Text

Forwards Financial Info Re Decommissioning of Plants
	ML20055H763
Person / Time
Site:	Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle
Issue date:	07/25/1990
From:	Morgan W; COMMONWEALTH EDISON CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	NUDOCS 9007300029
	Download: ML20055H763 (200)
	v • d • e

{{#Wiki_filter:. [~} CommonweeMh Edison 4.u. A ~~ /1400 Opus Ptte 7 Downers Crove, Illinois 60515 L/ i-- July 25, 1990 U.S. Nuclear. Regulatory Commission l ATTN: Document Control' Desk i Hashington, D.C. 20555

Subject:

Dresden Nuclear Station Units 1, 2 and 3 Quad Cities Nuclear Station Units 1 and 2 Zion Nuclear Station Units 1 and 2-LaSalle County Nuclear Station Units 1 and 2 Byron Nuclear Station Units 1 and 2 Braidwood Nuclear Station Units 1 and 2 Report indicating how reasonable assurance will be provided that funds will be available for Decommissioning. NRC Docket Nos. 50-010/237/249, 50-254/265, 50-295/304,.50-373/374, 50-454/455 and 50-456/457

References:

(a) H.E. Morgan letter to NRC dated December 22, 1987. l l (b) P.B. Erickson letter to H.E. Morgan l dated. September 27, 1988. (c) H.E. Morgan letter to NRC dated f March 27, 1989.

Dear Str:

Reference (a) submitted Commonwealth Edison's Dresden Station Unit 1 1 Decommissioning Plan. In' reference (b) the NRC requested additional L information concerning the Decommissic31ng Plan and specifically the financial aspects of the plan. ' Reference (c) indicated that the requested financial informatio, would be provided at a later date. The following attachments submit the requested financial information indicating how reasonable assurance will be provided to insure that funds will be available to Decommission the Nuclear Generating Facilities of the / Commonwealth Edison Company. / P 0007300029 900723

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~' .i ~If.you have any questions regarding this matter, please contact this Very truly yours a g i M W.E.~Horgan Nuclear Licensing Administrator 1; aw cc: .A.B. Davis, Regional Administrator - RIII ~ P.B..Erickson, Project Manager - NRR B.L. Siegel, Project Manager - NRR l :. ' Senior. Resident Inspector - Dresden ! i, t 'imw/ID122 l> i 1 i i' i i i I i m i

5 ..J M g}' <[ Reoort to the United StLies Nuclear Regulatory Commission Indicating How Reasonable _ Assurance Will Bt Provided That Funds Hill Be Available to Decommission the Nuclear Generatina facilities of 'I Commonwealth Edison Comoany Commonwealth Edison Company (the " Company")_hereby submits a report to the United States Nuclear. Regulatory Commission (the "NRC") indicating how reasonable assurance will be provided that funds will be available to decommission the Company's nuclear generating facilities in compliance with Parts 50.33(kT and 50.75 of Title 10 of the Code of Federal Regulations ("10 CFR 50.33(k) & 50.75"). The Company currently holds operating licenses for and has ownership interests in 12 nuclear generating units and holds a possession only license for and has an ownership interest in a nuclear generating unit which was retired from service in 1985. The 13 units are located on 6 sites in the State of Illinois. The Company owns 100% of 11 onits and has a 75% ownership interest in 2 units. 1he Company hereby sertifies that financial assurance for decommissioning its 13 nuclear generating units:is hereby i provided in the amount.of $1,748.6 million. The amount is expressed in ~ January 1988 dollars and has been determined in compliance with the_ formulas prescribed by 10 CFR 50.75(c) the results of which are summarized on the following schedule: i Licensed Thermal Amount in Amount in Power Millions of Hillions of i Unit Iypt (Mwt) 1986 Dollars (al 1988 Dollars (b) l Dresden 1 (c) Bwr 700 114.8 $ 135'.4 Dresden 2. Bwr _2,527 126.7 149.4 Dresden 3 Bwr 2,527 126.7 149.4 Quad Cities 1 Bwr _2,511 95.0 (d) 112.0 (d) . Quad Cities 2 Bwr 2,511 95.0 (d) 112.0 (d) Zion 1. Pwr 3,250 103.6 127.9 Zion 2 Pwr 3,250 103.6 127.9 LaSalle 1 Bwr 3,323 133.9 157.9 LaSalle 2 Bwr 3,323 133.9 157.9 i Byron 1 Pwr 3,411 105.0 129.7 Byron 2 Pwr 3,411 105.0 129.7 Braidwood 1 Pwr 3,411 105.0 129.7 Braidwood 2 Pwr 3,411 10h Q 129.1 $1.453.2 $1.748.6 (a) Estimated in January 19F' dollars in accordance with the formulas prescribed in 10 CFR 50.,5(c)(1). '(b) Estimated in January 1988 dollars in accordance with 10 CFR 50.75(c)(2) and NUREG-1307. (c) Dresden I was retired from service in 1985. (d) Represents the Company's 75% ownership interest. a

c _g_ The method by which the Company will provide financial assurance for its responsibility to decommission the 13 nuclear generating units ls L currently in transition from an internal funding method, which was used by l the Company prior to 1989, to an external funding method, which satisfies L the requirements of State of Illinois Public Act 85-1400 signed into law on September 12, 1988 (Exhibit I), the related Order No. 88-0298 of the Illinois Commerce Commission (the "ICC") (Exhibit II), the qualified nuclear. j decommissioning fund provisions of Section 468A of the Internal Revenue Code and 10 CFR 50.75. Prior to 1989 decommissioning costs were charged to customers-as a . portion of.the depreciation rate applied to the cost of the related nucient 1 generating units. Over $296 million was charged to customers in this manner. Beginning in 1989 the nuclear decommissioning costs were separated from the charges for depreciation and an annual provision for nuclear facility decommissioning was authorized in the amount of $66 million by the ICC in Order No. 87-0427, 87-0169, 88-0189 and 88-0219 Consolidated, dated December 30, 1988. (The December 30, 1988 order has been reversed by the Illinois Supreme Court on unrelated grounds and remanded back to the ICC.) 1 The $66 million annual allowance was based largely upon internal funding decommissioning cost requirements which had been submitted into evidence for these ratemaking dockets. The Company's current rate request filed with the ICC on. April 12, 1990 in Docket No. 90-0169 seeks.to upgrade the annual o l ' decommissioning charges to almost $171 million, which would upgrade the . annual contribution to the external fund to almost $179 million. The additional $8 million annual amount contributed to the external fund over the annual charges to customers relates to the amortization of the portion of the charges collected from customers prior to September 12, 1988, the effective date of.the Illinois law,.that were not eligible to be included in the Tax Qualified Decommissioning Trust. The Company's revised nuclear decommissioning funding proposal, if adopted by the ICC, will bring the Company's funding schedu e in line with the requirements of 10 CFR 50.75. The particulars of this nuclear decommissioning funding proposal are H' contained in Edison Exhibit 15.0 (Exhibit III) of the Company's April 12, 1990 rate request. The funding requirements will be revisited from time to time.(at least once every four years) and will be adjusted accordingly. l The Company has also submitted a decommissioning plan for Dresden [ Unit 1, the unit retired from service in 1985, that also contains an i. assessment of the major technical factors that could affect planning for l decommissioning (NRC Docket.No. 50-010). The related nuclear l-decommissioning cost estimate (Exhibit IV), which was prepared by Thomas S. LaGuardia, is not being used for the related financial assurance amount because the amount is less than that prescribed by 10 CFR 50.75(c).

^' ~ 7 -(. ..- i In accordance with ICC Order No. 88-0298 (Exhibit II),-the Company contributed during the year 1989 almost.$153 million to a Tax Qualified Decommissioning Trust, representing the current income tax deductions allowed by Section 468A of the Interna' Revenue Code with respect to amounts i collected from customers prior to 1989. During 1989 the Company also contributed in accordance with the ICC Order over $9 million to a Non-Tax Qualified Decommissioning ~ Trust, representing the $8'million annual contribution of pre-9/12/88 collections which-is not currently deductible for income tax purposes that are being made ratably over the remaining book ' lives of the nuclear generating units plus the not currently deductible portion of collections for the period September' 12 -1988 through . December 31, 1988. In addition, almost $64 million was contributed to the-Tax Qualified Decommissioning Trust in. March 1990 and the Company plans to contribute'$10 million to the Non-Tax Qualified Decommissioning Trust in September. -Total contributions to the funds through June 30, 1990 were $226-million and the balance of the funds on the Company's books at cost, including the net earnings thereon, were $242 million at June 30, 1990. L -Coptes of the Trust Agreements dated December 8, 1988 between Commonwealth i Edison Company and The Northern Trust Company (Exhibits-V and VI) are l ' attached. Also attached are copics of the audited financial statements of the trusts for the year ended December 31, 1989 (Exhibits VII and VIII) 'k which indicate that the market value of the tax quallfled and non-tax qualtfled trust-funds were $227 million and $19 milli',n, respectively, at December 31, 1989. i i-ID122 b l l

w ^ ' ~ ~ y p,t NP t Exhibit I ^j [. 'L i n t State of Illinois Public Act 85-1400 Signed into Law on September 12, 1988 i r i 1 ) I f 4 I I.' 'g f p q h .k i.. 1 t s l 'I 7687C/2 1-n I

-. - _. -.. - _.. ~.. -.... -. -. -. -. ~. _ - _... -. n i . e --. 4 4 i \\- s -1 i 'l LAttl1191SB0dvas01 1 AAEMORDFF TO SENATE SILL 1815 - 13 t 3 AMENDRENT 30. Amend Senate 9111'1415 en page 1. hy-17 3 deleting the title and inserting la lieu thereof ? the' 4 followleg -t 5 S- 'AB ACT' to amend eartala Acts la relaties.- to 19 =i 4. environmental preteettee.'s and 7 la line 0,. by inserting

, and Sectica 2Sa-1 is added 31

( 8 therete, the added and amended Sectiese* before 'te read's 23 q i 9

and 1

10 en page 15, by lasettlag after line 11 the followings - 24

tch. 111 1/2,'ase par. 19384-1) 26 11 See.

Bla.1. At least Se dare behre isselantas the '38-13 f:: inaloales of any L noelear sewer slant 1 - ted in this 29 q 13 State, the evaar er emerater of the slant shall file a ;;;e 30 14 ef the f:_ lesienine slan for the slaat with the M:r.;;. 31 15, The asesev shall review the slan to essess its setential 33 p 16 envireamental Lanset en the alte and anw surr== dine er 17 otherwise affected areas, and shall samment en the slan as it 33 it relates to matters within the Aeonev's seriodieties. 34 19 Seetten 3. Seetles 8-Ste.1 is added to *The publie 34 28 Ott11 ties Act*, approved June 29, 1931, as amended, the added 37 21 Sectiskt to read as fellows: (Ch. 111 3/3, new per. 4-500.1) 39 i 1 e ..v, -~ m.

.. _. ~ ,.,ME 3 !? s ? t* ~Letell1949tCdvae01' -c R 1-Sec. 0 100 1. (a) as used in this'$ection: 41 2 'll)

0,esamtestentne' means the series of activities

'43- ~ ) undertanen at the time a n tlear pewer slant is sermanentiv 44 u 4 ret: red from servlee to ensure that the f 6 mal' entomteent. 49 l decostenstat;:e. dismantleeint. removal and dissesal of tre 46 6 o ' 6 r. t. .?cht;*c ne ol a r.t site. and of any redtoactive-47 1 ? compone t s and eaterials 'asscetated with the slant, is i e accoeslished an compliance with all assitcable !!!!nois and -48 l 'r federa*

aws. a*d to e*stre that such final dissosition does 49 l

1 10 not sose any threat to the sublic health and safety, 11 (2) *Deesseni s s ionine costs' means all reasonable costs ll 12 and essenses incurred :n connection with the en t ostme'it. la 13 decont asiinat s on, dismantlement. removal and dissosal of the .93 14 . structures, systems a*d esamenents :f a nuclear sover slant $4 Il at the t:me of decommissionine, includine all essenses to be-16-Laevrred in connection with the steneration for ll '17 decessissionine, such as eneineerine and other slanales 16 18 eroonses, and to t>e incurred af ter the actual deccanissionine 97 t 19 occurs, such as shvsical security and radiation eenitorias la l. 20 essenses. less stoceeds of insurance, salvase or resale of 59 21 eachinery. construction seulement or asseratse the oest ef SG -22 which was ettareed as a decommissionine essesse, 23 (1) *0eessusissionine trust' oc

trust" means a fiduciarv 62 24 account in a bank or other financial institution established 63 25 to hold the decessissionine funds stevided--sure-et to 64 j

26 subsection (bitti of this Sectior. for the eventual oursese of 65 27-savine decommissionine costs,_ which shall be sesorate free 44 .1 28 all other accounts and assets of the sublic utility 1 -29 establishine the trust. 30 ta) *uuclear sower slant" or

slant" means a nucleet 68

.1 31 fission thermal never slant. Eaen unit of a multi-unit site 69 32 shall be considered a sesarate slant. 33 lb) Sv 90 days sfter the effective date of this 71 3d' amendatory Act of 1988, or by the date that the sait 72 al satisfies the criteria used by the Internal tsvenue Service 73 4 a-

. -., ~ ,.l.... e f. 4)* .LA98l11916tCdvaa01 a i 4 1 for 'determinine when fecternation commences for federal '14 h 3: ineose ' tas 'surseses on a **w seneratine unit, whichever is 1 .( ~ 3 later, every sublic v>ility that' owns er oserates, in whole-Il { .i 4 or in eart, a nuclear sover slant shallt l (1) establism 2 6ecommiss tens ee t rusta. which shall be 's 71 i l 6-

tas evalified*

deeospissionine trust and ' a "non-tas 78 7 avalifted* deece.Sissionine trust and shall hold the 79 .5 8 decessissionine funds established by the sublie utility for l. 9 all nuclear sower stents sursuant to subseetion ibl121 of '00-l 10 this Section: 11 (2) establish I decessissionine - funds for each such 42 12 slant, each of which shall be held for a slant as a ::: tate - 02-13 account in a decommissionine trust and 14 (31 desionate an independent trustee, subioet to the el is amoroval-of the Commission, to administer each' of the .- 46 16 decommissionine trusts. 17 tel The 2 decousissionine trusts shall be k;w, as the et it

tas eualified* decommissionine trust and the

'nen=tas,

09 19 avalified* decommissionine trust res;;;;19elv. ~ "-" trust 90 20 shall be established and Saintained as fellowet 3

21 (1) The "tas cualified* trust 'shall be ~ established and 92 22 maintained in' accordance with :::lon estA of the Internal 93 x 23 Revenue code of 1986 er any successer thereto and shall he-94 24 funded by the sub11e ut111tv for.'each =M mover slaat 95 25 throush annual assenate by the sublie utility that shall met 26 eseeed the assimus== aunt allowable as a deduction for 96 i 27 federal ineone tar nurseses for the voar for whlen the 97 le navnents were made, in accordance with 2;; tion 468A of the 98 29 Internal Revenue Code of 1986 or any su;;eeser thereto. 30 ill The 'nea=tas cualified* doesamissionian trust sinaiM. 100 31 be funded by the sub11e utility for each cr-anwer $==e4 101 32 thrauch annual navnenta by the sub11e ut111tv that shall 102 33 consist of the difference between the total - _ :s of 103 i 34 decommissionine ennenses collected after the effective date 35 of this amendatory Act of 1988 throueh rates and charees fres 104

.~. -. - -.-.- -.- - - - - - _. -. -. l ha 4-Latell1919todves01 ) i V 'the sublie utility'e' eustomers as stevided by the Ceanission-109 _3: eines the amounts contributed to the 'tse eustified' trust as 106 3 stovided by subsection teltil of" this Seetten and deductible 107 4 for federet income tas ourscoes in eteerdance with teetten 100-i- 5 464A of the Internal Revenue Code of 1986 er any successor 109 6 thetete. 7 (31 fne followine restrictions shall apolv in reemed to 111 4 administration of each deeossissionine trust: 113 i 9 ft) Distributions ear be made free a nuclear 114 10 decossissionine trust only to satisfy the liabilittee of the 115 11 public utility for nuclear deeosmissionine costa relatise' to 116 la the nuclear mover plant for wnich the decossissionine fund-117 13 was established and to new administrative costs, ineses tases 110 14 and other incidental essenses of the trust. Il Iill Any assets in a nuclear decessissionine trust that 130 16 escoed the ent necessary-to new the nuclear 131 17 dee-testosine costa of the suelear mover slant for whlet 133 18 the decessissionine fund was established shall be refunded to 133 l' 19 the sublic utilitt that established the tua$ for the murmese 30 of refunds or credita, as econ as staetieable, to the 134 31 utilitt's customers. 23 tiill In the-evest a sublie ut111tv sells er otherwise its 33-disasses of its direet ownershis laterest, se amt mort 137 at thereof. is a nuclear mover slaat with resseet to etist a 130 l l. as weeleer decessassiestos fand has bees patat11shed, the assets 139 36 ef_the_imad_shall be._d14tpbuted et t?O pyb1[e ut_L11.11_11._1ht 1 l 37 estent of the reductions in its liability for future 130 at b issionine after taklee into ac;n st the liabilities of 131 = 29 the sub11e utility for future deconstep}en}q et such singlear 133 30 sewer m1 ant and the liabilities 'that hpv( Mn assumed.._kt 133 l 31 another entity. The sublie utility shall, as sees as 134 33 staeticable, stevide refunds er credits to its eustenarl 33 restesentine the fuT1 m of tire reductions is l'ta - 135 34 ' liability for future decommissionine. 35 tivi The trustee shall tavest the 'tas cualified" trust 137

_ _ -. _. _ _... _... _ _ _. _. _ - _ ~ _ _ _ _ =': 3 1,. =,1 W. +l-Lttel1101190dvaa01 a 1-assets salv' in soeure assets that ate student ' investments for. 133 L 3 assets held in trust and in' such a way as to atteemt to 139 ) 3-eastatie the af ter-tas return en funds invested,- subioet-to. 140 4-the lleltations speelfQ4 in 'section 468a of the Internal 141 l 5 Sevenue code of 1986 'or any successor therete. 143-- 6' (vl the trustee shall lavest-the "non-tas evallfled* 144 7 trust assets only in secure sesets that are student 145 e investments for assets held in trust and la such a war as to 144 9 atteent to masimise the af ter-ts: return en funds invested. 147 10 Bewever the trustee shall not invest-any nortion of the 11

nen-tas evalified" trust's funds la the securities or assets-143 13 et any emerator of a nuclear sover 'stant.

149 13 1911 The "non-tas_ avalified' trust shall be subioet te '151 14 the arohibitless seeinst self-deallne amm11 cable to the ' *tas 183 1S - evalified' truet as saecified in Sectica ef?' sf the Internal 153 i 16. Revenue code of 1984, er any successor therete. k11 ineens earned by the trust's funda shall its 17 fv11) le beceae a mart of the trust's funds and suhteet to the - 156 19 arevieleas of this Section. 30 gilll The Camaission ear adest be role er reaulaties 158 31 such further restrictions as it deems seeeenare for the asund .189 23 annasement of the trust's funds, eenststent with the murassee lot. 33 of.this Gestica.a 24 ten to 90 dare after the offsetive data af hen t a ] (' ggg .......,..,..,.~...-~1 - - - ^ ^ .m 29 Amt of 1980. the - lesienshalldeteralesanj, 163 --- 2.l'EaI enthod ta ~ ' de' emateI.~ Iel'*E iEEi-MII'et y 36 a a r 164 27 esitfM 1 b il.dee m issitalpa_f.unda. E i 30 affeetive date of this amendatory act of 1988 he the"'Etl1TtI] -16$ )t ; 39 free -its susteners, and shall order 'ame 'ehanesI'le SEs 164 ~ j 30 f:: ameientes fee.:ine methods that tha - "maien findahl [67 .n 31 acessaarv. Im nakine its determinaties of *ma - - diate"i 168 33 fundian anthed. the temalasise shall else enealdaraties "te.I 169 33 but est he limited by: all smalleable federal reenlations. " " 34 The shamee la fundiae method shall be shamed-La over se 170 al amoreeriate meriod of time.

