ENOC-17-00005, ISFSI - Financial Test for Decommissioning Funding Parent Guarantee for the Year Ending December 31, 2016 Per 10 CFR Part 30 App. a

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ISFSI - Financial Test for Decommissioning Funding Parent Guarantee for the Year Ending December 31, 2016 Per 10 CFR Part 30 App. a
ML17089A714
Person / Time
Site: Big Rock Point  File:Consumers Energy icon.png
Issue date: 03/30/2017
From: Ford B
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
ENOC-17-00005
Download: ML17089A714 (8)


Text

Entergy Nuclear Operations, Inc Entergy 1340 Echekn Parkway Bryan S. Ford Senior Manager, Fleet Regulatory Assurance ENOC-1 7-00005 March 30, 2017 ATIN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Financial Test for Decommissioning Funding Parent Guarantee for the year ending December 31, 2016 per 10 CFR Part 30 App. A Big Rock Point ISFSI Docket 50-1 55 I 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 1 0 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 1 0-Q and 1 0-K filings.

There are no new commitments made in this letter. If you have any questions, please contact me at 601-368-5516.

Sincerely, BSF/Ijs/aye

ENOC-1 7-00005 Page 2 of 2 Attachments: 1 . Independent Accountants Report on Applying Agreed-Upon Procedures, including CEO Letter to NRC demonstrating compliance with requirements cc:

Mr. B. E. Green (TMBR)

Mr. J. R. Davis (ECH)

Mr. A. C. Bakken (ECH)

Mr. L. J. Smith (ECH)

Mr. C. E. Arnone (PAL)

Mr. L. M. Coyle (ECH)

Mr. T. Ngau (ECH)

USNRC Regional Administrator, Region Ill USNRC Project Manager, Palisades USNRC Project Manager, Big Rock Point Michigan Department of Environmental Quality Michigan Public Service Commission

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. Deloitte & Touche One Shell Square 701 Poydras Street, Suite 4200 New Orleans, LA 70 139-7704 USA Tel: +1 504 581 2727 wwwdeloitte .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 ofthe Companys compliance with the requirements specified in Appendix A, Section II A.2 to Part 30 of 10 CFR, the Financial Test: Alternative II (the Financial Test) as of December 3 1, 2016, included in the accompanying letter from the Chief Financial Officer ofthe Company dated March 23, 2017 to the NRC. The Companys management is responsible for compliance with those requirements. This agreed-upon procedures engagement was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants. The sufficiency ofthese procedures is solely the responsibility ofthose 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.

The following procedures were applied to the attached Schedules on pages 2 and 3 ofAppendix A as indicated with respect to the symbols explained below.

A. We compared these amounts to the Companys audited consolidated financial statements for the year ended December 3 1 20 1 6 and found such amounts to be in agreement.

B. We compared the 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 ofthe Financial Test on page 2 ofAppendix A and found such amounts to be in agreement.

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

D. We compared the Net Book Value ofBig Rock Point as shown in the column Per Financial Statements included in the Reconciling Schedule on page 3 of Appendix A to internal accounting records prepared by employees ofthe Company and found such amounts to be in agreement. We make no comment with respect to the assumptions used in the preparation of the internal accounting records or schedules.

E. We compared the Current rating of most recent bond issuance of this firm in relation to the August 19, 2016 bond issuance on line 2 ofthe Financial Test on page 2 ofAppendix A to the Moodys Investors Service Report for Entergy Corporation dated September 2, 2016 provided to us by employees ofthe 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 ofwhich would be the expression ofan 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.

bd4 March 23, 2017

Appendix A ETntergy InG New Orleans, LA 70113 March 23, 2017 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 701 13, 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, ofthe 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 Eacility Cpst Estimate Guaranteed Big Rock Point Independent Spent Fuel Storage installation License Nos. DPR-06, SFGL-16 Charlevoix, MI $ 2,500,43& $ 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 3 1St* 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 3 1, 2016.

I hereby certify that the content oft s letter is true and correct to the best of my knowledge.

I dre S. Marsh Ex tive Vice President and Chief Financial Officer Date I

See 10 CFR §72.30 filing for Big Rock Point, dated December 17, 2015, Accession No. ML15351A524.

Updated to $2016.

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 I 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 ofmost recent bond issuance ofthis firm Rating E Name of rating service Moodys

3. Date ofissuance ofbond Augst 19. 2016
4. Date of maturity of bond September 1. 2026
  • 5* Tangible net worth* * (if any portion of estimates for decommissioning is included in total liabilities on your firms financial statements, you may add the amount of that portion to this line) $7,907,488 B
  • 6 Total assets in United States (required only if less than 90 percent of firms assets are located in the United States) N/A Yes No
7. Is line 5 at least $21,000? X C
8. Is line 5 at least 6 times line 1? X C
9. Are at least 90 percent offirms assets located in the United States? If not, complete line 10. X
10. Is line 6 at least 6 times line 1? N/A I 1. Is the rating specified on line 2 BBB (including adjustments of + and or better (if issued

-)

by Standard & Poors) or Baa (including adjustments of 1, 2, or 3) or better (if issued by Moodys)? X

  • Denotes figures derived from financial statements.

Tangible net worth is defined as net worth minus goodwill, patents, trademarks, and copyrights.

RECONCILING SCHEDULE ENTERGY CORPORATION YEAR ENDED DECEMBER 31, 2016 Dollars in thousands Per Recon Per Line Number in financial oiling Cf0s CFOs Letter Statements Items Letter Total Assets $45,904,434 A Less: Total Current Liabilities (3,200,096) A Less: Total NonCurrent Liabilities (34,419,344) A Less: Goodwill (377,172) A Less: Net Book Value of Big Rook Point (334) D Tangible Net Worth $ 7,907,488 C $7,907,488 B