L-20-067, Retrospective Premium Guarantee - 2020 Internal Cash Flow Projection

Retrospective Premium Guarantee - 2020 Internal Cash Flow Projection

ML20064C505
Person / Time
Site:	Beaver Valley, Davis Besse, Perry
Issue date:	03/04/2020
From:	Benyak D Energy Harbor Nuclear Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML20064C503	List: L-20-067, Retrospective Premium Guarantee - 2020 Internal Cash Flow Projection
References
L-20-067
Download: ML20064C505 (8)

Text

CONFIDENTIAL COMMERCIAL MATERIAL TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10 CFR 2.390 AND 10 CFR 9.17 energY 341 White Pond Drive Akron, Ohio tU320 horbor March 4,2020 L-20-067 10 cFR 140.21 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and2 Docket No. 50-334, License No. DPR-66 Docket No. 50-4 12, License No. NPF-73 Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License No. NPF-3 Perry Nuclear Power Plant, Unit No. 1 Docket No. 50-440, License No. NPF-58 Retrospective Premium Guarantee In accordance with 10 CFR 140.21, Energy Harbor Nuclear Corp. hereby submits to the Nuclear Regulatory Commission (NRC) an internal cash flow projection for Energy Harbor Nuclear Generation LLC. Energy Harbor Nuclear Generation LLC is the Iicensed owner of the Beaver Valley Power Station, Unit Nos. 1 and 2; the Davis-Besse Nuclear Power Station, Unit No. 1; and the Perry Nuclear Power Plant, Unit No. 1, reactors. The cash flow projection provides evidence of the guarantee of payment of deferred premiums in the amount of

$20.496 million per reactor, as specified in 10 CFR 140.11(aX4).

This financial projection is confidentia! commercial information, and Energy Harbor Nuclear Corp. requests that information be withheld from public disclosure pursuant to 10 CFR 2.390 and 10 CFR 9.17(aX4). A redacted version of the financial projection Enclosure C to this letter contains confidential commercial material.

Withhold from public disclosure under 10 CFR 2.390 and 10 CFR 9.17.

Upon removal of Enclosure C, this letter is uncontrolled.

CONFIDENTIAL COMMERCIAL MATERIAL TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10 CFR 2.390 AND 10 CFR 9.17 Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station, Unit No. 1 Perry Nuclear Power Plant, Unit No. 1 L-20-067 Page 2 suitable for public disclosure is provided in the non-proprietary version contained in Enclosure A, A confidential version of the financial projection is provided in Enclosure C.

An affidavit supporting the request for withholding Enclosure C from public disclosure is provided in Enclosure B.

This information is required to be submitted annually on the anniversary date on which the indemnity agreement is effective for each reactor. Because the indemnity agreement effective dates vary for each reactor, the enclosure contains the information for the aforementioned reactors to be submitted by March 7, the earliest indemnity agreement anniversary date of the reactors.

There are no regulatory commitments contained in this letter. lf there are any questions or if additional information is required, please contact Mr. Phil H. Lashley, Acting Manager - Nuclear Licensing and Regulatory Affairs, at (330) 315-6808.

Sincerely,

\,1, Darin M. Benyak Vice President, Nuclear Support and Regulatory Affairs

Enclosures:

A. Energy Harbor Nuclear Generation LLC 2OZA lnternal Cash Flow Projection for Beaver Valley Power Station, Unit Nos. 1 and 2; Davis-Besse Nuclear Power Station, Unit No. 1; and Perry Nuclear Power Plant, Unit No. 1 (Non-Proprietary)

B. Affidavit C. Energy Harbor Nuclear Generation LLC 2020 lnternal Cash Flow Projection for Beaver Valley Power Station, Unit Nos. 1 and 2; Davis-Besse Nuclear Power Station, Unit No. 1; and Perry Nuclear Power Plant, Unit No. 1 (Proprietary)

Enclosure C to this letter contains confidential commercial material.

Withhold from public disclosure under 10 CFR 2.390 and 10 CFR 9.17.

Upon removal of Enclosure C, this Ietter is uncontrolled.