1,.t. f 1 i t J+4 ' Lt9061191trOfvoe01 e g 1 tel the trustee of a trust shall resort annuelle to the 113 ~ '3 M en. er nors freeuentiv if ordered hv*the -Caeslealen. 173 3 The resort shall include - 4 111' the trust's State and federal' tas returner !?$ i 5 til a report on the trust's portfolio of investeents and 177 6 'tne return thereon's-1 -(3) t r.e date and aeovat of serments received by the 179 e trust free the sub11e utilityt 9. (4) a copy of all correspondence between-the trust and 181 10c the Internal Revenue Serviret and Il til any other information the Camelssion orders the 103 12 trust to provide. l-13 (fl* a nuclear decossissionine trust established oursuant tel 14 to this section shall be eseest from tasation in -illinois.*: les ll and. t ?.6 in line 12, by changing *2.* to *3.'. 109 t t ee L L 4 1 1 1 { S k t l

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f '.rq,; ;;j; s Exhibit II i.; s 1 Illinois Comerce Comission Order No. 88-0298 l If. i { 'l I i l(* ,O ,1 l .1 Y [ -s i l - a. v i 1._ 1 .i s: \\ l l, t. l. I',

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a.W STATE OF ILLINCIS 2LLIN025 COMMERCE COMMISSION i Illinois commerce Commission L .on Its own-Motion a vs. Commonwealth Edison company 88-0298 Establishment _of Nuclear Decommissioning Trusts. 0,8g31 l lF' By the Commission L on September 28,

1988, the Illinois Commerce Commission I

(' Commission'),. on its own Motion, initiated proceedings with respect.to< Commonwealth Edison Company (' Edison *) and three other electric utilities for the establishment of nuclear decommis-- sioning trusts. The Commission initiated such proceedings in 'i l . response to Public Act 85-1400, which added section 8-508.1 to- 'the Illinois Public Utilities Act ("Act') and requires that by L -December 11, 1988, every public utility that owns or operates, in l whole or in part, a: nuclear power plant shall:- l' (1) establish 2 decommissioning trusts, a ' tar qualified' i and a "non-tax qualified" trust,-to hold decommission-ing funds; (2) es'tablish 2 decommissioning-funds for each plant to be held as separate accounts in tihe decommissioning-a trusts, and; '(3) designate an independent

trustee, subject to the

' approval of the Commission, to administer each of the decommissioning trusts. A Notice of Intervention was filed by the office of Public Counsel ('OPC*), but CPC did not actively participate-in the proceedings. Staff did not object to Edison's decommissioning trust proposals. 4 \\ I L Pursuant to notice 'as required by law and given in accor-L dance with the rules and regulations of this Commiss!on, this L matter was heard before a duly authorized Bearing Examiner of the commissien at 'its offices in Chicago, Illinois, on November 14 and 23, 1988. At said hearing, both Staff and Edison were i represented by counsel. Edison presented the testimony of its i Vice President -and Treasurer, Ernest M. Roth, in support of Edison's proposed decommissioning trust agreements. At the conclusion of the hearing on November 23, 1988, the record was l marked ' Beard and Taken."

38 j 88-0198 ~ . Edison proposes to establish two external' trust. funds - for each of its' twelve (12) nuclear power plants now in service, and for Dresden 1, which was retired from service in 1985. One trust s fund for each plant will be a Tax Qualified Trust established in accordance with Section 468A of the Internal Revenue Code of.1986 (' Code"), and the other trust fund will be a Non-Tax Qualified-Trust. Collectively, these trusts shall be known as the ' Common-wealth Edison Company Tax Qualified Decommissioning Trust Fund' and the ' Commonwealth Edison Non-Tax Qualified Decommissioning Trust Fund.' The purpose of such funds is to. Provide for end-of-life decommissioning costs of its nuclear power plants. -To permit efficient management of these trust funds, Edison proposes to enter into two master agreements: one Tax Qualified t Decommissioning Trust Agreement and one Non-Tax Qualified Decom-missioning Trust Agreement. Each of the two master trust agree-m ments will have under it the thirteen separate trusts for each of i Edison's thirteen (13) nuclear generating units. The 26 separate trusts will each have their own books, their own funds and will constitute separate entities pursuant to section 4-508.1(b)(2) of the Act. Edison expects,

however, that the trusts will be i

administered together and invested on a pooled basis, with the Tax Qualified trusts in one-pool and the Non-Tax Qualified trusts p in a separate pool. Edison has recovered and will continue in the future to recover decommissioning costs from its customers through its rates. Edison proposes to contribute into the Tax Qualified Trust that portion of the amounts collected previously that is ruled by the Internal Revenue Service to be currently tax deduct-ible through one lump sua payment. Edison also proposes to contribute annually into the Tax Qualified ' Trust amounts collected in the future that do. not exceed the maximum amount allowable as a deduction for' federal income tax purposes for the year in which such payments were made, in accordance with Section 468A of the Code. l Edison proposes to contribute amounts annually such that the l Won-Tax Qualified Trust will contain the difference between b decommissioning cost revenues collected subsequent to the effec-tive date of section 8-508.1 of the-Act and the maximum amount allowable as a deduction for federal income tax purposes under L Section 468A of the Code. Edison also proposes contributing into L the Non-Tax Qualified Trust decommissioning cost revenues col-lected prior to the effective date of Section 8-508.1 which are not currently deductible. Edison proposes making this payment in equal annual installments ratably over the remaining book life of i each plant, except for Dresden 1, for which the remaining book j life of Dresden 3 will be used so as to prevent an untoward drain on cash flow. Edison has correctly concluded that ratable contributions are permitted by Section 8-508.1(d) as an -

i t 3! },, 88-0298 q appropriate-period of time to phase in this change in decommis-stoning funding methods., Edison proposes that The Northern Trust. Company (' Northern Trust') serve as trustee for both - the Tax-Qualified Trusts -and U. Mon-Tax Qualified Trusts. Edison has pointed out that-appoint-i i mentief a single trustee for both funds will provide economy and efficiency of management and facilitate investment activities. Mr. Roth's testimony indicates that Edison evaluated-nine 4 corporate trustees, narrowed the field to four finalists and then. carefully selected Northern Trust from among toe final four candidates. Bis testimony ind pates that the selection of Northern - Trust was based on a-nober of factors, including the . soundness of-the financial institution, its extensive experience p in handling master trust accounts, the greater experience level l of the people dedicated to servicing the trusts, its superior L organisational depth, as well as its superior investment screen-ing, data handling and data reporting capabilities. L Edison states that Bide L. Thomas, Edison's President, is a member of the 'Soard of Directors of Northern Trust. In view of this fact, Northern Trust is an ' affiliated interest' of Edison within. the meaning of Section 7-101(2)(f) of the Act. Edison represents that no such affiliation ~ has had or will have any effect on ' Bdison's actions relating to the selection or the l. compensation payable to Northern Trust, as trustee. 1 - The proposed agreement provides that the trustee will have general investment discretion and general managerial powers over the assets of all trusts, and will have the power to delegate ministerial-powers and duties as it may deem advisable. The agreement further provides that Edisoa will have the right from time to time to-appoint Investment Managers for-the trusts and to direct the segregation of any part of all-of any such trust into one or more investment manager accounts." In the. event that l Edison elects to exercise its right to appoint an Investment Manager, the-trustee will execute investment decisions at the direction of the. Investment Manager, although the trustee will remain responsible to assure that investments are consistent with all applicable restrictions in the respective trust agreements. The Commission agrees with Mr. Roth's testimony indicating that -the use of inves.tment managers, as Edison proposes, can provide valuable investment flexibility, especially as the funds increase in aise. While the Tax Qualified and Non-Tax Qualified Trust agree-ments are similar,.they differ in their treatment of income taxes. As an initial matter, however, the Commission notes that j both types of trusts are exempted from Illinois state income l taxes pursuant to Section 8-508.1(f) of the Act. For the Tax Qualified Trusts, however, the agreement directs the Trustee to.

y r -r j s. 88-0298 file.a?.1 accessary. tax returns and to pay out of each separate ~ trust the appropriate' taxes. For the Non-Dualified Trusts, Edison vill prepare its own income tax returns with information 'provided.by the Trustee, so the agreement provides for-the trustee to remit the amount which Edison certifies as 'its tax obligation-attributable to the trust's activities within fifteen business days following Edison's request. Except for reimburse-ment of decommissioning costs, this is the only other provision in the agreement which permits a distribution to Edison. The Commission is of the opinion that the clear intent-of the Illinois Legislature was to assure that sufficient funds are being set aside to fully decommission all nuclear plants within + Illinois. - The Commission has concluded, consistent with this legislative intent, that the Commission may adopt by rule or regulation such restrictions as it may deem necessary for the sound management of the Trusts' Funds. l The commission is further of the opinion that there should be a periodic review cf the nuclear decommissioning trusts to assure.that' appropriate.*unds are being set aside and to assess the performance of the Trustee and any Investment Managers such review should-occur at l' east once every four (4) years. The commission is also of the opinion thats (1) any altera-tion or amendment which substantially, significantly or materially affects.the Trust Agreements is subject to the prior approval of. the Commissions (2) the Krustee and any Investment Manager are held to an ordinary negligence standard applicable to l s fiduciary; (3) the Trustee and any Investment Manager are subject to removal by the Commissions and (4) a copy of any and all notices required by the Trust Agreements shall be given to the Commission. The Commission also notes that compensation rates have not been explicitly set forth in the Trust Agreements. The Commis-sion hereby expresses its intent to review the level of compen-sation rates based on the market created by other decommissioning trust-funds established, pursuant to federal and. state regula-tions. In particular, we note the decision of the California Public Utilities Commission, Re: Nuclear Facilit*j Decommissioning costs, 87-0562 OII 86, decided May 29, 1987, t ed POR 4 th 13). Edison represents that, in its judgment, approval of trust agreements substantially in the form of those provided to the Commission is necessary to-the conduct of Edison's business as a public utility and.is-in the interests of Edison and the public. The Commission, having considered the entire record herein and being fully advised in the premises, is of the opinion and finds that: '

1 ~ 88-0298 ~(1) lBoison, an Illinois corporation.with its-principal offices-in Chicago, Illinois, is a corporation engaged in the generation, transmission, sale and distribution. -of electricity to the-public in the state of Illinois, .and, as'such, is a public utility within the meaning of The Illinois public Utilities Acts

(2) the Commission has jurisdiction' of Edison and of the'.

subject matter-of this. proceeding; (3) the recitals of fact and conclusions-reached in the prefatory portion' of -this' order are supported _ by, evidence of record, and are hereby adopted as' findings of facts (4) petitions to Intervene-were filed by Opc and COB, but neither party appeared'at the: hearings; (5) Edison-owns all of p' art of thirteen (13) ruclear power plants-as defined in Section 8-508.1(a)(4) of The Acts (6) the evidence demonstrates that Edison's proposed taust-agreements fully comply with the requiremente of section 8-508.1 of. The Act and Section 468A of the Internal. Revenue Code,.to the extent applicabler. (7) _ Edison's proposal to contribute into the Tax Qualified Trust amounts collected previously ' that are ruled by the Internal Revenue _ Service to be currently-tax

deductible through-one 11 ump sua payment,- and amounts collected. in the future through annual payments that: shall not azeeed the-maximum amount allowable as a deduction _for~ federal income tax' purposes for the year in which such payments were made 'is reasonable and in compliance with both-Section 6-508.1(c) of The Act and.

Section 468A of the Internal Revenue Codes (8) Edison's proposal to transfer currently non-deductible decommissioning cost revenues collected prior to the effective date of Section S-508.1 through' annual payments to. the Non-Tax Qualified Trust - ratably over the remaining _ book life of each nuclear power plant (except. for Dresden 1, for which the remaining book life of Dresden 3 will be used) is reasonable and an appropriate.sethod of effecting such transfer -in compliance with Section 8-508.1(d) of The Acts (9) Edison's proposal to contribute amounts annually such that the Non-Tax Qualified Trust will contain the difference between decommissioning cost revenues collected subsequent to the effective date of Section..

' *} j 88-029'8.. 1 8-508.1 of the Act and the maximum' amount allowable as-a ' deduction for federal income tax purposes. under section 468A of the Internal Revenue Code is reasonable and-in compliance with Section;8-508.1(c)Lof the Acts (10) Northern Trust, which Edison selected as sole' trustee, is highly qualified to serve as trustee for the.decom-missioning funds.and approval should be grar,ted to serve as said trustee; (11) the fact that there is an ' affiliation of - interest *-

r between Edison and Northern Trust, has not had any bearing on its selection as trustee and will not have any future effect on Edison's actions relating to the L

selection or the compensation payable to Northern-i Trust, as trustee for the decommissioning trusts; (12) Edison's retention of the right to appoint one-or more. investwent managers will help ensure that the trusts-retain the necessary investment-flexibility as the L: -funds increase-in sise and is reasonable; L, (13)-Edisnn should be required to inform Staff with reason-I able notice of its intention to appoint or replace any and ' all Investment Managers,. and file any agreement 1 with Investment Managers with the Commission; (14) Edison should be allowed to make minor amendments to the trust agreements which do not substantially or materially affect the operation or effectiveness of the ~L trusts without commission. approvalt

however, Edison ll should-report any such amendments to-the trust agree-sents on an-annual basis.

E IT IS THEREFORE ORDERED that: A. The consent,-authorization and approval of the Commis-1 sion is granted to Commonwealth Edison Company to: (1) establish a Tax Qualified Trust and a Non-Tax Qualified Trust for each of its thirteen (13) nuclear power plants and related master trusts substantially in the form of the Trust Agreements submitted to this Commis-sions (2) aske~ ainor amendments to the trust agreements which do not substantially or materially affect the operation or effectiveness of the trusts without commission approvals (3) contribute 19 9 the Tax Qualified Trust 6. + ,--.-,r..--

. -- ~. -. -. 'l 1 88-0298 (a) amounts-collected previously that are ruled by the y Internal Revenue Service. to.be -currently.' tax. . deductible through one lump-sua payment, and= (b,) amounts. collected ' in. the future 'through annual. payments that shall not exceed - the maximum amount allowable as a deduction-for federal income tax purposes for the year in which such payments were made, in accordance with section 468A of the Coder '(4) contribute into the - Non-Tax Qualified Trust, throughL annual payments, amounts representing: (a) decommissioning cost revanues collected prior to the ef fective date - of Section 4-508.1 of The Act which are not currently deductible,.such revenues -i to be contributed ratably over the remaining book life of each plant, escept for Dresden 1 for which the remaining book life of Dresden 3 will be useds (b) the difference between the-decommissioning cost revenues collected subsequent to the effective: y date of Section 8-508;1 of The Act and the maximum i amount allowable as a deduction for federal income tax purposes under Section ' 468A of - the Internal. Revenue Coder (5)- appoint,from time to time Investment Managers, to . segregate investment. manager accounts, and to-permit each Investment Manager to direct the trustee-concern- -ing the ' investment of segregated investment manager accounts. B.- The consent, authorisation and-approval of the commis-sion is granted to commonwealth Edison ~ Company to employ The Northern Trust' Company, as the trustee for all decommissioning trust funds. l C. Edison shall require the trustee to report annually to the Commission, and such reports shall includes (1) state and federal tax returns or information returns for each trust; (2) a -report on each of the trusts' portfolio of invest-u ments and the return thereons (3) the date and amount of payments received by each trust from Edisons

'l 88-0298 1 1 (4)'.a et,9y of all correspondence between each trust and the 1 Internal Revenue service.

1

' (5)- minor encadsents to the trust agreements as set. forth in Finding (14)-herein. D. Edison shall inform staff with reasonable notice of its intention to. appoint-or replace any and-all Investment Managers 1 and file ~ with the Consission a copy of _ any Investment Manager Agreement. .] B. Approval of-th's commission is her2by granted'to Edison j to'. do any and all: things not contrary so law,' or the rules an t' regulations of the commission, incidental, accessary, or approd priate to the performance of any and all acts specifically _authorised.in this order. By_ Order.of'the Commission this 7th day of December, 1988. I e (SIGNED) MARY B. BUSHNELL Chairman (S E A L). b l l 4 9 O e g.

88 0298-C commissioner Manshio,: concurring: My: concurrence-is based upon a disagreement. with the majority's addition of the following language i ... commission has concluded, consistent with this legislative intent, that the Commission may adopt by' rule or regulation such restrictions as it may deem necessary for the sound 2 management of.the Trusta'tFunds. The commission is further.of the opinion that there should be a periodic review of the nuclear decommissioning trusts.to assure that appropriate funds are being set aside and to-assess the-performance of the Trustee and any Investment- ) Manager; such review should occur at least once every-four 1 (4) years. 1 The commission is also of the opinion thats (1) any i alteration or amendment which substantially, significantly_or j materially affects the Trust Agreements-is subject to the -l prior approval.cf.the commissions-(2) the Trustee and any Investment Manager are held to an ordinary negligence

standard applicable to a fiduciary (31 the. Trustee and any-Investment Manager are subject to removal by the Commissions and (4).a copy of any and all notices required by the Trust Agreements shall be given to the1 Commission.

The commission also notes that compensation rates have not E been: explicitly set forth in the Trust-Agreements. The commission'hereby expresses its. intent to review the level of compensation: rates based on the market created by other- ^- decommissioning trust funds established pursuant to federal a and state regulations. In particular, we note-the decision of the California Public Utilities Commission, Re: Muclear Facility Decommissioning) Costs, 87-0562 CII 86, decided May 29, 1987, (84 PUR 4th.13. -The inclusion of these four paragraphs to each Order in J Dockets 88-0298 Commonwealth Edisont 88-0299 Illinois Power, 88-0300 Iowa-Illinois Gas and Electric; and 88-0301 Union L Electric Company-is, at best, dicta; and at worst, misdirection. My overriding concern is that the four paragraphs indicate a JE direction that is not based upon evidence of record. In L addition, the language misinterprets the primary purpose of the l L legislation, Public Act 05-1400, and predetermines the need for a p rulemaking. Furthermore, the majority's focus on certain I'

> r 88 0198 additinnal restrictions is inappropriate. Their conclusions are not based upon a comprehensive inquiry into the need for, and-type of restrictions articulated. The nature of the trust-relationship and the impact of the articulated restrictions has not-been considered, particularly in light of applicable professional standards. In effect, the commission has rushed to judgment to articulate conditions where it does not need to do so.. PREQUEL TO ROLENARING As I have indicated, the above four paragraphs included by the majority do not relate to the resolution of these cases. In fact, the clear indication is that the Commission had predetermined rulemaking since it is necessary for-the ' sound management of the Trusts Funds.' No one disputes the-Commission's ability to adopt further rules'or-regulations providing for such further restrictions. That is not the issue. The issue:is whether such rules or regulations are necessary for the sound management of the Trusts Funds. I would remind my. colleagues that this docket did not address the necessity of a rulemaking proceeding. As such, the theoretical base'for the conclusion reached in:these four paragraphs is lacking. HIn the past the Commission: bas-explored comples= subjects and relationships-through use of a number of non-adversarial formats, such_as, Notice,of Inquiries (NOI) proceedings, and workshops. The advantage of a less adversarial proceeding is that it promotes discussion and understanding of technical and other problems before a rule:is considered. Bere, the' Commission has predetermined the necessity of a rule without undertaking such an inquiry. The path undertaken-may, therefore, be misdirection. In order to more fully. elaborate on my concerns, I will review specific objections to each paragraph. TBE 'IN ADDITION' pARAGRApB In general, the language of this paragraph sets up the subsequent paragraphs. It,'however, notes that the ' Commission has' concluded.' First, the conclusion is not based upon evidence in the record. Second, if the conclusion is based upon ' legislative intent,' we are left to a reading of the statyte. Section 8-508.1 provides that every public utility that owns or operates, in whole, or in part, a nuclear power plant, shall estab1'ish two decommissioning trusts. The primary legislative intent is to safeguard decommissioning funds for the time of 2

____-.__._..__.7___._.___.__ a cu 88-0298' g, I " decommissioning. - f ocus on the management of those funds.The four paragraphs. included by th! the extent of. oversight my colleafues contemplate.An ambiguity arises over i TBE ' PERIODIC REVIEW' PARAGRAPE The commission concludes that review within four years is -appropriate. What is the magic in four years? It is certainly 4

not' based upon the record.

While articulating a period for L review, the-Commission does not reveal its-intention regarding P the; mechanism'for such review, or to whom the burden of going forward shall fell upon. The mechanism, if any, and the groponentofreviewareleftwiththe' Commission'swisdomon four years.' 1. Another. aspect of the majority's four paragraphs is the lf interrelationship of various statements. This paragraph, taken ~ together with condition three in the following paragraph could be L y-construed to mean that if the Commission assesses an investment-manager's performance, and is not satisfied with the financial return of the trust. fund,'the commission could instruct the company to move its funds elsewhere. Further, the Commission simply by refusing to approve any investment manager othe the Commission's own choice. L These: potentially: broad powers. First, will-standards be set for a present several problems. ,a fund's-financial performance? Eow will the Commission set these standards?' 12f the fund does [' .not meet the-Commission's-standard, will the utility's shareholders be penalised? adequately evaluate a trust fund's financial performance.Second performance can be evaluated, but past performance is no Past guarantee of futare performance.

fa13 into the trap of trying-to become financial forecasters and2 fear that the predict which trust will produce the o commission really can pick the "best' ptimal return.

If the the wrong business. investments,.then we are in 2 do not oppose the Commission retaining the option to assess an investment manager's performance. Bowever, I fear that there may be a temptation for the Commission to use hindsight and second guess qualified investment professionals. Such 'finetuning' could lead to less favorable outcomes. 3 l

y a -,o -88 0298 o .The Commission's expertise lies in public utility regulation. We should stay within our legislatively' mandated sphere of authority and define very limited and carefully thought c tt standards for our periodic reviews of trust funds and thear 1 Trustees. THE ' CONDITIONS' PARAGRAPE o The third paragraph lists four conditions which appear to highlight concerns without appreciating the problems they may create. l~ L 1. Prior Approval of the Commission This restraint may act in a manner to hamstring the ability - of a Trustee to; effectively carry out his duties. It-certainly adds time to any requests and loss of. time say lead to a loss of. L _ opportunity.- Potentially, the prior approval of the Commission-L may add that amount cf time which would eliminate the reason for its. request. In' addition, since commission approval is y undertaken within the parameters of the Public Utilities Act, J l, what type of public notice, intervention, and public hearings l will be required? l 2. An Ordinary Negligence Standard Negligence is not a standard of conduct. 'It is:a kind of i conduct. According to Prosser's'Bandbook of the Law of Torts, 4th Edition, 1971, neg11gence is a cause.cf action whose elements include duty, breach of duty, proximate cause and actual loss, p. 143. The. applicable standard of conduct-is the ' reasonable man of ordinary prudence.' This standard is modified if one-has in fact superior-knowledge, skill and intelligence. Bence,.

professionals in general are required not only to esercise reasonable care in what they do, but also to possess a standard minimum.of apecial knowledge and ability.

