the information and use of the board of directors and management of the Company and the NRC, and is not intended to be and should not be used by anyone other than these specified parties.

March24, 2016

Appendix A Entergy Services, nc

.Eflt 639 Loyola Avenue NewOrteansLA 70113 Tel 504 576 4000 March 24, 2016 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington DC 20555-0001

Subject:

Entergy Corporation Parent Guarantee of Funds for Decommissioning: Letter from Chief Financial Officer to Demonstrate Financial Assurance I am the chief financial officer of Entergy Corporation, 639 Loyola Avenue, New Orleans, LA 70113, a corporation. This letter is in support of this firms use of the financial test to demonstrate financial assurance, as specified in Title 10, Part 50, of the Code ofFederal Regulations (10 CFR Part 50).

This firm guarantees, through the parent company guarantee submitted to demonstrate compliance under 10 CFR Part 50, the decommissioning of the following facility owned or operated by subsidiaries of this firm.

The current cost estimate or certified amount for decommissioning, and the amount being guaranteed, is shown for the facility:

Name of Location of Current Amount Being Facility Facility Cost Estimate Guaranteed Big Rock Point Independent Spent Fuel Storage Installation License Nos, DPR-06, SFGL-16 Charlevoix, Ml $ 2,430,00& $ 5,000,000 Entergy Corporation is required to file a Form 10-K with the U.S. Securities and Exchange Commission for the latest fiscal year.

The fiscal year of Entergy Corporation ends on December 3l. The figures for the following items (Financial Test II) marked with an asterisk are derived from Entergy Corporations independently audited, year-end financial statements and footnotes for the latest completed fiscal year, ended December 31, 2015.

I hereby certify that the content of ttter is true a d corr Ct to the best of my knowledge.

Ar* S. Mart Executive Vice President and Chief Financial Officer Date See 10 CFR §72.30 tiling for Big Rock Point, dated December 17, 2015, Accession No. ML15351A524

FIhNk%C1kU TESEI: ALTERNAT[VE II (10CFRIart3OAp A Secton ItA.24 Entergv Corporat cn Parent Guarante ofF unds For Decomirissioning Dollars in thousands 1 Gusrtn:eed amount fir Sm Rock Poi tt Indcpendcnt Spen E uel St rage Instal auor, License Nos DPR-0$, Sf Ci 16 (total cost of all cast est;mates shauld be stated in paragraphs ahose) $5,000 2 Current rating of most recent bond issuancc. of this firm Rating Baa3 F Name of rating service Moodys

3. Data of issuance of bond July i. 2015

4. Date of maturity of bond jjyJ202

5 Tangible net ssorth** (ifan portion ofcsrmates for decommissioning is included in total liabilities on your firms firarcial statements )t u may add the amoint of that portion to this line) $9,186,191 B 1 oti ascets in United Stares trequired only if less than 90 percent of tinys assets are locaed in the United States) N A Yes No

7. U lne 5 at leas 52 1,0000 X C

8. Is tue 5 leat times lunL 1? X C a; 94 u Ore a nt sco a atcd t \u I r if a S X 31 D -,

I ,,i1 s m s, nr cc dl r tfl tkN f,,

R CON( IL ING S( HEDULE EN I ERGY CORPORAl ION YEAR ENDED DECEMBER 31, 2015 Dollars in ti usand Pc Rec on i)

,1 I irNtnberr Firar ;aI 0! CR) s Cf (3 s Letter Statenents lctal Assts $44 647,681 A Les 1 oa1 Cnrrcn: I iabihtie (3 089,958j A I es 4otal NonCurrent Liahilities (3L982J47) A Less G odwill (377,172)

Less: Net Rook Value of Big Rock Point LlI6J3) I)

Fangible Net Worth $9,186,191 C $Q18&191 B