CONFIDENTIAL COMMERCIAL MATERIAL TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10 CFR 2.390 AND 10 CFR 9,17 Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station, Unit No. 1 Perry Nuclear Power Plant, Unit No. 1 L-20-067 Page 3 cc: NRC Region I Administrator (without Enclosure C)

NRC Region ll! Administrator (without Enclosure C)

NRC Resident lnspector (Beaver Valley) (without Enclosure C)

NRC Resident lnspector (Davis-Besse) (without Enclosure C)

NRC Resident lnspector (Perry) (without Enclosure C)

NRC Energy Harbor Nuclear Corp. Fleet Project Manager (without Enclosure C)

Director, Bureau of Radiation Protection/Department of Environmental Protection (BRP/DEP) (without Enclosure C)

PA Department of Environmental Protection, Bureau of Water Protection (without Enclosure C)

Site BRP/DEP Representative (without Enclosure C)

Utility Radiological Safety Board (without Enclosure C)

Enclosure C to this letter contains confidential commercial material.

Withhold from publicdisclosure under 10 CFR 2.390 and 10 CFR 9.17.

Upon removal of Enclosure C, this letter is uncontrolled.

Enclosure A L-20-067 Energy Harbor Nuclear Generation LLC 2020 lnternal Cash Flow Projection for Beaver Valley Power Station, Unit Nos. 1 and 2; Davis-Besse Nuclear Power Station, Unit No. 1; and Perry Nuclear Power PIant, Unit No. 1 (Non-Proprietary)

(One Page Follows)

Energy Harbor Nuclear Generation LLC 2020 lnternal Cash Flow Projection (Non-Proprietary)

(Dollars in Millions) 2020 Proiected(1X2) lnternal Cash Flows:

Revenues Cost of Revenues Operations and Maintenance Other Operating Costs Capital Expenditures Deferred Cash Flow Net lnternal Cash Flow ](3)

Percentage Ownership in Units.

Davis-Besse Unit No. 1 100.00%

Perry Unit No. 1 100.00%

Beaver Valley Unit No. 2 100.00%

Beaver Valley Unit No. 1 100.00%

Maximum Total Contingent Liability $g1.gg4(3)

Notes.

(1) lnformation contained within the brackets [ ] is considered proprietary.

(2) Rounding has been used to calculate the values.

(3) Energy Harbor Nuclear Generation LLC has coverage of all cash costs per the terms of a power supply agreement with an affiliate. Therefore, Energy Harbor Nuclear Generation LLC will be able to satisfy any deferred premiums through the funding from their affiliate.

CERTIFICATION l, David D. Faranetta, Chief Financial Officer of Energy Harbor Nuclear Generation LLC, hereby certify that the foregoing lnternal Cash Flow Projection for the calendar year 2020 is derived from reasonable assumptions and is a reasonable estimate.

IDateZOZC D. Faranetta

Enclosure B L-20-067 Affidavit (Two Pages Follow)

10 GFR 2.390 AFFIDAVIT OF DARIN M. BENYAK l, Darin l\fl. Benyak, Vice President, Nuclear Support and Regulatory Affairs state that:

1. I am authorized to execute this affidavit on behalf of Energy Harbor Nuclear Corp. and its affiliates.

2. Energy Harbor Nuclear Corp. is providing information in support of its "Retrospective Premium Guarantee" submittal. The proprietary version of Enclosure C being provided in the submittal contains a 2020 cash flow projection for Energy Harbor Nuclear Generation LLC and the projected revenue is based on an intercompany Power Supply Agreement dated February 27,2020. This document constitutes proprietary commercial and financial information that should be held in confidence by the Nuclear Regulatory Commission (NRC) pursuant to the policy reflected in 10 CFR 2.390(a)(4) and 10 CFR 9.17(a)(4), because:

a. This information is and has been held in confidence by Energy Harbor Nuclear Corp. and its affiliates.

b. This information is of a type that is held in confidence by Energy Harbor Nuclear Corp. and its affiliates, and there is a rational basis for doing so because the information contains sensitive financial competitive information concerning Energy Harbor Nuclear Generation LLC's anticipated cash flow.

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 Energy Harbor Nuclear Generation LLC by disclosing its internal cash flow.

1

3. Accordingly, Energy Harbor Nuclear Corp. requests that the designated documents be withheld from public disclosure pursuant to the policy reflected in 10 CFR 2.390(a)(a) and 10 CFR 9.17(a)(a).

Energy Harbor Nuclear Corp.

Darin M. Benyak Vice President, Nuclear Support and Regulatory Affairs STATE OF 0lio COUNTY OF *f Lht tvlt L Subscribed and sworn to me, a Notary Pu blic, in and r the County and State above named, this luA day ot4t ,h-,zo2o.

A KITI,IBERLY D. A[.lDEHS tlotrry Publ'rc, Shh of Ohh My Comm Expires: /t ',t 7',Xat o My Gommlsdon EStirE$

December 27,W8, 2