The ordinary negligence standard created by the Commission is.a lesser standard of care than what courts would usually apply. I This provision is an example of the hastily conceived and poorly considered language which characterise the four L paragraphs. The Commission has no authority or expertise in establishing standards'for tortious conduct. 3. Commission Ability to Remove the Trustee L 4 V l.

-,~ - l. a u -1 e i 88-0298

o A' trustee.by his/her very nature is in a special relationship

urder.the Law.

The Commission's ability to remove the Trustee, as I previously mentioned, interferes with that relationship. AL 1 Trustee's primary consideration should be the affairs of the -trust, not regulatory intermeddling. + 4. Copies of.any and all notices. 3 -This Commission does not take into consideration-the cost to' trust administration. Coupled with the final paragraph added by. the majority, it is perhaps understandable. THE ' CALIFORNIA

PARAGRAPN The review of compensation rates is appropriate.

The reliance upon a California PDC decision is not. In that case, l l the California commission noted: 1 ~ We cannot-approve agreements that provide for such fees. The evidence in the record does not support the reasonableness of the proposed fees. Not only are the fees excessive but the potential trustees and investment managers also.ask for their expenses in addition to their fees, and a limitation on'their fiduciary. liability. 84 PUR 4th 13 at 30' As the above paragraph makes clear the facts.cf-that case determined the Commission's decision. In this docket, we-have no -facts.- The' compensation rates, as the majority noted, have not been explicitly set forth in the Trust Agreements. The Commission abould be wary of citing with approval, decisions of other jurisdictions, which have not been examined in 1 the record and which may contain specific approaches which the commission does not want to' adept. The California decision-sets a 10 basis point cap, a declining block schedule, and no recovery (f. expenses. Is this Commission endorsing that specific approach? If not, then what does the citation add to the order? CONCLUSION What the Consission has added in four paragraphs does not osmonstrate innovation, but is merely an example of ' tinkering." I support adoption of the proposed order as drafted by the hearing examiner. The additional language is, at best, 5 + - -. - - - - m m

~ .c 3 i se s w' i /* 88-0298- ] j surplumager and at worst, an obstruction which potentially could hinder the performence of the very decommissioning trust fund it was intended to help. Any decision to institute rulemaking should be discursed and reviewed outside of this docket.- The majority's decision-to articulate its fears and-impose restrictions may bar fuller discussion. As a final note,~1 draw attention to this commission's decision in docket 83-0537/84-0555-where we ordered a construction audit, but required the auditor not to quantify specific amounts. This example ~of ' tinkering * .more than anything else, created reversible error and diminished -public confidence. As historians have noted, 'Those who fail to . learn from the past are condemned to repeat it.' i 4 p / I l O b l i f e 6

/.~. 4F 9.. - 1 .+ J. O, i J i 88-0298 1 Commissioner stone concurring L Section 8-508.1 of P.A. 85-1400 is a timely and significant addition to the State's body of nuclear; utility' law. The fundamental importance of assuring the availability of sufficient x i funds to enable the safe and prompt decommissioning of nuclear plants at the end-of their useful lives cannot be overstated. These four orders are an excellent, and, in several ways, an-a innovative-first step by the Commission, in cooperation with Illinois's four nuclear utilities, to assure-that effective, instruments.are in' place-to accomplish-this objective. The Commission-has responded in an abbreviated' time frame ~ ith arrangements that promise strong Commission oversight of the w decommissioning trust, while avoiding inapproprate micromanagement of the utilities' own responsibilities. These orders are a beennnine and, as-the statute provides in section 4-508.1 (c) (vii;,): 'the Commission may adopt by rule or regulation such-further restrictions as it deems necessary for the sound management of the trust's funds' consistent with the . purposes of this Section." Several important issues should be considered more fully as part of the final guidelines for decommistioning trust funds. An early rulemaking will provide a forum for exploring and resolving-questions to allow full implementation of these orders. In the rulemaking process, the Commission should continue to draw upon, the espertise ofLthose state commissions with.a successful history of-nuclear trust fund oversight. Among the topics for a. rulemaking are 1. Establish search procedures and selection criteria for. l determining the qualifications of trustees. (The methodology developed by Illinois Power is one helpful example). 2. Similarly, establish procedures and criteria for selectica ei investment managers as well as determine whether the Commission wishes to require its prior approval of any such selection and, specifically, of the investment management agreement. L i l --r -ww

h ~. 88 0298 3. Develop performance standards for trustees and investment managers to enable the coraission to evaluate them ob$eetively in. determining whether retention or removal is appropriate. 4. Consider whether, and under what conditions, the Commission should review disbursements from the trusts. S. Consider whether,.and under what circumstanees, the commission should assume the power to resolve dispgtes L between a utility and its trustee. There may well be other areas which need esploration and definition. The rulemaking process should provide an opportunity to discuss and determine the most effeettve mechanisms to assure -full safeguards for the ratepayers' investment. Y The Commission should also order periodic site-specific updates of estimates for the cost of decommissirning each plant. For, not only must the money collected be wisely invested and managed, but the amount collected must be sufficient, based on res11stie, current assessments under changing conditions and costs. Whether this is handled'through the decommissioning trust fund rulemaking mechanism or by a separate ordering seehanism, it should be decided at the earliest opportunity to avoid the necessity for subsequent large ' catch-up* funding by'ratepayers. 9 / e 9 2 e

4, 1-i .-i i-i Exhibit III ,j i 1 i i Comonwealth Edison Company Edison Exhibit 15.0 1 1 Illinois Comerce Comission Docket No. 90-0169 ? Filed April 12, 1990 ) i 1 5 i 1 7687C/4

5s.own. Exhibit 15.0 i Pago 1 of 19 Commonwealth Edison Company l Testimony of John C. Bukovski i Vice President I \\ 1. Q. Please state your name and businers addrear A. My name is John C. Bukovski. My business address is One First National Plaza, P. O. ;ox 767, Chicago, Illinois 60690. l 2. Q. What is your present position with Commonwealth Edison Company? A. I am a Vice President responsible for finar.0ial ) planning. i 3. Q. Briefly describe your qualifications and background. I A. I received a BSEE degree from the University of Illinois in 1965 and in 1970 a MBA from the Illinois l Institute of Technology. I joined Commonwealth Edison ) L in 1965 and have held various positions in I engineering, division operations and the financial j l' \\ l areas of the Company. My previous position was an Assistant Vice President responsible for rate. case and regulatory economic matters. l i i ) i 4 m em e w m m- - .__,..y,...-4 ..,, _.., _., + ,,.m,.-,,

m Exhibit 15,0 I Pago 2 of 19 .g I 4. Q. Have you ever testified in other proceedings before i the Illinois Commerce Commission? L A. Yes. I testified in both Step 1 and Step 2 of Docket Nos. 87-0427, et. al., regarding alternatives to ] i traditional ratemaking treatment of Byron Unit 2 and l Braidwood Units 1 and 2 and other. issues. I testified in Docket No. 86-0249 concerning the financial impacts of cancelling Braidwood Unit 2. In Docket No. 82-0855 I filed testimony regarding rate moderation plans'.. As Director of Rates I testified in Docket No. 83-0537 l regarding Edison's proposed general increase in electric rates. When I was Director of Economic l \\ l Research, I testified in Docket No. 78-0646 which 1 related to the economics of completing our nuclear construction program. I have also testified from time o f to time on various other matters. 5. Q. What are the purposes =of your testimony in this proceeding? A. The first purpose of my testimony is to describe } Commonwealth Edison Company's method of accounting for f L end-of-life decommissioning costs of its nuclear units including the recovery of those costs through electric rates. I will discuss the evolution of the decommissioning funding methodology employed by the Company and the decommissioning costs included in the 4 -,n--+~

m,e-

_ = &Q1oon, c, - Echibit 15.0 pago 3 of 19 ^ Company's test year cost of servied for this proceeding. Second, I will show'that Byron 2 and Braidwood 1 and 2 are used and useful and that the Company should be entitled to earn a full return on its prudent investment. The three units have been operating in a base load manner since being placed in service, have already provided customers with significant savings, have been used to assure reliable ~ service to our ratepayers and have provided significant environmental benefits. Finally, I discuss the Company's sale of certain retired i fast-start peaking units in 1988. 6. Q. Please describe what is generally meant by the terms decommis'sioning and decommissioning costs. + A. Decommissioning is the safe removal of nuclear facilities from service and the reduction of' residual radioactivity at the site to a level that permits release of the property for unrestricted use and the termination of the license. The term nuclear facilities' refers to the site, buildings and contents, and equipment associated with any NRC-licensed activities. Examples of decommissioning activities would be decontamination of systems to reduce occupational exposure, controlled blasting to demolish concrete structures and removal and disposal of e ww

O

,-----r,-.,,-.-,-,,,,,,.-w-,- ..,--..w,.

m. _ __ _ - __ L*. Eshibit 15.0 i Pag 3 4 of 19 i radioactive wastes by burial. The cost of l decommissioning includes all reasonable expenditures such as labor and material costs, transportation and disposal of radioactive materials and the { site-specific factors for each unit that account for differences in plant design and construction. 7. Q. Are there'any new state or federal requirements which affect the Company's decommissioning costs? i A. Yes. In June 1988, requirements were adopted by both the State of Illinois and the Nuclear Regulatory Commission outlining the general obligations for ( decommissioning nuclear facilities particularly with respect to providing reasonable assurance that i adequate funds for performing decommissioning would be ,available at the end of a nuclear unit's life. 8. Q. please summarize the effects of these requirements. A. Until these requirements were imposed, we provided for [ decommissioning through our depreciation charges. The reserve for decommissioning was deducted _from rate base and, in effect, was assumed to earn our overall cost of capital for purposes of determining the annual accrual needed to fund decommissioning at the end of the plant's life.,We did not get an income tot deduction for the annual accrual. Today we make annual contributions to an external trust fund. We do 5

Echibit 15.0 paga 5.of-19 i o' get a tax deduction for those contributions, but tax. requirements limit the trust to very low-yield investments. The overall effort is to increase our revenue requirements by a large amount. 9. Q. What approaches are specified by the NRC to assure the safe decommissioning of a nuclear facility? A. The NRC has defined SAFSTOR, ENTOMB, end DECON I (immediate dismantlement) as the three alternative approaches to reduce residual radioactivity.to a level permitting release of the property for unrestricted I i L use in termination of a license. Under the SAFSTOR [' \\ approach, the nuclear facility is placed and t maintained in a condition that allows it to be safely I l stored and subsequently decontaminated. ENTOMB is the method in which radioactive contaminants are encased in a structurally long-lived material, such as concrete. The entombed structure is maintained and i monitored until the radioactivity decays to a 3evel permitting unrestricted release of the property. Lastly, with DECON or immediate dismantlement, structures and portions of a facility and site '5 I containing radioactive contaminants are removed or decontaminated to a level that permits the property to 4 be released for unrestricted use shortly after cessation of operations. b mm e

. - 3 &Q1 son Exhibit 15.0 i Pago 6 of 19-4 After analyzing the advantages and disadvantages of each of these alternatives, the Company has concluded that immediate dismantlement or DECON is the most appropriate method. Although this method requires expenditures of large sums of money in a relatively short period of' time, this alternative would meet the requirements for termination.of a NRC license and make the site available for unrestricted use earlier than SAFSTORlor ENTOMB. 10. Q. How did Edison provide for decommissioning costs prior. to 19887 A. Prior to the 1988 federal.and Illinois requirements referred to above, the commonly used funding options for decommissioning ^were (1) segregated fund and (2) non-segregated fund, otherwise referred to as the l external method and internal method, respectively. If ( the funds are segregated, the money is set aside as the utility collects it and is invested in relatively I safe securities. If the funds are non-segregated, they are not set aside; rather the utility places the money in its general revenue account and draws on it I to pay for current corporate expenses. This approach i enables the utility to reduce its current borrowing costs to some extent because non-segregated funds can be used to finance projects that would otherwise 4 i

4 m ca6 con 1 Echibit 15.0 page 7 of 19 q require utility borrowing. Therefore, by definition a 'non-segregated fund follows an internal method of accounting -- that is, the utility itself retains ) direct control over the collection, investment and i expenditure of decommissioning funds. Conversely, in i 1 an external fund, monies collected are invested and controlled by outside. trustees. In its final rule published in June of 1988, the Nuclear Regulatory Commission voted to eliminate internal funding reserves as a permissible method of funding nuclear lld R decommissioning costs. Prior to this regu'.ation, the H Company utilized internal funding for its nuclear decommissioning expenses. On September 12, 1988, the effective date of the Illinois statute requiring Illinois utilities operating nuclear facilities to establish external funding of decommissioning I expenses, the Company had accumulated approximately $270 million in its internal decommissioning fund l i l since the start up of its first nuclear generating l unit. l 11.- Q. What funding methods are considered acceptable for providing reasonable assurance of the availability of I funds for decommissioning nuclear reactors as defined 4 in the NRC final rule? l w ,e-we--*y.,w -w.--.- w w-w- - -e.-we a-m-y w-* -t rww=*~w-*-7-- m

1 Echibit 15.0 pago 8 of 19 A. The funding methods now considered acceptable by the NRC for providing reasonable assurance of the availability of funds for decommissioning nuclear reactor are prepayment, guarantee method and external L sinking fund. prepayment is the deposit prior to the start of operation into an account segregated from licensee assets and outside of the licensee's j administrative control. This deposit can be in the form of a trust, escrow account, or government held fund using certificates of deposit, deposits of government securities or other investments. A guarantee or surety methoi can be in the form of surety bonds, letters of credit or insurance, that l guarantee that decommissioning costs will be paid l should the licensee default. An external sinking fund is a fund into which periodic payments would be made. and whose investment earnings together with the deposits would be sufficient to pay for i decommissioning at the time termination of operation is expected. An external sinking fund may be in the + same types of accounts similar to those described above for prepayment. l Pursuant to the requirement of the Illinois statute effective September 12, 1988, the Company established two external master trust funds -- a l ,e ... ~.,

Echibit 15.0 .I page 9 of 19 j tax-qualified and a nontax-qualified fund -- to hold i decommissioning funds for each of our 12 nuclear units now in' service as well'as Dresden 1 which was retired from service in IJ85. This method of funding is consistent with the external sinking method fund j ~ prescribed by the NRC in its final decommissioning rule and was approved by the Illinois Commerce j 1 Commission in its order in Docket No. 88-0298.- ] 12. Q. What other requirement must the Company comply with as defined in the NRC final rule? J;l A. The NRC final rule requires licensees to submit by ) 1 July 26, 1990 a report containing certification that ) l reasonable assur'ance will be provided that adequate funds will be available for decommissioning. To provide this assurance the rule requires that two factors be considered, namely, the amount of funds needed for decommissioning and the funding method used. 13. Q. Are there any other related regulations with respect to the treatment for funding of nuclear i decommissioning costs? A. Yes. Section 468A of the Internal Revenue Code of 1986 as amended describes the treatment for income tax purposes of decommissioning costs deposited in tax-qualified funds for years beginning with 1984. These Internal Revenue Service regulations permit a I -. -. ~, -,,.,..

~.. ~ Exhibit 15.0 l pago 10 of 19 taxpayer to elect to deduct nuclear decommissioning costs that are contributed to an external fund subject s t to certain restrictions. These regulations also L include the prescriptive information that generally will have to be included by the Commission in future rate orders so as to satisfy the requirements governing the issuance of schedules of ruling amounts by the Internal Revenue Service. This information is summarised on Edison Exhibit 15.3. 14. Q. With respect to the Internal Revenue Service final' i regulations, what information is required to be j included in future orders by the Illinois Commerce Commission for nuclear decommissioning costs collected by Edison and depos'ted into a qualifying external fund to assure the deduction? A. As prescribed by income tax regulations, the Internal' Revenue Service will not provide Commonwealth Edison i Company (or any taxpayer in a similar situation) with a schedule of ruling amounts with respect to any taxable year beginning on or after January 1, 1987 until the Commission has determined the amount of L decommissioning costs included in the Company's cost of service. Under. income tax regulations, decommissioning costs are'not considered included in 4 the Company's cost of service unless (1) the -vev y

r E01 son Echibit 15.0 Pago 11 of 19 i. Commission' identifies the amount of decommissioning costs to be included in the Company's cost-of service in their orders or opinions or (2) the written records of the ratemaking proceedings indicate the amount of decommissioning costs to be included in the Company's cost of service. If these requirements are not included in the future orders of.the Commission, the Internal Revenue Service will not issue schedules of ruling amounts to the Company, thus precluding the-Company from taking advantage of the maximum amount allowable for decommissioning cost funding as a deduction for federal income tax purposes under Section 468A of the Code. Additionally, Edison Exhibit 15.3' lists the specific information that must be covered by the Commission in respect of l i tax-qualified nuclear decommissioning costs. 15. Q. What is included in the 1991 test year expenses for estimated decommissioning costs proposed to be l recovered from ratepayers? A. As shown on Edison Exhibit 15.1, the estimated i L. L decommissioning costs included in the Company's 1991 1 test year cost of service expenses amount to L $170,838,500. This amount reflects the annual levelized cost of service amount based on equal annual installments ratably over the remaining book life of l l

n. Exhibit 15'.0 pago 12 of 19 L' each nuclear unit of the Company, escept for Dresden 1 for which the remaining book life of Dresden 3 is used. This is the same methodology that the Commission found appropriate in its order in Docket No. 88-0298 issued December 7, 1988. 16. Q. What assumptions are integral to the development of the estimated decommissioning costs included in the 1991 test year cost of service? A. Assumptions utilised in developing the 1991 cost of service amounts are shown on Edison Exhibit 15.2. 17. Q. Please describe the major differences between the nuclear decommissioning cost of service amounts in this proceeding and that identified in the final order ICC Docket No. 87-0427. A. In Docket No. 87-0427, the $66 million 1987 test year cost-of service amount represented the amount applicable to the decommissioning component of the Company's annual nuclear depreciation rate as filed in that proceeding. It was based on the internal fund method and assumed the Company's test year after-tax rate of return of 11.11% on both prior and current collections (or deposits) from ratepayers. The Company currently has four investment f' managers managing portions of our externist fund. As of March 31, 1990, we have investments, at cost, 4

~. _ L. Edison Echibit 15.0 pago 13 of 19' totaling $239.1 million. We expect about 60% of the 1991 contribution to be deposited in a tax qualified fund and about 40% in the non-tar qualified fund. Given the investment restrictions required by federal law for these funds, as well as our recent experience, 1 i we estimate our after-tax returns (and after deducting trustee and manager fees) to be 6.07C for the tax qualified portion and 6.748% for the non-qualified funds. Nuclear decommissioning cost escalation, while not precisely calculable, is estimated to be about 6%% j j based on formulas contained in the NRC final-regulations. The estimate reflects a 32-year ] ~ l. accounting life for the last unit in service at each The ultimate cost of decommissioning each station. unit expressed in 1988 dollars and the expected year J l of decommissioning is shown on Edison Exhibit 15.2. ' The cost estimates are based on the formulas in the ) NRC rule to calculate the certification amounts that provide assurance of LJequate financial responsibility ] that the bulk of the funds necessary for decommissioning are being provided for by the utility. These cdst estimates will be provided in the decommissioning funding report to be filed by July 26, 1990 to the NRC. l l. 4 e, e,-w-* .-r-- n.,,

Echibit 15.0 page 14 cf 19 .18. Q. 'Is the Company-in this proceeding proposing any changes to the funding method or any other operational criteria with respect to its use of the external trusts as identified in the final Commission order in Docket No. 88-02987 A. No. 19. Q. Does this conclude your testimony regarding nuclear decommissioning costs? i A. Yes. 20. Q. Are Byron 2 and Braidwood 1 and 2 used and useful? j A. Yes. When the units were initially authorized in the early 1970's, the Company had the concurrence of the L Illinois Commerce Commission that the units were. going i p to be needed to provide reliable service. During the construction of the units, the Commission conducted formal reviews on several occasions and concluded that [ it was in the ratepayers' best interest to complete i construction of the facilities. The units were placed i h in service in 1987 and 1988 and at a cost that was L i L near the low and for units placed in service in a-i comparable time period. The units have been operated in a base load manner and have already provided reductions in customers bills through significant fuel savings realized by the operating efficiencies of the three units. During the hot summer of 1988, the three t ,--,-n-, w- ~ +

b-J E3hibit 15.0 Pago 15 of 19 units were needed to assure reliable service. The l j Company espects to continue to operate the units in a L base load fashion and as time passes.the capacity from all tdree units will continue to assure reliable service. 21. Q. Did the Illinois Commerce Commission take any specific 1 action before the Company started construction of i Byron 2 and Braidwood 1 and'27 ] A. Yes. The Commission authorized Byron Station in Docket No. 57941 by an order dated July 11, 1973. The I Braidwood Station was authorized in Docket No. 58339 by an order dated March 27, 1974. 1

22..

Q. Did the Commission reexamine the decision to continue i construction after the initial certification? A. Yes. As discussed in Mr. Rifakes' testimony, the Commission twice conducted formal detailed investigations of the economics of completing the l units. 23. Q. What were the findings of the Commission in these J t investigations? 3 A~. The Commission concluded that the units could be delayed without excessive effects on service reliability, but prompt completion was the most economical alternative. As a result, the Commission l 1 [ twice ordered the Company to complete the units in as i l-timely and economic a manner as possible. 4 ,,.e,.-

... e w.. Erhibit'15.0 ' pag 1 16 of 19 j 24. Q. When did the Company place the three nuclear units in service? j A. Byron 2 was placed in service for accounting purposes on April 11, 1987, Braidwood 1 on November 19, 1987, i and Braidwood 2 on August 5, 1988. 25. Q. Have ratepayers realized any benefits from these units? ) A. Yes. Tha three units have been operational for a i combined total of more than 82 months, generating more than 40 million megawatthours of electricity and saving more than $250 million in fuel costs to j customers when compared to the fuel. costs of low sulfur coal. The units have relatively low operating costs and are amongst the first units to be 5 dispatched. They, therefore, have. operated in a base l , load manner since being placed in service. 26. Q. Have Byron 2 and Braidwood 1 and 2 been needed in order to assure reliable service to customers? l l A. Yes. In the summer of 1988, all three units were i 1' needed to assure reliable service to our customers. That summer, our system experienced its' all-time peak load of 17,459 megawatts on August 17. At the time of that peak, each of Edison's 12 nuclear units was operating at or ngar full capacity, with the exception l only of LaSalle 2 which was then in coast down and operating at 259 megawatts short of summer capacity, 9 I --r-- ..--..r ..e_., m .m

Echibit 15.0 pag 3 17 ef 19 j and Braidwood 2 which was in testing and operating at 273 megawatts short of summer capacity. 27. Q. How does the Company expect to operate Byron 2 and Braidwood 1 and 2 in futuic years? A. The Company expects to continue to operate Byron 2 and j J Braidwood 1 and 2 in a base load manner. We expect j the operating efficiencies that these units have already provided to continue because nuclear fuel is expected to be more economical than fossil fuels. As j i in the past, the units are expected to provide significant environmental benefits. In 1989, our { 4 l nuclear units furnished almost 83% of Edison's system L i generation, the highest ever. Our increasing use of nuclear power has allowed us to steadily reduce fossil emissions since 1973. Given the proposed acid rain legislation, it is likely that other utilities using [ f predominantly fossil fuels will have to make j significant investments to comply with the proposed l laws. These costs will have to be passed onto the customers of these utilities in the form of higher rates. The Edison system, on the other hand and due in large part to Byron 2 and Braidwood 1 and 2, is not likely to require significant additional expenditures [ to comply with the proposed legislation. l

s.w* ova i Exhibit 15.0 l pago 18 of 19 1 I 28. Q. How should the Commission treat Byron 2 and Braidwood 1 and 2 in this proceeding? A. Given the performance of these units since being placed in service and our future expectations, the units should be found used and useful and the Company allowed to earn a full return on its reasonable investment in the facilities. 29. 'Q. What is the current status of the Company's fast-start peaking units that were installed in the period u 1968-19717 j A. In 1983, the Company removed from service for an indefinite period 17 peaking units with a combined capacity of 308 megawatts. The units were installed in the period 1968-1971 because of shortages of l capacity during a period of rapid load growth combined with unexpect'ed delays'in the service dates of the Dresden and Quad Cities nuclear units. The' fuel, operating and maintenance costs per kilowatthour of output from the units had been extremely high and they were operating very infrequently at the time. None had operated since January, 1982. In the interest of holding down expenses in a period when the capacity was not needed, required L maintenance had been repetitively deferred. In fact, I many parts had been borrowed from some of these units

Edison

. Exhibit 15.0 i pago 19 of 19 as replacements for' parts required for other units. Since the units were expected to be removed from service for a considerable period of time, in 1983 we asked and received permission from the Commission Staff to retire the units for accounting purposes. j t In 1988, the Company sold 15 of the 17 units totalling 249 megawatts of_ capacity to,various purchasers. Since the units'had been retired.for accounting purposes, were not operable, and repair was i not justifiable, any return to service was questionable at best. The Company decided it was more l economic to recover any remaining salvage value and sell them for the best price it could get. The I - remaining two units, 59 megawatts, were returned to service in 1990 basically to provide voltage control, l but 58 megawatts of peaking capacity was removed from L service because this capacity was inoperable and because repair costs could be indefinitely deferred. 30. Q. Does this conclude your testimony? A. Yes, it does. l l n 4 4 0 t --s, ,o w ~ev ,ne,,---e

r

,- 3 71 1 Edison Enhibit 15.1 b Ceco Decommissionles Fundine - 1991 Test Tear ~ Amortisation of Prior Total i l Cost of Service Collections-Contribetles t DBalifled Ilon-Oualifled Total Ison-Omelliled Amount ^ ($1000's) ($1000's) ($1000's)- (S) (8) i Dresden 1 $ 3,723.9 $11,787.9 8 15,511.8 $1,189,883 $ 16,701,683 Dresden 2 6,984.1 9,290.2 16,274.3 1,313,103 17,587,403 Dresden 3 6,984.1 9,434.0 16,418.1 1,198,109 17,616,209 Quad Cities 1 '5,637.1 6,332.7 11,969.8 826,264 12,796,064 Quad Cities 2 5,637.1 6,339.2 11,976.3 821,782 12,798,082 l Zion 1 6,352.9 6,018.3 12,371.2 919,041 13,290,241 l Zion 2 6,352.9 6,118.4 12,471.3 536,966 13,30s,2f6 l l LaSalle 1 9,489.5 3,924.5 13,414.0 324,141 13,738,141 LaSalle 2 9,964.0 3,454.7 13,418.7 211,210 13,629,910 Byron 1 8,734.5 2,565.7 11,300.2 161,300 11,461,500 I Byron 2 10,211.6 1,500.1 11,711.7

09,688 II,821,388 l

( Braidwood 1 10,211.6 1,699.7 11,911.3 17,750 11,929,050 Braidwood 2 10,536.7 1,553.1 12,089.8 0 12,089,800 t System Total $100,820.0 $70,018.5 $170,838.5 $7,929,237 $178,767,737 JCB15 ~! .~

h'. L i Edison -Eshibit 15.2 Page 1 of 2 Ceco becommisalonina Fa=Aine 1991 Test Year s knaumptions

1) Black Lung Restrictions apply to the Qualified Fund Investments and the income tas rate is 34%.

2) Decommissioning cost estimates are based en NRC minimum requirements. The-following estimates as orpressed in 19888 and the espected year of decommissioning are:

Estimate (8 Millions) Year of M Unit (19s[11__ Decommisalonine Dresden 1 135.4 2004 Dresden 2 149.4 2004 t Dresden 3 149.4 2004 Quad Cities 1 112.0

2005 Quad Cities 2 112.0
2005 Elon 1 127.9 2007 Eton 2.

127.9 2007 l LaSalle 1 157.9 2017 LaSalle 2 157.9 2017 I Byron 1 129.7 2020 l Syron 2 129.7 2020 Braidwood 1 129.7 2021 Braidwood 2 129.7 2021

Ceco Portion

3) Decommissioning cost estimates escalate at 6.54 annually until the beginning of their decommissioning year.

4) The decommissioning year is based on a 32 year accounting life for the last unit in service at each station.

t i l-l l

4 j toista Erhibit 15.2 Page 2 of 2

5) Qualified and non-g'ualified contributions are deposited March 15 and september 1 each year, beginning in 1991, respectively. The final year.of funding for each unit is as follows:

Flaal Year of Final Year of Dualified Funding Mon-Ouallflod Fundine Dresden 1 2003 2003 Dresden 2 2003 2003 Dresden 3 2003 2003 j Ouad cities 1 2004 2004 Quad cities 2 2004 2004 Elon 1 2006 2006 Eion 2 2006 2006 j LaSalle 1 2014 2016 .LaSalle 2 2016 2016 l Byron't - 2017-2019 Byron 2 2019 2019 Braidwood 1 2019 2020 Braidwood 2 2020 2020

6) The. level of contributions assume that a revised tan ruling amount is submitted to the IRS to update authorised ruling amounts and increase l

funding into the Qualified Fund. l'

7) calculation of Qualified and Non-Qualified Funds' after-taa, after-fees investment earning's rates are based on the projected returns and asset allocations provided by Michael Simon, Investment Dept. on March 22, 1990. The annual Quallflod fund interest rate is 6.074, and the Non-Qualified Fund interest is 6.748%.

9 4 6 9 9 9' e h JCBIS

-~ . _ -. - ~ - - m ) Edison Exhibit 15.3 i Page 1 of 2 l 1 Commonwealth Edison comoany i Information Required to Be Covered by a Rate Order For Tar-Oualified Nuclear Decommissionino Conte (1) A description of the proposed method of decommissioning the nuclear unit,' for example, prompt removal / dismantlement, entombment, or mothballing; (2) The total estimated cost of decommissioning the unit l expressed in current dollars, that is, based on price i levels in effect at the time of the ratemaking proceeding; (3) The total est$=ated cost of decommissioning the unit expressed in future dollars, that is, projected to the year (s) in which decommissioning expenses are expected to be incurred; i (4) A description of the methodology used to convert the e current estimated decommissioning cost to the future estimated decommissioning cost; (5) The years in which decommissioning costs are expected to be incurred and the estimated (future) decommissioning g cost for each year in the period; (6) The after-tax rate of return assumed to be earned by amounts collected for decommissioning; (7) The years in which decommissioning costs for the nuclear i t unit are projected to be included in the Company's cost of service and the projected amount that will be included for each year in the period; m

9 Ediscn Exhibit 15.3 J Page 2 of 2 ) (8) The estimated date on which it is projected that the ) nuclear unit will not be included any longer in the Company's rate base for ratemaking purposes, as determined in the most recently completed ratemaking proceeding; (9) A description of any engineering or cost studies that were-i relied on by the Commissions in determining the amount of decommissioning costs to be included in the Company's cost of service; g (10) The frequency of contributions to a nuclear i decommissioning fund for a taxable year; and (11) A schedule of the amount of decommissioning costs to be i included in the Company's cost of service. i f i i f -t i 4 JCB14 h -wes,- ~ w- ,.v,---,

o 6 Exhibit IV Estimated Cost of Decommittionina Dresden Unit 1 The attached nuclear decommissioning cost estimate was prepared by i Thomas S. LaGuardia in November-1985 to quantify the preliminary decommissioning plan for Dresden Unit 1 previously filed in NRC Docket No. 50-010. The total cost for prompt dismantling of $97 million (see page 33 of 66) is expressed in 1985 dollars. This estimated cost was converted to 1986 dollars using an inflation rate of 6.5% and was converted to 1988 - dollars using the formulas prescribed in 10 CFR 50.75(c)(2). The resulting 1988 cost estimate of $121.8 million is less than the $135.4 million estimate made in accordance with 10 CFR 50.75(c). The higher amount is being used in our current funding proposal filed with the Illinois Commerce L Commission on April 12, 1990 (Exhibit III). 7687C

r-4 t 4 .i ;, ' t;

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D00' ment C84-25-801 2 4 Page 1 of 66 .i i ( 1 I p c i ') DECOMMISSIONING STUDY e for the DRESDEN NUCLEAR POWER STATION UNIT 1 i Prepared for COMMONWEALTH EDISON COMPANY L November,'1985 ) Approved by: D A mme F Thomas S. LaGuardia P.E. l t e e i ,. - - -,,.,,. _..,., ~ -.,.,.,.. -..,,, ..y. ~ -y

? n DRESDEN NUCLEAR POWER STATION COMMONWEALTH EDISON UNIT NO.1 s a .Ahg.O A^ ^^ 1 ^ g. ^- ik ^ ., u.a._.& ..,,,y -- -gm_,,,_. 7.,, y \\'ZeM1M =" * %W. l. 12 iG 7b 4eamer i 4,%%p F, n .x 4w.W.3 3N.y.g. mate _. M a... i s._ ~~ 'M ,,e- ,N "'. g * ' g, er me .,- =x weite 3Ja. _ 3 ,s s s s., p d. Q% . 'E "M l i , aMS* N f, g %. a s,_. p 4 ? s, L' ~ s ~ 4% + 3 = ~:s A-2n en e

(;jy. ( -si {. q ' 1 '[o/ Dacument-C94-25-981 lY Page 2 of 66 t TABLE'0F-CONTENTS 7

l*

l. SU MMARY '2. INTRODUCTION 8. ' 2.1. Objective of Study 8' 2.2 Regulatory _ Guidance 8 2.3 Electric Utility Position on Decommissioning 10 2.4 Other Regulatory Positions 19 3. DECOMMISSIONING ALTERNATIVES DESCRIPTIONS 11 3.1 Prompt-Removal / Dismantling 11 3.1.1 Period 1: Preparations 3.1.2 ' Period 2: Decommissioning Operations 3. l'. 3 Period 3: Site Restoration and-License Termination 3 '. 2 Mothballing'with. Delayed Dismantling 16 -3.2.1 Mothballing Operations 3.2.2 Mothballed Dormancy 3.2.3 Mothballed Delayed Removal / Dismantling 4. COST ESTIMATE 20 4.1 Basis of Estimate 29 -'4. 2 Methodology 29

4. 3 -

Site-Speci fic - Considera tions 22 -4.3.l_ Major Component Removal-e 4.3.2 Transportation' Methods 4.3.3-Site. Conditions at Facility Closeout 4.4 Assumptions 25 4 4.5-Cost Estimate Summary 33 ti j% SCHEDULE ESTIMATE 59 5. RADIOACTIVE WASTE VOLUME 53 OCCUPATIONAL EXPOSURE-54 i: CONCLUSIONS 56 0 9. REFERENCES 58 ILLUSTRATIONS- ' Figure 1.1 Site Plan 5 1.2 Cutaway of Reactor Enclosure 6 1.3 Schematic of Steam Generation System 7 4.1 Sketch of Reactor Vessel and Internals 23 4.2 . Sketch of Fuel Handling Pools 24 4.3 Sketch of Steam' Generator 26 4.4 Sketch of Steam Drum 27 APPENDICES A Unit ~ Cost Factor Development 59 B Unit Cost Factor Listing 63 Revision Log 66

= ( $cC1 1 N9 ' _f; s i[ ' lof ? + D:cument C04-25-881 4. ~ u? Page 3 of 66 a i o

1.

SUMMARY

t L LThe Dresden Nuclear Power Station Unit 1 (Dresden 1) is located 993 acre site near the confluence of the Des Plains and the .en a Kankakee Rivers about 50- miles southwest of Chicago in Lake //.

County, Illinois.

It is the first.of three units on the site, l sithough significantly different in design than Dresden Units 2=:& ,jf"(' -3. This first generation, turnkey, demons.tration plant was the first full-scale privately financed nuclear. power plant in the L U.S. The Nuclear Steam Supply System (NSSS) is a dual cycle L boiling lightwater moderated and cooled reactor with forced-l! circulation. It has a rated thermal output'of 700 MWth and a l unit rated electrical output of 207 MWe..The reactor containment

structure is a freestanding spherical structure in the form of a sphere.

Dresden Unit 1 produced power commercially from

July, d

1960 to October 31,

1978, generating'approximately'15,800,000 MWhr of electricity.

Figure 1.1 shows the site plan,; Figure. 1.2 shows a cutaway of the Reactor Enclosure and Figure 1.3 shows'a ) i schematic of the Steam Generation System. This study provides

cost, schedule, waste management and radiation -exposure estimates for decommissioning Dresden 1.,These i

estimates are provided for two alternative decommissioning methods: prompt removal / dismantling, and mothballing with delayed dismantling. The cost estimate is presented in 1985. dollars and 1 i does not include taxes-(other than property taxes), interest, or monetary escalation. ' Prompt removal / dismantling of a power reactor consists of removing from the site all fuel assemblies and source material, radioactive fission and corrosion

products, and all other radioactive materials having activities above unrestricted activity levels.

For.this study it is assumed the spent fuel can be removed; from the site to a federal repository. The reactor g , vessel and internals must be removed. with remote tooling. The t i. facility operator may then have unrestricted use of the site with no requirement for a license. If the facility operator se i ' desires, the remainder of the reactor facility may be dismantled and all vestiges removed for disposal. l l Mothballing consists of placing and maintaining the facility in -protective storage. Typically, all fuel would be removed from the site, but for Dresden 1 the fuel will be temporarily stored in the fuel storage pool until a federal repository is available, Initial mothballing operations would consist of general plant decontamination activities, radiation surveys, the processing and removal of any radioactive waste materials, securing a L . possession-only

license, and the implementation of

security, surveillance and maintenance plans for the delay period.

Delayed ) dismantlement activities would be initiated after 30 years and would-consist of radiation surveys, removal of all radioactive ) plant components, systems and structures, processing and removal of all solid and liquid radioactive wastes, and restoration and release of the site for unrestricted use. l

.--7 -+,, ,g: iX5!'ni ?' - j' e i Decument C94-25-SS1 ) e 8 ? Page 4 of 66i i The~ cost-and schedule estimates presented; :in this=. report are: based; on the complete removal ofL all' radioactivity-and the- > dismantling.'and disposal of.all generating, equipmen t and-2 structures.. The total-cost in 1985. dollars including a 250 contingency is:shown in Table 1.1. The costs in Table 1.1 are. summaries.taken from the detailed cost tables 4.4 and 4.5 and ' schedule information from Table 4.2.. g TABLE.1.1 ( H~ -COST AND SCHEDULE ESTIMATE

SUMMARY

l s Cost +, S Schedule-(Thousands) Months .. Prompt' Removal / Dismantling 96,613,980 72' '[

Mothballing-with 39 Year Dormancy-

i-sand Delayed Dismantling Initial operations 6,796,999 12 4

l-30 years maintenance cost 12,584,199 360 i Delayed dismantlementi 89,296,899 66-Total' 198,676,999 Ili i i.' 1 J i h-b ov

,.i, --4 4 : g

s Dscument C84-25-981:

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j i~ D$cumentiC84-25-881 i j, i Page 6 of'66 m .t FIGURE 1.2 . CUTAWAY VIEW OF REACTOR ENCLOSURE i; 1* 1u-EMERGENCY CONDENSER di 4- 'f POISON STORAGE - N N TANK PRIMARY STEAM i DRUM -- V Q, s .2 i ) ] 6- ,/ Lg s K ll k 8 h.'. %.[ ( r c ?y@,,?..,..$s.. s,.. - -)s x-u 5 i h, ,o h"/sNb#h -E. 6' ,4 U 'h SECONDARY 4 \\ C CENERATOR 'l' STEAM, t J- 'k Np .h Q...y,yjV j. M*= mAM >.. : J. ' g* *,,/ REACTOR . :r}. SECONDARY STEAM ,A SECONDARY FUEL TRANSFER TURE i FERDWATER PRIMARY sasswATsa o.

9

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~.... -. ..:.,:, m. v, v ' T. -a D3cument C94-25-901 1 Page'7.of:66 w o _. FIGURE: 1.3'- i i SCHEMATIC OF STEAM GENERATION SYSTEM \\' i i ^ i o 10 ~ ATWOSPHERE .i s + 4 i EWER 0ENCY C - LIQUID " " " '9 SON SYS.. IP CONDENSER l t___] r. _ _ _ _ _ _ _ _ _ _ + _ ;=R v e .h A PRlWARY STEAM f, 4 , ORUW n 3 g 3 r II - a PRlWA RY FEE 0 WATER RISERS 9\\ [0 DOWNCOMERS

REACTOR l'-

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e ,+ f >4 Document C94-25-981 . n. W Page 8 of_66 2. INTRODUCTION L2.1 _ OBJECTIVE OF STUDY The. objective of.-this, study was to prepare an estimate of the costs,. schedule, occupational-exposure and waste volume -generated to decommission the Dresden facility. The alter-natives evaluated were promptsremeval/ dismantling, and safe storage with mothballing end: delayed dismantling. The costJ estimate will provide Commonwealth Edison Company (CECO) f eith.the ' cost basis to perform a_ financial analysis estimating __ the ' ' present cost of decommissioning the nuclear plant..The decommissioning-occupational _ exposure and waste volume -estimates are included-to show how they compare to exposures and waste volumes generated during plant operations. . 2. 2 ' REGULATORY GUIDANCE i The U.S. Nuclear _ Regulatory Commission-(NRC)' provided. decommissioning guidance-in Regulatory Guide 1.86 (Ref. 1). This. guide . defines four-decommissioning alternatives acceptable 'to the. NRC including mothballing,- in-place Lentombment, -removal of radioactive components and dismantling, and conversion to -a new nuclear system or a fossil' fuel = system. Removal / Dismantling consists of r.emoval from the -site. of all fuel and. rad.ioactive fluids and all other_ materials having activities -above, accepted unrestricted activity levels. The facility ' owner may dismantle for disposal-all remaining vestiges of.the site. Mothballing consists of putting the facility in protective storage by. removing all fuel'and radioactive waste from the site. Adequate radiation monitoring, environmental-surveillance and appropriate security procedures should_be established under a possession-only license to protect public health and safety. Entombment consists of putting the facilit in protective possession-only license, y storage under a as in the case of mothballing, and sealing all remaining radioactive or contaminated components (e.g., pressure vessel and reactor internals) within a structure integral with the primary containment. The structure should provide integrity for the period the radioactive inventory remains in entombment.

^ ~~ ~ ~ ~ i g g,,, .s-lg li Dscument C64-25-8811 Page 9 of 66

Conversion useslthe existing turbine generator system with aft a.

new steam: -supply. system. The original nuclear steam supply system and other radioactively-contaminated components Land systems.would be removed and disposed of by-one-of the. previous three decommissioning alternatives.- The new NRC Proposed. Rules' (Ref. 2), and the-report ,i 'NUREG-0586 "Draf t Generic Environmental Impact Statement" 'j (Ref. 3) does not considar conversion as a true decommissioning alternative. It is considered to be an alternative use for the turbine generator system after decommissioning by-one of the other alternatives. The:NRC has used new terminology in the Proposed Rules for the previously described-alternatives. liothballing is called SAFSTOR, entombment is ENTOMB and removal / dismantling is DECON. In this

study, the Regulatory Guide.l.86 decommissioning alternative terminology will be used.

The NRC Proposed Rules allow dismantling following SAFSTOR to be delayed for periods up to approximately 30 years to-permit the principal. exposure radionuclide, Co-60 -(5.27 year' half-life), to decay, to-lower levels. This delay ' i,s expected to significantly reduce occupational exposure levels. The NRC Proposed Rules preclude the Entomb alternative h unless the reactor internals are removed. However, the ? Rules note that it would be quite difficult to actually demonstrate.that a remaining entombed inventory will decay to levels permitting unrestricted' release of the property within_ 100 years. This would require continued surveillance-i . indefinitely (tens of thousands of years) and a virtually infinite total cost. Accordingly, for this study TLG p excluded entombment and assumed.a mothballing with 30 year i (or more) delayed dismantling scenario for consideration. This delay would allow Dresden 1 to be ~ decommissioned at p' approximately the same time as Dresden 2 & 3. Since the Dresden site is a fully manned operating power-station, there will be appropriate security measures in effect for the duration of the dormancy period of Unit 1. The NRC published the Proposed Rules in the Federal Register on February 11, 1985 with the final ruling expected to be issued by mid 1987. These proposed rules indicate that the NRC will require utilities to perform a site-specific decommissioning study of their units or use $100 million dollars (1984) as the estimate to remove the radioactive L portions of the plant; select an alternative for decommis-L sioning their facilities; submit a preliminary decommission-ing plan including techniques the utility will use to facili-tate the decommissioning process, (reduce exposure and waste l volume); and establish the cost and methods for collecting

11 - i u- ,w. 3 Dscument C04-25-991L Page 10 of 66 t funds tol finance the program. -The additional effort- ' f required by each utility to respond to these new regulations 'will' be the; preparation of site-specific -decommissioning plans-and ' cost estimates for each nuclear. unit and=the selection, of 'a financing method to accumulate funds, n i 2.3-ELECTRIC UTILITY POSITJON ON DECOMMISSIONING ~ The electric utility industry has recogni=ed. the need to provide . adequate ' funds' for decommissioning. and has; established-some precedent with respect to the methods .. y proposed for decommissioning. In-general, the' industry followed the-lead-of -recent US NRC ' staff positions . recommending DECON (Prompt Removal / Dismantling) as the il proposed decommissioning alternative. The NRC Draft-Generic. p Environmental -Impact-Statement has shown-DECON to be the lowest cost-alternative to comply with the decommissioning-L objective to; terminate the license. Furthermore, -DECON s takes advantage of the availability immediately following - l shutdown of plant operations personnel who are intimately knowledgeable of-the plant equipment and-systems. These plant- ' systems,

cranes, hoists, and radwaste processing systems have been;well maintained and are. operable for' use during decommissioning, i

\\ A recent survey-performed by the Edison Electric Institute and th'e American ' Gas Association (EEI/AGA) (Ref. 4) of 30' electric utilities showed 73% of them used the ~ prompt removal / dismantling method in their funding plan for l '. decommissioning. 2.4 -OTHER-REGULATORY POSITIONS l State public utility commissions have concurred with the Prompt-Removal / Dismantling (DECON) alternative as the-basis for establishing a fund. The aforementioned EEI/AGA survey L showed 97% of the surveyed utilities were successful in i ' obtaining acceptance by the regulatory agency of the [,, preferred plan, company 1 i,' l 6 -4

. y ". " *1' e Decument-C94-25-901 Page 11'ofH66 3. ' DECOMMISSIONING ALTERNATIVE DESCRIPTIONS-4 Two specific decommissioning alternatives are-reviewed for the Dresden 1 study:. Prompt Removal / Dismantling and Mothballing with Delayed Dismantling. For the Mothballing' alternative, a delay or dormancy period of-20 years. is assumed. Although they differ s ' with respect to time, technique,' cost, and environmental impa c t, these alternatives. attain-the same final result:. removal of all m radioactive materials from the site and ultimate release - of the site for unrestricted pae. The following sections describe' the basic activities necessary for-each alternative.

Although' detailed procedures for each~

activity required are not provided'here, and actual sequences of work may vary, these activity descriptions should. provide a basis for detailed engineering planning and scheduling of decommission-t ing. L 3.1 PROMPT REMOVAL / DISMANTLING 3.1.1 Period ~1: Preparations

1. Engineering and Planning Prior to final plant

shutdown, the utility should' begin to identify; specific plant personnel who will be retained on-site -for the decommissioning project.

These-personne1' will be responsible for project -management, health and safety, administration, quality assurance, and security. During this, preshutdown period, the: ' utility will= identify and collect the necessary documentation,

records, vendor manuals and drawings needed.for the detailed engineering and planning for decommissioning.

In preparation of License Documentation, regulatory criteria applicable to decommissioning must be reviewed. The existing technical specifications must be reviewed and modified to reflect the decommissioning requirements and to delete nonapplicable operating specifications. The NRC is requested to issue a' possession-only amendment to the i operating license. A decommissioning plan is then prepared. In

addition, an environmental impact assessment may be required.

Much of the work in the development of the Decommissioning Plan is also relevant to the development of the detailed engineering plans and procedures; these will include: e "-r =m

i s. p: y '" q >: w 6, ., ;, ) ' Document;C94-25-091 'Page 12 of'66-li-l 1 Detailed procedures and sequences. fort - removal; of- ,y systems-and components. l

' Procedures-for. sectioning. and: disposal 'of

-the reactor vessel and-its internals Plans for decontamination:of structures and' systems:

~

1

Design, procurement, and testing-of special

~! 1 - equipment T i LN

- Identification and selection

'of specialty ' contractors ~ in

' Procedures for removal and disposal of radioactive

+1t materials Site . preparation plan's for-decommissioning: -[ L.- . activities L Sequential planning of activities to. minimize; 1, conflicts with simultaneous activities (

2. Site Preparations Immediately following final plant shutdown. and in-2 !

preparation for actual decommissioning' activities, the ~ following jobs should be done: N 7

. Prepare site support and storage facilities as 1

required. g3 @[ 1 Rem'ove and' dispose of all : fuel; and any-source materials. Control blades -cannot be removed'at ~t s$ this~ time as they are necessary'for removal' of 4the L. hydraulic control rod drive units; however, the pfF cost for disposal of the blades is not allocated to i" the decommissioning costs. This activity may be t carried 'out by existing plant personnel in accordance with standard operating technical: pf! specifications. 4 y-um Clean all plant areas of loose contamination and ,f g. process all liquid and solid-wastes. y p Conduct radiation surveys of work area contamination and general dose levels; major component,

piping, and structure dose levels (including the reactor vessel and its internals);

internal piping contamination levels; and activation composition and contact dose levels of N primary shield core samples. L. K 5 e s n-.

, gag * < +: e x g e ~ Dacument C94-25S891"

~

,Page--13 of)66-L L.

- Calculate residual byproduct material-inventory 'for-ip

plant components, structures-and. systems,f"and normalize. neutron flux profiles to survey dat'ac for

! development of-packaging and shipping requirements j andidecommissioning : safe ty 1 requirements. + Determine shipping container requirements for activated materials.and-fabricate. k' . Develop-procedures 'for occupational exposure.

control, control and. release of liquid 'and gaseous effluents, control of. solid radwaste,o si ce, security and emergency. procedures, and industris1: safety.

f Following-' receipt of the possession-only, license amendment from the NRC, the reactor will be disabled by deactivation /deenergizing of control. rod ' drive mechanisms and the modified-technical-specifications will:be~ implemented.. - 3.1.2LPeriod 2: Decommissioning operations 'The dismantling procedures may begin upon receipt of the. dismantling-order-from the NRC. For the, Prompt-Removal / Dismantling-alternative, the decommissioning

operations will involve the'following:

' Construct temporary facilities and arrange -existing storage

-facilities-to support the dismantling ' activities. 'These may include: changing rooms and lE (" hot" laundry for increased work force;: protected 'and open.laydown areas to facilitate equipment removal and: shipping operations;. additional roads to facilitate hauling and transportation; and an additional' air-locked access hatch to facilitate D' entrance into the reactor building for large/ heavy equ i pmen t.. Dispose of-all hazardous and toxic wastas. Design, procure, and install water cleanup system for removal of cutting residues and crud deposits from the reactor vessel segmentation operations. i , ).. a Design and. fabricate special shielding and contamination control envelopes; special tooling and remotely operated equipment; modification of present spent fuel pool to support segmentation activities; and rigging for segmentation and w removal of piping sections and' components, including the reactor vessel and its internals. Procure required shipping

casks, liners, and Low Specific Activity (LSA) containers from suppliers.

eweI i ev.

i. g Decument C94-25-9914 l .Page 14 of-66: i Drain,fflush, remove, ship and dispose-:of piping and components, as - they are no longerErequired to: p supportiother decommissioning activities. Conduct decontamination-of components' and piping systems as required _ 3 Remove control rod drive housings and. instrumenta tion-tubes 'from reactor-vessel loweri head; and: section as required for ' shipping and ,1 burial'.- Cut vessel-closure head for shipment and burial-in j steel LSA: containers. i 'q L Segment the steam deflector

support, the turning-l L

vanet assembly and guide posts and package in ^i shielded; casks. These operations will be performed i by remotely operated equipment: within contamination d control 1 bar rier (s). Ship and bury packaged items.- q L Disassemble,Esegment and package remaining reactor l internals' ' including the top. grid guide; assembly, l bottomLcore support assembly, bottom core support-l thermal

shield, inner water. seal and diffuser:

basket' assembly'in special underwater shielded ~i shipping seasks. The operations ~ are conducted j underwater.using remotely operated tooling and a 4 contamination control envelope. or other contamination-barrier (s). Ship and bury packaged. 1 items. t Cut and package reactor vessel into shielded k p containers. This operation is accomplished in air l using.. remotely operated equipment within a-l contamination control-envelope. Sections will be placed in containers under water (for

example, in the fuel; handling canal) or may be done in air with crane operator-by shielded envelope.

Ship and bury-pa. protected ckaged items. Remove concrete biological shield including activated / contaminated concrete by controlled demolition.

Package, ship and bury radioactive portions.

Decontaminate exterior surfaces, as

required, and seal weld all openings in the steam generators.

Cut piping and remove steam generators for shipment and burial. These components can serve as their own burial containers provided that all penetra-tions are properly sealed. Decontaminate remaining reactor building areas including steam generator cubicles.

49 w.

W W,.. \\ E. ~ Document C84-25-951 ( I Page 15 of.66-w ~ plant sys'tems and associated. components ~! Remove-E according Lto the sequence - established in the' decommissioning activity specifications.

~ Perform radiation survey to assure th'at: remaining

] portions .of the-reactor buildingt;are freen of: 1 surface contamination-and that containment-1 integrity is noLlonger required. Demolition of the remaining portions of the-containment structure and^ interior portions of the 4 reactor building can now be-accomplished. . Internal floors (and.~ walls if above grade) are removed from- 'I the-lower levels upward, using controlled blasting techinques. Concrete rubble and 'other suitableL . materials'can be used on-site for fill; otherwise. the - rubble will-be trucked off-site to a local landfill. i Remove.all remaining-concrete-in - Reactor Building-l by controlled-blasting to three feet below grade. Torch-cut'and remove the Reactor sphere steel. for disposal. Remove remaining

Turbine, Fuel

Handling, Fuel p

Storage, Off-Gas and other-buildings and structures p

containing radioactivity in a.similar manner after-radioactive materials .and equipment have been '1 removed.. In addition, outside storage tanks; should be drained,. decontaminated. where required, -and L removed. Usei radiation and contamination control techniques until radiation surveys. indicate the i a areas are clean. Ship and bury all remaining radioactive-marerials.. i Conduct final radiation survey to assure that all radioactive materials -have been removed. This i survey may coincide with final'NRC site inspection. 3.1.3 Period 32. Site Restoration and License Termination L Following completion of the decommissioning l L operationd, site restoration activities may begin. These involve demolition and removal of the following operations: Remaining structures may then be removed using conventional' -demolition techniques for above ground structures, including the Stack and all remaining yard structures. The Switchyard and torers will remain in service as part of the CECO power grid. o + e --r t mm. mm - - .- m .a - a

4. o, ?

l s aq M' ) 13 j Document C94-25-991-1 H Page 16 of 66 1 1 a '.All building foundations will. be backfilled using; noncontaminated concrete rubble with a granular s Lfill surface. Site. areasi 'affected by the-u dismantling activities will-be cleaned up and the 3 ',. plant site will be graded and landscaped-as i i riq t required. 1 A final, dismantling program-report will be. prepared and: submitted to the

NRC, along with a request for 4 <

-j termination of the possession-only license.. Following NRC approval of. this

request, the license will be terminated and the site

.may-be released for unrestricted use. H 3.2 MOTHBALLING WITH DELAYED DISMANTLING The Mothballing decommissioning alternative represents ~ the g' minimal ' effort required to provide a condition that ensures public health and safety from residual radioactivity remain-ing-at the site. While the "mothballing" was originally used to describe this alternative, it is a misnomer' since this is.a permanent condition and reactivation of the plant is not J intended. The facility is-left essentially. intact and all structures are maintained-in a sound condition. All systemsfnot required to be operat'ional for maintenance and surveillance purposes during the dormancy period-are- . drained, deenergized, and secured. Minimal cleaning / removal of loose contamination and/or fixation and sealing of remain-- ing contamination is performed. All access to contaminated areas are sealed and/or secured to provide controlled access for-inspection and maintenance. -ij The engineering and-planning requirements are -similar to those required for

the Prompt Removal / Dismantling alterna-tive althoogh a

shorter time period 1s expected. Site preparations are also similar to those described for dismant-- ling alternative.

However, with the' exception of required radiation surveys, the mobilization and preparation oof site facilities is less extensive.

3.2.1~Mothballing Operations Following receipt of the Possession Only

License, the modified technical specifications will be implemented.

Spent fuel and in-core source materials will be stored L in-the storage pool on-site until a federal repository l is available for disposal. These steps may be done by j plant personnel in accordance with standard operating i: l b L 1

3; i t p.) -Document C04-25-901 'i: - r /*

Page 17 ofR66 l

L procedures. All other liquid and solid wastes will be. I +- r processed-and-removed-andiplant radiation surveys will-be made.- i The' decommissioning activities for the Mothballing alternative will be as follows: Drain, deenergize, and secure all noncentaminated systems.. r Remove filter elements and resin beds for shipmen t - and burial. i Drain reactor vessel. Reactor vessel: internals j will remain in, place.

Drain, deenergize, and secure 'all contaminated systems (excluding the fuel pool).

Decontaminate as required. m 39 Prepare lighting and alarm _ systems as reg' ired :for. u continued use. De-energize and/or secure portions 1 3 of electric

power, HVAC and other systems: _not required for continued use.

j. Clean-loose. surface' contamination from-building- . access pathways. Perform final radiation survey of plant and _ post-warning signs as appropriate. Erect physical: barriers and/or secure all: access to a radioactive ' or. contaminated areas,_.except as' ~ y' required for controlled access for inspection and maintenance. Prepare the fuel pool for temporary fuel storage. 'T Cover pool with wire mesh on framework to-prevent debris from falling into pool. Relocate .any [y componen ts adjacent to the pool that could conceivably fall into the pool. m Install security and surveillance monitoring j-equipment and relocate security fence around secured stnucturas,as required. a ~ Prepare final decommissioning program report for submittal to NRC. = ~

,fA z D$cument C64-25-891: h Page 18 of;66 1 3.2.2 Mothballed Dormancy Act'ivities required during the planned 30-year ? dormancy

period, for the Mothballing alternative, J

L1 include. a 24-hour guard.

force, preventive-and j

L corrective maintenance on- . safety: 1 systems, area: b lighting, general building-maintenance,' heating. and ventilation of buildings, routine. radiological inspections of contaminated: buildings,- maintenance of L structural integrity, -and an environmental.and e radiation monitoring program. Maintenance of-the fuel pool water chemistry and-y -support systems will be performed, however'these costs are part of fuel operations costs and not included in i theidecommissioning costs. 4 1 1 Maintenance and equipment inspection activities are provided-by the full time utility maintenance-staff. Their duty is tot maintain the building in.-a safe condition, provide adequate lighting, ventilation, and heating;'and perform periodic preventative maintenance on essential equipment. An environmental surveillance program is carried out during the dormancy period to prevent releases of . radioactivity to the environment. Any releases should be identified and. quantified. Appropriate emergency procedures should be'- established.- An environmental surveillance- -program willL generally-be .a modified /abbroviated version of that carried on during . normal plant operations. q. Security during the dormanpy period is primarily

conducted to prevent unauthorized entry and to protept the public from the consequences of-their'own actions.

Security detection and notification systems used during plant operations are augmented by the installation of audible alas.as. Full-time securityDis provided by the adjoining'Dresden Units 2&3 security force throughout the mothballed dormancy. Primary physical security is provided by the site's 24-hour security force for the duration of the dormancy period. The facility will also be secured by high security locks on exterior doors and intrusion alarms. Fire and radiation alarms will be monitored continuously by security personnel. n t ~ -. ...-..m. e-

r.i' t ..t' j

,. :y:

m ' 'L ep p .D3cument C04-25-991 l Si Page1191of'66. _i 3.2.3 Mothbs11ed Delayed Remo,v,,al/ Dismantling At the' end of the dormancy period for the Mothballing alternative-(assumed -to be. 30 years),: the-same. dismantling-operationsasthose described for. the. l ': Pr ompt' Dismantling alternative' would be performed. The. remaining considerations.are the same as: those. of delayed removal / dismantling from entombment. 1, p ( b l lu J'c l 1 11 \\ l 4 '1 A l

t q 4 Document 084-25-881' o d Page 29'of 66 i 4. COST ESTIMATE t A site-specific costLestimate was prepared-for Dresden 1 to account. for the unique features of the nuclear steam supply. . system, electric power generation

systems, site buildings and structures.

The-basis for the estimate, including the source of: information, methodology, assumptions and' total

costs, will be

'i described in this section. 4 '.1 BASISHOF ESTIMATE o The site-specific cost estimate was developed using' Dresden 1 drawings and the inventory documents provided by CECO. These drawings and documents were used to identify the general' arrangement of the facility and to' determine estimates of building. concrete volumes, steel quantities, numbers and size of-components, and land area of the site restored. L> The decommissioning effort is a labor-intensive program. . Representative, labor rates for each geographical region and each craft or salaried ' worker are essential for the development of a meaningful site-specific decommissioning 4 L cost estimate. CECO provided typical craft labor rates and o salary data-for administrative personnel from recent labor ) contracts and CECO personnel payroll records. Rates for shipping-radioactive wastes for burial were L provided by Tri-State Motor Transit (Ref. 5) published [ tariffs for-this cargo. Transportation. costs have escalated L rapidly in .the past few years-and recent rates must be'used p for' accurate' site-specific cost estimates. ef Burial costs for radioactive wastes have increased approximately 15% in the last year. The availability of burial sites are of national concern, with regional compacts being formed to provide adequate burial' space for operating L and -planned reactors. -For this study a hypothetical regional burial facility assumed to be located within'500 miles of the.r:esden 1 site was used for cost estimating purposes. Actual burial rates from an operating burial ground (Barnwell, SC) were used to approximate the actual rates for this hypothetical site (Ref. 6). Table 4.1 L summarizes the cost basis for this study. 4.2 METHODOLOGY The methodology used to develop the cost estimates follows the basic approach presented in the AIF/NESP-909 study report, "An Engineering Evaluation of Nuclear Power Reactor Decommissioning Alternatives" (Ref. 7) and the USDOE " Decommissioning Handbook" (Ref. 8). These references

si 'L ^ + ' ,o: U Dccument C94-25-991' il

79.,

Page 211of 66 4 t TABLE.4.1 d ? o

SUMMARY

OF COST BASIS E l'. Dresden 1 plant drawings, equipment and structure inventory. 2. CECO employee salary and craft labor rates for site administrative, operations, maintenance and outside contractor personnel.

3.

Engineering services rates were estimated at $60/hr. q 4. Material and equipment costs for conventional demolition or construction activities were taken from R.S. Means (Ref. 9). S. Rates for shipping radioactive wastes for burial were. provided by Tri-State Motor Transit in published tariffs for this cargo. 6. Burial costs'for the regional burial ground were obtained-from Chem-Nuclear Corporation in t Barnwell,SC (Ref. 6). .s 7. All costs in this estimate are'in 1985 dollars. j f 8. -This estimate excludes taxes (other than property =i taxes), interest and escalation. I l[' use a unit cost-factor metho'd for estimating. decommissioning p activity costs to simplify the estimating calculations. Unit cost factors for concrete removal (S/cu yd) steel removal (S/ ton) and cutting costs (S/in) were developed from the labor and material cost information provided by CECO. p With-the item quantity (cu

yds, tons,

inches, etc.)

developed from plant drawings and inventory documents, the activity-dependent costs were estimated. The activity duration critical path was used to determine the total decommissioning program schedule. The program b schedule is used to-determine-the period-dependent costs for program management, administration, field engineering, equipment -rental, quality assurance and security. CECO provided typical salary and hourly rates for personnel p associated with period-dependent costs. The costs for I conventional demolition of nonradioactive structures, materials,~ backfill, landscaping and equipment rental were obtained from R. S. Means. Examples of development of unit e

.o w

Dccument C94-25-081 Page 22 of 66' cost factors are presented. in. the. US' DOE Decommissioning

Handbook.and are-reproduced in Appendix A.

Appendix B lists. . g~ 'theLspecific' factors developed for the Dresden 1 analyses.- j .The' activity-fand period-dependent: costs were summed to deve-o lop the total decommissioning costs. An additional 25% con-l tingency was added-to allow for unpredictable program problems. For the purposes of this study, the costs and con-tingencies were allocated evenly across each of<the periods.. TLG believes the unit cost factor method -provides a ' demon-strable basis for establishing reliable cost estimates. The detail of activities provided in the unit-cost factors for act.ivity time. labor costs. (by craft), and equipment and j consumables costs provide assurance that no cost elements have been-omitted. :These detailed unit cost factors coupled-with the plant-specific inventory of piping, components and-t structures provide a--high degree-of confidence in the reliability of the cost estimates. 4.3 SITE-SPECIFIC CONSIDERATIONS- ~ L I -There are .a number. of site-specific considerations that affect the method for dismantling and removal of-equipment from-the site and the degree of, restoration required. The cost impact of these. considerations identified herein are included in this cost study. S L4.3.1 Major' Component Removal .The reactor vessel and. internals will be cut into ~to fit existing shielded shipping casks. The segments [ segment. size and number *of segments per cask are selected to. comply with expected curie limits per shipmen t, weight limitations, and allowed maximum cask curie and weight license limits and external radiation levels. All vessel and internals cask - shipmen ts will be made in. US DOT approved truck casks. Figure 4.1 shows a sketch of the; reactor vessel and internals. Figure 4.2-shows a sketch of the fuel handling pools that will be used to remove the segmented vessel-and internals. 1 L Reactor. recirculation piping will be cut from the i reactor vessel. The reactor recirculation pumps will be lifted out intact, packaged and shipped via truck for disposal. The four steam generators will be decontaminated m internally and externally as required, and all piping penetrations will be seal welded closed. The steam generators will be . removed in one piece and transferred to a railcar for shipment to the burial e i f. I '. -L.:

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e., - f; Dscurant C64-25-881; ,o Page 24 of 66 e. . FIGURE 4.2' ~ SKETCH-0F FUEL HANDLING POOLS 1 S-FUEL RACK CARRIER 3% FUEL RACM s/ / TRANSFER TUSE l lJ '- ) _ Eg c l O 1 it_. I B ~ d l R. - ) L - J \\, -. t / -/ ~ D I l l FUEL HANDLING CRAF. / l-d [i \\ }N " %&',0 '. L1 j x FUEL RACK SASKETa-SEAL FUEL BASKET GATE VALVES. 1 CARRIER L o, l O f f

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gl' Dtcu Ont C84-25-8811 j

ji:." \\ ji Page 25;of 66: L. ground. The steam generator shell will: serve as.its ' own ~ burial. container. ~ Figure <4.3 shows a sketch:of a j) E steam generator. l ) The steam-drum. will-be-simi'larly decontaminated. internally and externally as required, and all piping i penetrations seal welded closed. The steam drum will be. segmented ~.into four sections to facilitate rigging ~ and removal. Each section will be prepared for' i removal.by seal welding cover plates over.the ends, i h and lifting l lugs' welded to the.shell._ _The sections-0 H will-be lowered to the equipment hatch elevation and ~ + . transferred through the airlock. .A mobile crane. outside' the_ sphere. will, lower the sections.to grade-and transfer them to a railcar. The drum shell will serve as its own burial container. Figure 4.4-shows a' il , *a sketch of the steam drum. L The main turbine will be dismantled using conventional B maintenance procedures; the turbine" rotors and shafts R' will be packaged as LSA waste and-shipped for controlled burial. The lower turbine' casings will'be removed from their anchors by controlled demolition-andL shipped' as-LSA waste for controlled burial. The main condensers will be segmented and packaged in standard' waste containers and shipped for controlled p burial. E4.3.2 Transportation Methods m For the0 purposes of-cost estimation, it was assumed i o that-'the main turbine sections would have to. be transported for burial by rail. The RPV ' lower head _ ill also be shipped by railcar, with the main package w turbine sections. 4.3.3 Site Conditions at Facility Closeout It.is assumed that the site -will be restored by ,c regrading to conform to the_ adjacent landscape. Sufficient topsoil will be replaced to permit regrowth 1 of native vegetation. Underground piping and tunnel structures will b'e demolished:by collapsing the piping with explosives and the resulting trenches will be backfilled. 4.4 ASSUMPTIONS Table 4.2 lists the assumptions made in the development of the cost estimates for Dresden 1. l . ~.

i r <4 1 ;4 w

D:cument C64-25-881-A Page.26:of 66 s

FIGURE 4.3 Ji ' SKETCH OF~ '1 ' ~ ~ " . STEAM GENERATOR: i + W ~ ~., - g } 3 j -l i ~ l.y ,y 'l v 'y^ o. 1 [ j l j.; I 1 ,\\ t w s %= O e

N,-., .1 ' Document C64-25-881' 5,; ~ Page"27l.of.66 i . riouRE 4.4 I -[ '] EEEoEs .6 ..c t gy { i = ~, " W5 $,f W.a# - Gg;L i t G NCg 9 w } I sitAM ~ DROM / 7__ gg ____--g g-OnAtNS DISTRISUTOR 80X \\g % c. e M\\ ,,,,,L a WaxTURE / - #N 7tmNAL CQNNCCTION AtSER l i i e o e s -w-

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) 9 La c l 'N Decument'C64-25-881 i Page 28 of 66; i '1 TABLE 4.2 1 ASSUMPTIONS s L 'l. 'The utility and De:ommissioning Operations Contractor- (DOC). H staf fs ~ for single shif t. operation are assumed to be:

o Altern/ Program

~ Mgat Craft Total Period-Months Organisation Labor Labor Personnel-g 1 Prompt Removal / Dismantling 1;1 Prep. 1-6 Utility 5 0 5 7 Utility 5 9 15 '4=- 12 DOC 41 63 194 e

2. Decom. 13 - 54 Utility 5

0 5 Oper. DOC 37 61~ 98 .i 3..Dismt. 55 - 72 Utility 5 0 5 -Rmng. DOC 19 28 47 .Struct. j Mothballing Close 1 - 12 Utility 2.5 -0 2.5 p DOC -27 c16 43 2. A hypothetical. burial site at' approximately 599 miles distance was' assumed as the final destination 'for all-radioactive: waste shipments from Dresden .l. Burial. rates for.this _ hypothetical site were taken from the Barnwell SC rate schedule. 1 - 3. _ Nuclear liability insurance includes liability insurance for damages or injuries from equipment,

material, etc. used during decommissioning and/or-radiation exposure.

LNuclear liability 't asu rance - is terminated after final decontamina-tion:of the site.- Builders risk insurance.is included in. subcontract labor costs. i The 'NSSS (reactor vessel and recirculation piping and 4. valves) will be chemically _ decontaminated.using one chemical. 4 1 ~' flush.and two. water rinses prior to component segmentation for removal'. Typically, a decontamination factor (DF) of'19 is' expected =(Ref. 8 En 19). ~ 5. Minor scrap amounts will be generated during decommis-sionirg. However, these small amounts are not included as a salvage credit line item in this study because: (1) the scrap value merely offsets the associated site removal and + y 4 --n,..,,

7:

Dorsent C64-25-991 Page 29 of 66 j TABLE 4.2 cont'd. scrap reprocessing costs, (2) scrap has .a relatively low value in the

market, (3) the salvage market for heavy equipment is uncertain, and (4) the salvage market for l

alectrical equipment is limited. The scrap processing and site. removal costs are'not included in the estimate. 6. The reactor vessel and internals disposal costs are based on remote segmentation in-place, packaging in casks with shield-

ing, and truck shipmen t to tt.e burial ground.

A maximum normal roadweight limit of 73,280 pounds was assumed for all vessel segment shipments. This includes vessel segment (s), e supplementary shielding, cask tie-downs and tractor trailer. The max, mum curies per shipment assumed permissible for burial is 47,999 curies based on the license limits of avail-able shielded shipping casks. The

number, size and curie content of segments were selected to meet these limits.

7. All contaminated

piping, components and structures other i,

than the reactor vessel and internals meet DOT limits for l LSA material. The main turbine and reactor-vessel lower E head package, steam generators, and steam drum were assumed shipped by rail, i 8. Noncontaminated underground piping (except the

intake, discharge, and circulating water piping) will be abandoned withcut special considerations.

The plant intake and-i discharge and circulating water piping and tunnels will be collapsed and backfilled to eliminate the potential for subsidence after the site is released for unrestricted use. 9. The decommissioning activities will be performed in [ accordance with the following regulatory documents: 19 CFR 29 Standards for Protection Against Radiation 19 CFR 39 Rules of General Applicability to Licensing of Byproduct Materials L 19 CFR 49 Licensing of Source Material la CFR 50 Domestic Licensing of Production and Utilization Facilities le CPR 51 Licensing and Regulatory Policy and Procedures for Environmental Protection 19 CFR 61 Licensing Requirements for Land Disposal of Radioactive Wastes i 19 CFR 79 Domestic Licensing of Special Nuclear L Material i 29 CFR 1919 Occupational Safety and Health Standards 1 49 CPR 170-189 Department of Transportation Regulations Governing the Transport of Hazardous Materials

l Document C64-25-881 Page 38 of 66 TABLE 4.2 cont'd. ) i A12 environmental regulations in force in 1985 will be in I force during decommissioning effort. l 19. Plant conditions & construction: Insulation materials used throughout station may contain asbestos and will be removed prior to dismantling. I Transformers and capacitors may be filled with oil containing PCB's. The PCB's will be removed prior to-l' dismantling.

11.. Dresden Unit 1 will be isolated electrically from the rest of the CECO system and decommissioned completely!

i.e., the i station will be out of service prior to commencing the demolition effort. l 12. CECO will furnish outside electrical power required to l demolish the station. 13. No equipment will be salvageable as used equipment. All equipmen t will be worn, obsolete and suitable for scrap as - deadweight quantities only. 14. CECO will remove all items of furniture,

tools, mobile equipment such as forklifts,

trucks, bulldozers, other similar mobile equipment and other such items of personal property owned by CECO that is easily removed without the use of special equipment.

Not included is equipmen t and i items affixed to buildings or building fixtures by means of

bolts, welding, cement or other means of permanent attachment.

15. The future Ceco project team assigned to the decommissioning i effort will investigate the economics of reusable construc-1 tion materials, 1 i 16. Fuel 311 tanks will be emptied by using their contents as fuel'in the auxiliary boiler. i l 17. Fuel oil tanks will be cleaned by flushing or steam cleaning l as required to demolish in a safe manner. I l 18. Acid and caustic tanks will be emptied by normal usage. 19. Lubricating and transformer oils will be drained and removed from site by waste disposal vendor. 29 CECO will contract with a Decommissioning operations Contractor (DOC) who will be the demolition project manager and 'shall provide sufficient staff to perform the S

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0 g

+ i Do;tment C64-25-Ofl Page 31 of 66 TABLE 4.2 cont'd. preparatory demolition planning and scheduling and to manage the demolition efforts. site security during demolition will be provided by CECO or its subcontractor. The demolition work wi,11 be performed by a demolition subcontractor to the

DOC, who will be provided adequate

staff, labor, equipment, materials and overhead to complete i

the demolition. 21. The railroad spur into the station will be maintained for use during the decommisssioning project. l ? 22. Existing warehouses will remain for use by the demolition j contractor and its subcontractors, as well as CECO. 23. All-above grade structures will be removed to 3 feet below l grade level. i i 24. The station grounds will be graded to conform to the adjacent landscape and will be planted with grass for l erosion control. 25. L The switchyard will be left intact for use by CECO for the i electrical distribution system. l 26. Piping and electrical manholes will be backfilled with a suitable earthen material and abandoned. 27. Vertical pump structures and sumps will be backfilled with a suitable earthen material and abandoned. 28. Water drain holes will be drilled in the bottom of all below grade structures to be abandoned by burial. i 39. Subaqueous intake structures will be abandoned without special consideration. 31. Structures will be backfilled to grade level 1 32. Culverts and headwalls wi'11 remain in place to allow natural drainage. 33. Transmission towers will remain in place, i 34. Rip-rap remains in place with earth cover. i 35. All manholes will be filled with soil in place. 36. The perimeter fence location will be moved as appropriate to conform with the technical specifications in force at the various stages in the project. l i )

3 I Document C84-25-081 l l Page 32 of 66 i TABLE 4.2 Cont'd. 1 37. All road and parking area base material remains in place. 38. All road and. parking areas with asphalt surfacing will be removed and the area covered with fill and landscaped. 39. All concrete road and parking areas will remain in place and the area covered with fill and landscaped. 48. All gravel road and parking areas will remain in place and the area covered with fill and landscaped, i I

41 The railroad will be removed to intersectior tith main

line, t

and ballast remains in place with earth coi L 4 i I e b 9 I .=

i D Cument C84-25-881 Page 33 of 66 4.5 COST ESTIMATE

SUMMARY

A summary of the decommissioning alternative costs in 1985 dollars for. each period is shown in Table 4.3, including a 25% contingency. Tables 4.4 and 4.5 show the detailed listing and costs of major activities for each decommission-ing alternative. Note that "Decon", as used in the headings of these

tables, refers to decontamination.

It should be noted that " Total," as used in the heading of Tables 4.4 and 4.5 is the-sum of Decon, Remove, Pack, Ship and Bury as.well as other miscellaneous items not listed (such as engineering and preparations, nuclear liability insurance, plant energy budget and DOC staff relocation expenses. i TABLE 4.3

SUMMARY

OF DECOMMISSIONING COSTS (Thousands of Dollars) .: 2 Alternative Months

Est Cost, $

Prompt Removal / Dismantling + Period la Preparations 12 11,615 Period 2: Decom Activities 36 65,916 Period 3 Structure Dismantling 24 19,983 Total 72 96,614 Mothballing/ Delayed Dismantling Mothballing 12 6,796 Dormancy (30 years): 369 12,584 s Delayed Dismantling: 66 89,297 Total. 438 108,677

All costs are in 1985 dollars and include 25% contingency.

Columns may not total due to roundoff error. l^ l.

z ,.c s . ~.. TABLE 4.4 COST ESTIMATE FOR PROMPT REMOTAL/ DISMANTLING: Dresden Unit-1 (THOUSANDS OF 1985 dollars) i Activity Decon Remove Pack Ship Bury Total Cu Td Serap M-hrs M-Rem PERIOD 1 1. Remove fuel & source material n/a i 2. Decon plant & process waste a 3. Review plant dwas a spees. 276 4 Perform detailed red survey a i 5.1 Estimate by-product inventory t 60 5.2 Computer time 10 i 5. Total 70 6. Submit for possession-only license 96 7. End product description 60 l l 8.1 Detailed by-product inventory 78 I 8.2 Computer time 10 8. Total 88 i i 9.1 Define major work sequence ~ 450 l 9.2 Computer time 4 9. Total 454 10.1 Perform safety analysis 186 I 10.2 Computer time 5 1 10. Total g 191 o c 11. Submit dismantling plan 12. Receive possession-only license 31 1 j. 13. Receive dismantling order a o er j a o = Subtotal Period 1 Activity Costs 1266 YIu o vi = i .m ee e e NOTES: "n/a" indicates that fuel handling, packaging, shipping, and disposal are charged to i plant operations, not decommissioning "a"' indicates that costs are included in the utility staff oosts. j - All costs are rounded; columns may not total due to roundoff error =. - _.., _.. _... _.. _.. _, _ - _. _.. ~.. _... _.... _ _ _,.. _ _ _. - -..... - _ - _ _.. _... -.

. x,.:~~.= m 7 + 9(,

es.

TA8LE 4.4 (Continued)' COST ESTIMATE FOR PROMPT REMOVAL / DISMANTLING: Dresden Unit.1 y Activity Decca Remove Pack Ship Bury Total Cu Yd Serap M-bra M-Ree Period 1 Undistributed Costs 1 Decon equipment -21 21 i 2. Decon supplies 21 21 i 3. Staff relocation expenses 91 4 Process 11guld waste 51 19 50 434 555 538 643 2 5. Nuclear liability insurance 72 6 Property taxes-460 7. Health physics supplies 143 143 8. Disposal of contaminated solid waste 10 4 81 95 100 738 2 9. Plant energy budget 463 ) Subtotal Period 1 Undistributed Costs 42 195 29 54 515 1921 639 1381 3 i l DOC Staff Cost 5773 Utility Staff Cost i 332-Subtotal Staff Costs for Period 1 6105 TOTAL PERIOD 1 COST 42 195 29 54 515 9292 639 1381 3 i PERIOD 2 Activity Specifications 14.1 Plant & temporary facilities 295 14.2 Plant systems 250 14.3 Reactor internels 426 14.4 Reactor vessel 390 O 14.5 Sacriricial shield 30 E 14.6 Moisture separators / reheaters 60 14.7 Reinforced concrete l 96 w a 14.8 Turbine & coudenser 14.9 Pressure suppression structure 250 E e, 120 14.10 Primary containment Q 96_ w' 14.11 Plant structures & buildings 187

b 14.12 Waste management 276 14.13 Facility & site closecut 54 e

14 Total 2530 t = -

l TABLE 4.4 (Continued) COST ESTIM&TE FOR PROMPT REMOVAL / DISMANTLING: Dresden Unit 1 ? Activity Decon Remove Pack Ship Bury Total Cu Td 3ers, M-hrs M-Ree ~' t Planning & site Preparations 15. Prepare dismantling sequence 144 16. riant prep. & temp. suces 1005: 17. Design water clean-up system 84 18. Rigging /CCEs/ tooling /etc. 851 19. Procure casks / liners & containers 74 Detailed Work Procedures 20.1 Plant systems 284 } 20.2 Yessel head. 14 20.3 Reactor internals 240 20.4 Remaining buildings 81 20.5 CRD housings & ICI tubes 60 20.6 Incore instrumentation 60 20.7 Removal primary containment 120 20.8 Reactor vessel 218 20.9 Facility closecut 72 20.10 Sacrificial shield 72 20.11 Reinforced concrete 20.12 Turbine a condensors 60 250 20.13 Moisture separators & rehesters 120 20.14 Radweste building 164 20.15 Reactor buildine 164 20. Total 1979 [ c Rock Removal 21. Remove spent fuel rocks 243 15 14 5 186 464 223 8771 53 l [ Nuclear Steam Supply System Removal I 22.1 Recirculation System Piping & Yalves 62 627 97 99 1097 1983 970 26801 317I -l 22.2 Recirculation Pumps & Motors 15 40 20 8 48 131 55 2336 31, o* 22.3 Steam Drum 26 30 4 26 110 1% 125 1954 22e e 22.4 Steam Generators 33 2837 124 216 123 3333 109 98511 988 22.5 CRDMs & ICIs Removal 40 3 9 to 82 145 55 1202 22

4 22.6 Reactor Yessel Internals 44 1082 55 179 743 2103 91 10060 32m

= 22.7 Reactor Vessel 83 18 % 126 115 256 2477 297 10060 32

22.

Totals 304 6515 436 653 2459 10366' 1701 150925 1444 = - - .--n c. . ~. - = ~.. -

TABLE 4.4.(Continued) COST ESTIMATE FOR PROMPT REMOTAL/ DISMANTLING: Dresden Unit 1 ~, Activity Decon Remove Pack Ship Bury Total Cu Td Serap W hrs WSee Removal of Major Equipment 23 Main Turbine / Generator 269 502 206 774 1751 834 407 9293 18 24. Main condensers 179 138 39 16 316 688 391 5098.. 9 Disposal of Plant Systems 25.1 Rx Enc Drn Tnks & Fuel Handig Trtant 7 116 8 3 63 197 78 4632 13 25.2 Radweste C1ctr Tnk/Fitr/Weste Demin Tnk 6 111 8 3 62 189 77 4371 36 i 25.3 Waste Neutra11zer & Secadry SG Weste Tk 3 60 6 2 45 116 56 2373 2 25.4 Turb Bldg F1r Drain Tnk & Laundry Weste 139 8 3 64 215 80 5207 14 25.5 Liquid Waste Storage & Holdup Tanks 284 13 5 103 404 127 10650 269-25.6 sludge Hndis/ Resin Storage / Waste concent 4 78 5 2 37 127 46 3128 41 25.7 River Water 47 47 102 1855 1 1 25.8 service Water 52 52 ~ 218 2049 25.9 Cooling Water 77 77 230 2978 l 25.10 Well Water 153 153 158 5859 25.11 Fire 33 33 72 1300 25.12 Air 20 20 127 786 25.13 Plant Heating 120

20 338 4644 i,

25.14 Fuel & Lube Oil 43 43 51 1672 25.15 Chlorine a 5 5 9 190 25.16 Cleanup & Condensate Demineralizers 138 23 8 181 350 224 5199 57 25.17 Reactor Enclosure Air Conditioning Water 16 43 59 181 2346 25.18 Control Rod Hydraulics 452 15 6. 122 595 151 16696 247 i 25.19 Turbine 72 18 12 314 415 389 2729 9 1 25.20 Main steam & Condensate 892 204 92 2439 3627 3023 33851 88 S i 25.21 AC Auxiliary Power (clean) 13-13 40 502 g 25.22 AC Auxiliary Power (contaminated) 3 <1 <1 5 8 6 109 <1 g 25.23 Instrumentation & Control (cles;) 174 174 484 6817 a 25.24 Instrumentation & Control (contaminated). 161 13 5 105 284 130 6332 83 25.25 Miscellaneous RCS 88 24 6 134 253 166 3351 231 e n i 25. Totals 36 3376 344 147 3673 7576 4551 2011 129645 1015 w I Decontamination of Site Buildings 26.1 Reactor Enclosure 401 166 31 13 253 865 314 21528 99

E l

26.2 Turbine Building 51 2 <1 18 73 23 1%5 7 ** 26.3 Fuel Handling Building 5 <1 <1 2 7 2 192 1 26.4 Fuel storage Building 45 42 2 <1 16 105 20 3116 26. Totals 502 208 36 15 289 1050 358 26800 107 Subtotal PerioJ 2 Activity Costs 1264 10522 1372 1041 7697 28563 8060 2418.330533 2646 i i, w --.u.e,- .,w m-. e .4 -,-,,n. m,-,wn,--y --...n-- -.w.- >.a, ,--~u ,,,,n-_,--s

TABLE 4.4 (Continued) COST RSTIMATE FOR PROMPT REMOVAL / DISMANTLING: Dresden Unit 1 ~,- Activity Decon Remove Pack Ship Bury Total Co Yd Scrap M-bre M-Ree Period 2 Undistributed Costs } 1. Decon equipment 64 64 2. Decon supplies. 62 62 3. Staff relocation expenses 272 .e 4 Process liquid waste 154 58 150 1303 1665 1615 1929 5 5. Nuclear liability insurance 318 6. Property taxes 1380 7. Health physics supplies 429 429 8. Heavy equipment rental 390 390 9. Pipe cutting equipment 397 397 10. Disposal of contaminated solid waste 30 12 243 286 301 2213 6 11. Plant energy budget 926 Subtotal Undietributed costs Period 2 126 1371 88 162 1546 6190 1916 4142 10 a I DOC Staff Cost 16264 i Utility Staff Cost 996 Subtotal Staff Costs for Period 2 17260 TOTAL PERIOD 2 1390 11893 1460 1203 9243 52013 9976 2418 334675 2656 l PERIOD 3 Removal of Building Cranes j 27. Removal of all b1dg cranes 30 30 60 228 l Demolition of Remaining Site Buildings o i E 28.1 Reactor Enclosure 5920 5920 3862 176703 g i i 28.2 Turbine Building 1363 1363 467 38656

s 28.3 Fuel Handling Building 272 272 34 7929 3

28.4 Fuel Storage Building 12 12 22 336 e n j 28.5 Circulating Water Intake 4 4 10 123 w 28.6 Stack 1 92 92 1455 h i 28.7 Miscellaneous Site Structures 23 23 19 560 gy i 28. Totals 7685 7685 4414 225763 e Site Closecut Activites EO l 29. Backfill Site 429 2342 i 30 Grade a landscape site 216 2081-31 Final radiation survey 32. Final report to NRC a 94 I 33. Terminate possession-only license a- .. ~ - ~ ~

-e TABLE 4.4 (Continued) COST ESTIMATE FOR PROMPT REMOVAL / DISMANTLING: Dresden Unit 1 Activity Decon Remove Pack Ship Bury Total Cu Yd Serap M-brs M-Nee Subtotal Period 3 Activity Costs 7715 8454 4474 230414 Period 3 Undistributed Costs ' '3 1. Nuclear liability insurance 53. l 2. Property taxes 1150 l 3. Heavy equipment rental. 260 4. Plant energy budget 463 ~ Subtotal ?eriod 3 Undistributed Costs 1926 3 DOC Staff Cost 5226 i Utility Staff Cost 380. Subtotal Staff Costs for Period 3 5606 TUTAL PERIOD 3 7715 15986 4474 230414 TOTAL COST TO DECOMMISSION 1432 19803 1989 1257 9759 (77291110615 6891 566470 2660 1 { TOTAL COST TO DECOMISSION WITM 255 CONTINGENCT: $ 96.613,980 TOTAL RADWASTE VOLUME BURIED: 10,615 CU TDS ~I TOTAL SCRAP METAL REMOVED: 6,891.4 TONS l l' TOTAL CRAFT LABOR REQUIREMENTS: 566,469.9 MAN-MOURS O i O l s TOTAL PERSONNEL RADIATION EXPOSURE: 2,659.8 MAN-REM I l m v i E 1 e n j e w

a 99 9

1 u o vi } EE NOTE: () This cost includes $28,971.020 for Utility & DOC staff periods 1-3 costs and $14,580,030 ror engineering and preparations, property taxes, nuclear liability plant energy budget, and staff relocation expenses. l .-_c..;~__._.-_....._..____....__

... = = G. ,1 -,q,;, TABLE 4.5 3 =. COST ESTIMATE FOR MOTHBALLING/ DELAYED DISMANTLING: Dresden Unit 1 (THOUSANDS OF 1985 DOLLARS) ~ ~, - ' Activity' Decon Remove Pack Ship Bury Total Cu Yd Scrap M-hrs M-Nem PERIOD 1: Mothballing Activities 1 1. Remove fuel & source material 2. Review plant dwgs & specs. ~ n/a ~ 19 3 Perform detailed rad survey a i 4.1 Estimate by-product inventory 10 ~ 4.2 Computer time 2 4 Total 12 ~ 5. Submit for possession-only-license 60 6. End product description 10 7.1 Detailed by-product inventory 38 { 7.2 computer time 10 7. Total 1 48 8.1 Define major work sequence 8.2 computer time 60 4 8. Total 64 9. Perform safety. analysis of operation 43 10. Perform safety analysis of end product 43 11. Submit dismantling plan 60 i 12. Receive possession-only license o a ~" Activity Specifications l i 13.1 Prepare plant and facilities for mothbal as a 60 13.2 Plant systems 60 8 13.3 Plant structures and buildings Q ~' 60 13.4 waste management 120 h 13.5 Facility and site dormancy 120 13 Total $7 4 420 m. ) NOTES: "n/a" indicates that fuel handling, packaging, shipping, and disposal are charged to 1 plant operations, not decommissioning "a" indicates that costs are included in the utility staff costs. - All costs are rounded; columns may not total d0e to roundoff error , - -, +. .,. ~,,, .n,..a-, ..----n-,-.nn-

x. ..-v

;.},_

TABLE 4.5 (Continued) ~. COST ESTIMATE FOR MOTHBALLING/ DELAYED DISMANTLING: Dresden Unit _1 Activity Deoon Remove Pack Ship Bury Total Cu Yd Scrap-M-bre M-Ree Detailed Work Procedures 14.1 Plant systems 60 1-14.2 Facility closeout & dormancy 14 Total 50 120 15. Procure vacuum drying system 6 [ 16 Drain /de-energize non-cont, systems a 17. Drain & dry RSSS a 18. Drain /de-energize contaminated systems a 19. Decon/ secure contaminated systems f 20 Prepare support equipment for storage a 194 3000 3 Decontamination of Site Buildings 4 21.1 Reactor Enclosure 75 75 3127 15 21.2 Turbine Building 42 42 1742 6 i - 21.3 Fuel Handling Building 4 4 170 1 21.4 Fuel Storage Building 9 i 21 Totals 9 -377 4 129 129 5416 22 s 22. Perform radiation survey 23. Secure building accesses a a 24 Prepare & submit final report 35 Subtotal Period 1 Activity Costs 129 1264 8416 25' O O l 0 4 C 4 m W 8 9 O I i M a 64 S St >=.

-.--,c,.--7.- I ,.j TABLE 4.5 (Continued) COST ESTIMATE FOR MDTNBALLING/DELATED DISMANTLING: Dresden Unit 1 ~, Activity Decon Remove Pack Ship Bury Total Cu Td Serap M-hrs M-Nee Period 1 Undistributed Costs 1 Decon equipment 64 64 2. Decon supplies 55 55 3. Process liquid waste 15 6 15 127 162 157 188 <1 ,. 4 Nuclear liability insurance 72 5. Property taxes 460 l 6 Health physics supplies 143 143 7. Disposal of contaminated solid weste 10 4 81 95 100 738-2 8. Plant energy budget 463 Subtotal Period 1 'Jndistributed Costs 119 158 16 19 208~ .514 257 925 2 - DOC Staff Cost Utility Staff Cost 2493 166 i Subtotal Staff Costs for feriod 1 2659 TOTAL COST TO MOTMBALL 248 158 16 19 208 5437 257 9341 27 l TOTAL COST TO MOTMBALL WITH 255 CONTINGENCT: $ 6,795,972 TOTAL MOTHBALLING RADWASTE YOLUME BURIED: 257 CU TDS ] TOTAL SCRAP REMOVED: 0.0 TONS i TOTAL CRAFT LABOR REQUIREMENTS: 9.341.1 MAN-MOURS TOTAL PERSONNEL RADIATION EXPOSURE: 27.2 MAN-REM E% i I a ee n j O j ~ EY .l e e. es e i i NOTE: () See final page of this table for explanation of development of this cost i d .~ =

. ~. = x.- TABLE 4.5 (Continued) COST ESTIMATE FON MOTNBALLING/ DELAYED DISMANTLING: Dresden Unit 1 Activity Decon Remove Pack Ship Bury Total Cu Td Scrap M-hrs M-Nem PENIOD 2: Mothballed Annual Maintenance Cost 1. Quarterly Inspection s 2. Semi-annual environmental survey s 3. Prepare reports s 4 Health physics supplies 10 5. Nuclear. liability insurance 1 6. Maintenance supplies 52 7. Plant energy budget 61 8. Site maintenance staff 47 9. Licensing /aupport staff 225 i FERIOD 2 ANNUAL MAINTENANCE TOTALS 396 SUBTOTAL MAINTENANCE COST *FOR 30 TEARS DORMANCY: $ 11.894.150 l + Balance of property taxes for remaining four years following mothballing: 690 TOTAL MAINTENANCE COST FOR 30 TEARS DONMANCT: $ 12.584,150 b O i .o r o C i I. .E l e n w 's H i .o en - l E E i 5 j NOTE: "s" indicates that the cost is included in the utility maintenance staff cost. j _ _ =, _ m

TAst.E 4.5 (Continued) COST ESTIMATE FOR MOTMBALLING/ DELAYED DISMANTLING: Dresden Unit.1 - *~ 4 Activity. Decon Remove Pack Ship Bury Total Cu Yd Scrap M-bra M-Res FERIOD 3 r 1. Review plant dwgs & specs. 276 2. Perform detailed rad survey a [ 3. End product description 60 i l 4.1 Detailed by-product inventory 78 l 4.2 Computer time 10 4 Total 88 5.1 Define major work sequence 450 5.2 Computer time 4 5. Total g$, 6.1 Perform safety analysis 186 6.2 Computer time 5 6. Total 191 7. Submit dismantling plan 31 -8. Receive dismantling order a -l Subtotal Period 3 Activity Costs 1100 Period 3 Undistributed Costs I 1. Staff relocation expenses 91 .E i 2. Nuclear liability insurance <1 Q. l 3. Health physics supplies 143 143 g 4 Disposal of contaminated solid waste 1 <1 8 10 10 74 <1 5. Plant energy budget -231 3 Subtotal Period 3 Undistributed Costs 143 1 (1 8 475 10 74 <1 e n DOC Staff Cost 5773 L Utility Staff Cost 332 o Subtotal Staff Costs for Period 3 6105 1-TUTAL PERIOD 3 COST 143 1 <1 8 7680 10 74 <1

~ TABLE 4.5 (Continued) COST ESTIMATE FOR MOTHBALLING/ DELAYED DISMANTLING: Dresden Ostt 1 Activity Decon Remove Peek Ship Bury Total Cu Yd Scrap M-bra M-See PERIOD 4 Activity Specifications ~ 9.1 Re-activate plant & temporary facilities 442 9.2 Plant systems 250 93 Reactor internals 426 9.4 Reactor vessel 9.5 sacrificial shield 390 30 ~ 9.6 Moisture separators / reheaters 60 9.T Reinforced concrete' 96 9.8 Turbine & condenser 250 9.9 Pressure suppression structure 120 i 9.10 Primary containment 96 9.11 Plant structures & buildings 187 9.12 Waste management 276 9.13 Facility & site closeout 54 9. Total 2677 Planning & Site Preparation 10 Prepare dismantling sequence 144 11 Plant prep. & temp. swees 1125 12. Design water clean-up system 84 i 13. Rigging /CCEs/ tooling /etc. 952 14 Procure casks / liners & containers i 74 Detailed Work Procedures E' i 15.1 Plant systems 284 15.2 Vessel head .t 14-15.3 Reactor internals g. 240 w a 15.4 Remaining buildings 81 15.5 CRD housings & ICI tubes 60 e 15.6 Incore instrumentation g 60 15.7 Removal primary containment 120 d: 15.8 Reactor vessel 218 15.9 Facility closeout 72 ta i 15.10 Sacrificial shield 15.11 Turbine & condensors 72 $) i 250 15.12 Moisture separators & reheaters .i 120 15.13 Reinforced concrete 60 15.14 Radweste Building l 164 15.15 Reactor building 164 15. Total 1979 . ~

I .o -TABLE 4.5 (Continued) -~ COST ESTIMATE FOR MDfNBALLING/ DELAYED DISMRETLIIE: Dresden Weit 1- {' Activity Deeon Remove Pack Ship. Bury-Total' Cu Td Serap M-hre M-See Rock Removal 16. Soent fuel racks 15 14 5 186 221 223 591 <1 Nuclear Steam Supply System Removal 17.1 Rectreulation System Piping & Valves 62 627 97 40 783 1609 970 26801 16 17.2 Recirculation Pumps & Motors 15 to 20 8 42 125 55 2336 2 17.3 Steam Drum 25 30 4 26 108 193 125 1954 1 v 17.4 Steam Generators 33 2837 124 216 114 3323 109-98511 49 --? ~ 17.5 CRDMs & ICIs Removal 40 3 9 4 50 106 55 1202 1 l 17.6 Reactor Vessel Internals 41 958 52 137 427 1615 86 8160 5 ~ 17.7 Reactor Vessel 83 1906 126 115 252 2483 297 !*60 5-17. Totals-301 . 6401 433 545 1775 9455 1696 147125 79 ~ Removal of Major Equipment 18. Main Turbine / Generator 269 502 2c5 774 1751 834-407 9293 18 19. Main Condensers 179 138 39 16 316 688 391 5098 9 i Disposal of Plant Systems 20.1 Rx Enc Drn Tnks & Fuel Handig Trtant 7 116 8 3 63 197 78 4632- <1 20.2 Radwaste C1ctr Tnk/Fitr/ Waste Demin Tnk 6 111 8 3 62 189 77 4371 <1 1 20.3 Waste Neutralizer & Seendry SG Weste Tk 3 60 6 2 45 116 56 2373 <1 1 20.4 Turb Bldg F1r Drain Tnk & Laundry Waste 139 8 3 64 215 80 5207 <1 i i 20.5 Liquid Weste Storage & Holdup Tanks 284 13 5 103 404 127 10650 4 20.6 Sludge Hadig/ Resin Storage / Waste Concent 4 78 5 2 37 127 46 3128 <1 20.7 River Water 47 47 102 1855 E 20.8 Service Water 52 52 218-2049 2 20.9 Cooling Water 77 77 230 2978 g l 20.10 Well Water 153 153 158 5859 w m 20.11 Fire 33 33 72 1300 3 20.12 Air ~ 20 20 127 786 C 1 20.13 Plant Hemting 120 120 338 4644 i 20.14 Fuel & Lube Oil 43 43 51 1672-O 20.15 Chlorine 5 -5 9 190 gy g f ( ~.-a -.._4 ..m. ,,w r, w -., ,,.,r.-. u..~.,.-,~.,...,.~~.,e.,

TABLE.4.5 (Continued) COST ESTIMATE FOR MOTNBALLING/ DELAYED DISMANTLING: Dresden Unit 1 Activity Decon Remove Pack Ship Bury Total Cu Yo Scrap M-bra M-Ree 20.16 Cleanup & Condensate Demineralizers 138 23 8 181 350 224 5199 <1. 20.17 Reactor Enclosure Air Conditioning Water 16 43' 59 181 2346 20.18 Control Rod Hydraulics 452 15 6 122 595 151 16696 4 20.19 Turbine 72 18 12 314 415 389 2729 <1

- 20.20 Main Steam & Condensate 892 204 92 243?

3627 3023 33851 1 20.21 AC Auxiliary Power (clean) 13 13 to 502 -20.22 AC Auxiliary Power (contaminated) 3 <1 <1 5 8 6 109 <1 20.23 Instrumentation & Control (clean) 174 174 484 6817 20.24 Instrumentation & Control (contaminated) 161 13 5 105 284 130 6352 <1 20.25 Miscellaneous RCS 88 24 6 134 253 165 3351 3 20. Totals 36 3376 344 147 3673 7576 4551 2011 129645 15 Decontamination of Site Buildings 21.1 Reactor Enclosure 401 166 31 13 253 865 314 21528 1 21.2 Turbine Building 51 2 <1 18 73 23 1965 <1 21 3 Fuel Handling Building 5 <1 <1 2 7 2 192 <1 21.4 Fuel Storage Building 45 42 2 <1 16 105 20 3116 l 21. Totals 502 208 36 15 289 1050-358 26800 -2 s { Subtotal Period 4 Activity Costs 1018 10407 1368 934 7013 27776 8055 2418 318554 123 Period 4 Undistributed Costs j 1. Decon equipment 64 64 2. Decon supplies 62 62 3. Staff relocation expenses 272 ~ n o 4 Process liquid waste 85 25 65 565 740 700 2510 6 e 5. Nuclear liability insurance 318 5 6. Health physics supplies '829 429 gy 7. Heavy equipment rental 390 390 e 8. Pipe cutting equipment 397 397 O l 9. Disposal of contaminated solid waste 30 12 243 286 301 2213 60y 1 10. Plant energy budget 926 w. Subtotal Undistributed Costs Period 4 126 1302 55 77 808 3885 1001 4723 12 P,, T e l DOC Staff Cost 16264 $O Utility Staff Cost 996 Subtotal Staff Costs for Period 4 17260 TOTAL PERIOD 4 1144 11710 1424 1011 7821 48921 9056 2418 323276 135 i 4 r, w- ,,w-.,. .*w-m -., w .s m mm m

~* TABLE 4.5-(Continued)- COST ESTIMATE FOR MOTHaarI.TNG/ DELAYED DISMANTLING: Dresden Wait 1 Activity Decon Remove Pack Ship Bury Total Cu Yd Serap M-bra 96-See 3 I PERIOD 5 Removal of Building Cranes 22. Removal of all b1dg cranes 30 -30 60 228 l Demolition of Remaining Site Buildings 23.1 Resetor Enclosure 5920 5920 3862 176703 l 23.2 Turbine Building 1363-1363 467 38656 l 23.3 Fuel Handling Building 272 272 34 7929 23.4 Fuel Storage Building 12 12 22 336 l 23.5 circulating water Intake 4 4 10 123 l 23.6 Stack 92 92 1455 23.7 Miscellaneous site structures 23 23 19 560 23. Totals 7685 7685 4414 225763 [ Site Closecut Activites i 24 Backfill Site 429 2342 25. Grade & landscape site 216 2081 26. Final radiation survey a 27. Final report to NRC 94 28. Terminate possession-only license a L Subtotal Period 5 Activity Costs 7715 8454 4474 230414 3 i Period 5 Undistributed Costs O i 1. Nuclear liability insurance 53 E ~ 2. Heavy equipment rental 260 g { i 3 Plant energy budget 463 i Subtotal Period 5 Undistributed Costs w

s. -

776 3 e n a r 6 6 W 8 One O m Mt 8 w i t I I .m - ~

TABLE 4.5 (Continued) [ COST ESTIMATE FOR MOTH 8ALLING/DELATED DISMANTLING: Dresden Unit 1 Activity Decon' Remove Pack Ship Bury Total Cu Td Scrap M-hrs M-See l DOC Staff Cost 5226 Utility Staff Cost 380 Subtotal Staff Costs for Period 5 + 5606 .* TOTAL PERIOD 5 7715 14836 4474 230414 TOTAL COST DELATED DISMANTLEMENT 1144 19568 1425 1011 7829 71437 9066 6891 553764 135 i TOTAL COST DELATED DISMANTLEMENT WITN 255 CONTINGENCT: $ 89,296,750 i TOTAL DELATED DISMANYLEMENT RADWASTE YOLUME BURIED: 9,066 Ctl TDS TOTAL DELATED DISMANTLEMENT SCRAP WEIGHT: 6,891.4 TONS } TOTAL DELATED DISMANTLEMENT CRAFT LABOR NEQUIREMENTS: 553,764.4 MAN-HOURS TOTAL DELATED DISMANTLEMENT PERSONNEL RADIATION EXPOSURE: 135.0 MAN-REM TOTAL PROJECT COST 1392 19726 1440 1030 8037 (89458) 9323 6891 563105 162 i TOTAL COST e e Mothballing with 30 years dormancy & delayed dismantling: $ 108,676,900 TOTAL PROJECT RADWASTE VOLUME DURIED: 9,323 Cu TDS TOTAL PROJECT SCRAP WEIGMT: 6,891.4 TONS TOTAL PROJECT CRAFT LABOR REQUIREMENTS: 563.105.5 MAN-HOURS

g a

TOTAL PROJECT PERSONWFL RADIATION EXPOSURE: 162.3 MAN-REM l w ,a o e s s W 8w o ey m m e l NOTE: () This cost includes $39,789,560 for Utility & DOC staff periods 1-5 costs e >= and $18,043,250 for engineering and preparations, property taxes, nuclear liability - plant energy budget, and staff relocation expenses. 1 l ' Mothballed din :::y cost has no contingency applied against it. b o --z - + - ~ w. -,.,.,,...,. - -.., ~ ~. - ..,, _, _ _. _. ~ _ _ ~... _ _,. -. _

j Document C04-25 081 Page 58 of 66 l 5. SCHEDULE ESTIMATE The schedule for the decommissioning alternatives considered in this study of Dresden 1 follows the sequence presented in the AIF/NESP-909 study with minor changes to reflect recent i experience and revised estimates. The assumptions are listed in Table 5.1. Table 5.2 presents the schedule estimate summary and Figures 5.1 and 5.2 present the schedule of key activities for prompt removal / dismantling and mothballing. The schedule for delayed dismantling will reflect an abbreviated prompt dismantling sequence. TABLE 5.1 SCHEDULE ESTIMATE ASSUMPTIONS The following assumptions were made in the development of the i schedule estimate for Dresden 1. 1. All work except vessel and internals removal activities is performed during an 8-hour workday, 5 days per week with no L overtime. 2. Vessel and internals removal activities are performed by using separate crews for different activities working on different shifts, with a corresponding backshift charge for l the second shift. l 3. Multiple crews are used working parallel activities to the maximum extent possible consistent with optimum efficiency, adequate access for cutting, removal and laydown

space, and with the stringent safety measures necessary during demolition of heavy components and structures.

4. For plant systems

removal, the system with the longest single removal duration is considered to determine the duration of the activity.

TABLE 5.2 SCHEDULE ESTIMATE

SUMMARY

(Months) Activity Duration Il Prompt Removal / Dismantling 72 l Mothballing 12

[- f-a FIGURE 5.1 ' PROMPT REPJOVAL/ DISMANTLING SCHEDULE (Months) i Activity S 12 24 36 48 68 72 l 1. Remove fuel and process wastes 2. Prepare dismantling plan for NRC 3. Prepare activity specifi-cations and procedures 4. Remove and dispose of plant systems i 5. Segment and dispose of vessel and internals 6. Remove and dispose of tur-bine generator / condensers 7. Demolish and dispose of primary containment' interior 8. Radiation survey for_resi-dual contamination ~ 9. Break secondary contain-j ment; remove crane L j

19. Demolish remaining i

i reactor building i

11. Demolish remaining build-ings and structures o

12. Backfill, grade and landscape site

13. Final radiation survey; g

a report to NRC

14. Terminate license 1'

e n e s Y 0w 9% 9 m 9 m W + W w r-- - * - - +,,,--g-o.w .-w-e.,ee-g,,.3 ,m.---y-ve---,,ow- -+ ,,#--ec,,e,w-w,e e-y e. ,e

.1 s FIGURE 5.2 MOTHBALLING SCHEDULE (Months) Activity-0 2.. 4 6 8 IS 12 4 1. Remove fuel and process wastes 2. Radiation survey and ( inventory 3. Request possession-- ~ only license-l 4. Sequence work activities 5. Prepare activity specifi-l cations and procedures j 6. Drain and secure con-i l taminated systems J 7. Drain and secure contaminated systems 8. Prepare surveillance and monitoring systems i 9. Install reactor building, pressure equalization line

19. Decontaminate building pathways

11. Radiation survey and post radiation signs O

12. Secure all building accesses; prepare final report e

I m O w' 43e n e w 6. DJ 'I O O M r G 6 G W l .... - ~. - ~...., - ~.= - -~ . ~, _ ~. -. -

_ _ __. _~ Docume2t C54-25-991 Page 53 of 66 6 RADI0 ACTIVE WASTE VOLUME i The. radioactive waste volume generated during decommissioning is approximately 19,615 cubic yards for prompt dismantlement of the facility. The waste volume calculated herein is the gross container volume to be shipped and buried in controlled burial grounds. In general,' depending on the characteristics of the container contents (flat plates versus concrete rubble) the container may be filled to only 49% 60% of its volumetric capacity. Most of the materials for controlled burial are categorized as Low Specific Activity (LSA) material containing less than Type A quantitios as defined. in 49 CFR 173-189 (Ref. 11). The containers must be strong tight packages. For this study, steel containers measuring 4' x 4' x 8' have been used for

piping, small components and concrete.

The reactor vessel and internals are Type B shipments and accordingly must be shipped in reusable shielded casks with disposable liners. In this case, the liner volume was taken as the easte volume. Table 4.4 lists the radioactive waste volume for the prompt removal / dismantling alternative activities. The total 19,615 cu yds is generated over the 48 month decommissioning program. A typical 297 MWe boiling water reactor will generate approximately 6,570 cu yds of burial waste before treatment during its 39 years of plant operation (Ref. 12). Table 4.5 lists the radioactive waste volume for the mothballing with delayed dismantlement alternative activities. The total 9,323 cu yds is generated over the 12 month decommissioning program. e d

D:cument C84-25-801 Page 54 of 66 7. OCCUPATIONAL EXPOSURE l The preparation of estimates of occupational radiation exposure i was based on postulated radiation exposure rates in the various areas of the plant and on estimates of the staffing required to complete decommissioning ,ork. Exposure rate data was obtained w from NUREG/CR 9672 (Ref. 10) and is assumed to be representative of a generic condition typical of BWR reactors. The radiation doses to decommissioning workers are calculated as the product of the estimated radiation zone manpower requirements and the radiation exposure rates postulated for each decommissioning task. The decommissioning occupational exposure estimates are based on the following assumptions: 1. Personnel exposure to radiation is minimized by using shielding and remote handling techniques and by staying out of higher radiation fields when presence is not necessary. - 2. Local exposure rates near items such as tanks and pipes have been reduced by a successful chemical decontamination program prior to work in that area. 3. Careful prompt accounting of accumulated radiation exposure is maintained to rapidly identify tasks causing excessive dose accumulation by workers so that corrective action can be taken. t 4. Cobalt-60 is the primary contributor to radiation exposure. The reduction in personnel exposure from area and components after 30 years delay is assumed to be that of the reduction in Cobalt-69. Tables 4.4 and 4.5 list the occupational exposure estimates for each activity in the prompt removal and mothballing/ delayed dismantlement decommissioning modes, respectively. The results are summarized.in Table 7.1. Dresden Unit 1 local area dose rates and equipment dose rates were used as much as possible; I where such data was not available, generic dose rates for BWR reactors were assumed. m ...,._y .__.y .,m..

1 i. f D:Gument C64-25-081 Page 55 of 66 TABLE 7.1 OCCUPATIONAL EXPOSURE FOR DECOMMISSIONING I Activity ManRem y Prompt Removal / Dismantlement 2,659.8 Mothballing with Delayed Dismantlement 162.3 r ? I i ? i 4 1 ' b + 4 4-e 4 ' l l As-- a- ,n.-,,e

a...

7-, --,..,an.,, - - -,, ,.n,,,,,-- ,,-,.m, e.m-,

i Y D ument C04-25-881 ) Page 56 of 66 8 CONCLUSIONS i Decommissioning technology is well established and the tools and equipment necessary to completely dismantle Dresden Nuclear Power Station Unit 1 are available and have been demonstrated. The costs to decommission Dresden 1 using the prompt removal /disman-l tling alternative is 896,613,989 (including 25% contingency) for shipment of all wastes and dismantled materials to a regional burial site. These estimates reflect the site-specific features i of the Dresden 1 and the recent increases in radioactive waste shipping and burial costs. An analysis of the major activities + contributing to the total cost (without 25% contingency) is shown in Table 8.1. The removal costs, and CECO and DOC staff costs are obviously the largest percentages of the total

cost, reflecting the labor intensive nature of decommissioning programs.

Burial is the next most costly activity in the program. Burial costs will undoubtedly increase whether or not new burial facilities are authorized and licensed. Shipping will be most sensitive to increases in fuel costs and distances to existing or new burial facilities. Removal costs are dependent on the degree of remotely operated equipment available in the future and the associated higher cost of that equipment versus the savings in s labor costs. These results point to the need for periodic reviews of these estimates to incorporate new cost information and decommissioning costs in the future. l t TABLE 8.1

SUMMARY

OF ACTIVITY COSTS, PROMPT DISMANTLEMENT Costs Percent of Work Category (Thousands) Total Costs i l Decontamination 1,432 1.85 Removal 19,893 25,62 Packaging 1,489 1.93 Shipping 1,257 1.63 Burial (off-site) 9,759 12.63 Utility & DOC Staff 28,971 37.48 Other

14,589 18.86 Subtotal 77,291 100.00 25% contingency 19,323 25.08 TOTAL 96,614 125.95 Other includest engineering & preparations, property

taxes, nuclear liability insurance, plant energy budget, and DOC staff relocation expenses

.. ~

,4 - s. Dsetment C64-25-001 Page 57 of 66 The costs to decommission Dresden 1 are higher than recent decommissioning costs for other plants. The primary reasons for these higher costs are that the Dresden 1 costs are in 1985 l dollars and reflect all recent national inflationary trends in labor, materials and equipment. More importantly, the cost of radioactive waste burial has increased rapidly in the last few years. At the Barnwell,- SC facility alone the costs have increased almost 990% since 1978. Recent estimates (including Dresden Unit 1) have been prepared with more detailed site-specific

data, as cost-estimators strove to account for every piece of' equipment in each plant.

As actual dismantling experience on large reactors becomes available (such as FWR steam generator removal and BWR feedwater and recirculation piping modifications),. cost estimators are reflecting this experience in their estimates. For-- an equivalent sized

plant, a

BWR will olmost always be significantly more expensive than a PWR due to the larger-number of contaminated systems and structures. i I

Finally, the emphasis in reducing exposure to workers (ALARA) has required the need to increase the crew size (and costs) to minimize the exposure to any one worker.

These factors compound .to account-for the recent increases in decommissioning costs. l l l l

.;gp y; ,+ - ~ ~ Mj, L i y .e j TV i Dtcument C64-25-901 ) Page 58 of 66 s 4 y 9.- REFERENCES + fe' ;, 1. U.S. Nuclear Regulatory Commission Regulatory Guide 1.86, J " Termination of operating-Licenses for Nuclear Reactors", June, 1974. 2. U.S. Code of Federal Regulations, Title 10, Parts 30, 40, ( 50, 51, 70 and 72 (Proposed Rules),- Nuclear Regulatory Commission, Federal Register (p 5600+), February 11, 1985. L 3. U.S._ Nuclear Regulatory Commission NUREG-0586, " Draft Environmental Impact Statement on Decommissioning of Nuclear Facilities", January, 1981, 1' 4 EEI/AGA Survey on-Nuclear Decommissioning Methods / Costs, presented at the AGA Depreciation Committee and EEI i Depreciation. Committee Conference, Dallas TX, February 1 11-13, 1985 a 5. Tri-State Motor' Transit Company, Docket No, MC-199397 and Supplements. 6. Chem-Nuclear Services Barnwell, SC Rate Schedule. i 7. W.J. Manion and T.S. LaGuardia, "An Engineering Evaluation of Nucl' ear Power Reactor Decommissioning Alternatives", AIF/NESP-909, November 1976. 8. W.J. Manion and T.S..LaGuardia, " Decommissioning Handbook", U.S. Department of Energy, DOE /EV/10128-1, November, 1980. 9.- "Building Construction Cost Data 1984", Robert Snow Means Company, Inc., Duxbury, Massachusetts. ~ 10. U.S. Nuclear. Regulatory Commission, NUREG/CR

9672,

" Technology,. Safety and Costs of Decommissioning a Reference l Boiling Water Reactor Power Station," June, 1980. 11. U.S. Department of Transportation, Section 49 of the Code of Federal Regulations, " Transportation", Parts 173 through 189. l12. DEIS on 10CFR61, " Licensing Requirements for Land Disposal of Radioactive Wastes," Vol. 3 9

^:r .- ~ - - - - cw i - ,;p 1 v,s. h.\\S jf g/ si i. .Sg ; w.a..- D*cument C64-25-881 v,. : ,g;q ! #e '. ;:.' App;ndic0s A.- 3 5 - l1l[ * " g'. i Page 59 of.66: '= o:; l ? ?f,- jt, p. gi, l [ 1.i i t. I j t { 1 1liI; I ? t APPENDIX A a

1 DEVELOPMENTLOF-UNIT COST FACTORS.

'i jj. k' l' -1 s 0 3 1 j t 1-. e I

)

t - ~, ,5 s

~, 4 u. L * " O ' *1 Dieument Cf4-25-881 . App:ndloos-A - B 4 Page 60 of 66 3 -. e 1 APPENDIX A F u 1 UNIT COST FACTOR DEVELOPMENT Example:: Unit Cost : Factor' for Removal of Heavily. Reinforced Activated or Contaminated Concrete. L 1. SCOPE i Quantity of concrete to be removed is large enough to require use of track drill and one front-end loader with a.2 j i L cu.yd bucket. Oxyacetylene torch will-be. used for' reinforced concrete to cut rebar and for miscellaneous. . structural steel, etc. Reinforcing is assumed to.be No. 9 rebar (1-1/4"0D) on 12" centers p '2. EQUIPMENT AND MATERIALS REQUIRED L Pneumatically operated track drill l Compressor 750 CFM; diesel-driven Air-hoses and connections Blasting mats (minimum 6 to 10' x 12 ' steel) -Fog spray system - multiple spray heads Explosives magazine 0xyacetylece torch, gas bottles, hoses, fire o extinguishers Front-end loader with 2-yd3 bucket Rubble transfer container 3. CALCLLATIONS. Dur'ations: Required Operations Sequence Inte - - - - - - - - - - - - - - - - - - - - - - - - - - - - grated a Check all: equipment (drills, compressor fog spray, blast mats) 15 15 b Move drilling-equipment to location 15 (a) Drill holes on 2' centers, 2' burden, c 29' long, S' deep (7.4 yd3) 120 120 d Place charges in holes 69 60 Place blast mats and start fog spray 30 30 e f Evacuate area and. detonate charges 15 15 g-Verify charges have been shot 19 10 h Remove fog. spray & blasting mats 30 30 i Sample concrete rubble /rebar for radioactivity 15 (j) j Cut rebar with torch 60 60 k Remove rubble into transfer container 60 60 1. Move transfer container to packaging area 30 30 Total Durations: TIT 4TF Base Activity Duration = 439 minutes to temove 7.4 yd3

Dccument C04-25-881 . -q AppOndicas A - B-

=

-Page 61 of 66 ' APPENDIX A Cont'd. Work Difficulty Factors Against Base Duration p Height (20%) 86 Masks (50%) 215 Radiation (40%) 172 Actual Duration ' TIT Work Difficulty Factors Against Actual Duration- ~ PCs (30%) 271 Productive Duration 117I-Nonproductive Time Factors Union (8.33%) 98 Work Duration 1277 L Total. Time in Minutes = 1272 minutes per 7.4 yd3, or h 172 minutes per yd3 L' l' I1 Duration Rate Cost ' Labor Crew No. (hrs /yd3) (S/hr) (S/yd3) /. . Laborers 4 2.865 16.54 189.55 operators 2 2.865 22.73 130.24-Blastingjexpert 1 2.865 23.48 67.27 Assistant 1 2.865 23.48 67.27 Foremen 1 2.865 23.48 67.27 Subtotal labor costs. 521.60 L OH&P on labor.930t' 156.48 Total Labor cost per yd3 $678.08 Equipment Cost + Materials Rate, S (S/yd3) Ref..* 3 Blasting mats (10 'x12 ') 2.13/hr 18.31 5 Fog spray system-1.68/hr 1.68 1 750 CFM compressor 9.12/hr 26.13 2 Front'end loader w/ backhoe 6.08/hr 17.42 3 Track drill 12.00/hr 34.38 4 Subtotal materials $97.92 Adjusted for regiont.1 material costs; for Dresden use 85.1% +- See next page for References =. --i-

JW ~ l .i. 2 7 D3cument C84-25-091 t' -Appendices A - a Page 62 of 466' i APPENDIX A Cont'd. . Equipment cost + i Materials. Rate, $ ($/yd3) Ref.* Compressor:8-hrs'of gis/ oil 17.87/hr ~ 51~.19 2 Bucket' loader: 81 hrs of gas / oil 3.97/hr 11.37 3 Drills bits, etc. for 8 hrs 5.96/hr 1.61 4 =1 29 Explosive sticks' (2 each.at:.19 holes) 1.23/ pound 3.32 7 29 Blasting caps .l.28/ cap 3.46, 8 Subtotal'consumables $70.95= Subtotal materials &-consumables 168.87 l OH&P on-materials & consumables 9 19% 16.89 Total Materials'& Consumables: $185.76 TOTAL-UNIT COST FACTOR ~ $862.86 per-yd3 f( l l

I 1;

l J' <:I References ~ ^ g L 11.- TLG Engineering, Inc. estimate -2 R.S. Means (1985) 1.5, 15-070 R L 3. R.S. Means (1985) 1.5, 05-039 4. R.S. Means (1985) 1.3, 15-097 S. R.S. Means (1985) 2.3, 15-399 6. R.S. Means (1995) 1.5, 15-636 ,7. R.S. Means (1985) 2.3, 15-370 8. R.S. Means (1985) 2.3, 15-358 m I 1-9 L

- r_ .;;; z.;;.'. ' l -a { q y-.. Document-C94-25-881; .:n- . x; l0 ' 'Appendicos A - a 1 . c - c-..,, Page:63 of 66= 1 i .1 ,.-l + 'l '1 1, 'l p-l; ji: 1 i I L 1 l i H ~ APPENDIX B UNIT COST FACTOR I.ISTING l l l t (. a l \\ i [ ' s I I 1 1 l-l'

. ~.

=. '

t "1 wpim, .n T. % Dscument C04-25-001' App 3ndic30 A - a e'. Page 64 of 66 i i

i APPENDIX B-1 l

UNIT COST FACTOR LISTING Noncontaminated Factors A Unit Cost Factor Value Cut pipe <2.5 inches' diameter per LF 5.75 n Cut pipe 2.5-8 inches diameter per LF 9.55 Cut pipe >8 inches ~ diameter per L! 17.97-Remove valves 2.5-8 inches 114.94 q Remove valves >8 inches-203.43 t

Remove pumps, <300 pounds' 126.43 j

H RemoveLpumps,-300-1000- pounds 296;59 t W Remove pumps,= 1000-10000 pounds 3827.67. .i Remove pumps, >10000 pounds 4176.66 Remove heat'exchangers, <3000 pounds 906.42 j ' Remove heat exchangers, >3000 pounds 1622.03 i Remove' tanks, <300' gallons- '261.13 . Remove tanks,. 300-3000 gallons 461.42 Remove tanks, >3000 gallons, S/in cut .74 1 cRemove mise. components, <300 pounds 124.44 L ' Remove misc.-c'omponents,. 1000-10000 pounds 686.58 300-1000 pounds 344.21 l Remove misc. components, Remove misc.' components, >10000 pounds 1724.14 L CutLelectrical cable tray per LF 5.79 b l Cut' electrical conduit per LF 2.96 l Perform manual flame cutting, S/in 2.98 Remove clean concrete floors, S/cu yd 141.62 Remove heavily reinforced concrete, S/cu yd 100.89 ' Demolish subterranean-tunnels, S/in'ft 53.81 Perform excavation, S/cu yd 1.23

Perform bldg demolition (volumetric), S/cu ft 0.13 7 Remove 1 structural steel, S/lb 6.17 Remove steel floor grating, S/sq ft 2.16

. Remove' free-standing steel liner, S/sq. ft 6.90 Remove; grade slab concrete, S/cu yd 102.70 Remove' concrete rubble, S/cu yd 5.65 Landscaping,-S/ acre 7730.05 ' Remove monolithic concrete, S/cu yd 386.75 Remove concrete anchored steel liner, S/sq. ft 6.43 Remove standard reinforced concrete, S/cu yd 159.57 Remove masonry / block, S/cu yd 31.86

'iYkg[1" e h... ~ ~ ~ ~ ~ ~ 'T~ ' ~ ~ ^ ~ ^ d o 'vl/h i ,1n DDoument C84-25-901" l 1fo% 4 App 3ndioco A.- B: 1 e Page 65 of 66 J +, .m .tih 1 [ll ' APPENDIX B 2 x ) UNIT COST FACTOR LISTING t 1 Contaminated Factors L>> Unit Cost Factor. Value s j 'TU[

Cut pipe' <2.5 ~ inches diameter - per LF 37.76.

F Cut pipe 2.Sa8 inches diameter per LF 55.26 Cut pipe'>B inches diameter per LF 114.44' 1 , [jf l Remove valves: 2.5-8 inches 341.39 i D'i Remove valves >8-inches 572.21 4 .Removelpumps,1<300 pounds-357.46 LRemove pumps, 399-1999 pounds. 962.52 ' Remove = pumps, 1990-10000 pounds ~7351.32 ? Remove: pumps,->19000; pounds 1 19917.73 t L Remove heat exchangers, <3000 pounds 2158.41 L Remove; heat-exchangers, >3000 pounds 5230.98 i Remove moisture separator / reheater' 19915.84 'Removeltanks, <399 gallons 650.54 Remove' tanks, >300 gallons, S/in cut 2.37 Remove misc. components,.<300 pounds 455.97 .t Remove misc. components, 399-1999-pounds - 987.17 i l Remove misc.fcomponents,. 1990-10000 pounds 1858.96 N-Remove: misc.' components,->19000: pounds' 6196.88 l;f Cut, electrical cable trayfper LF-34.87 Cut electrical 1 conduit per LF 30.68 i Remove?feedwater heater 16318.05 li . Plasma [ arc cutiof cont. equip, S/sq in 1.32 Surface' decontamination, S/sq. ft. 2.59-i Procure and' prepare LSA 4'x4'x8' box 475.79 ^ Remove activated / contaminated concrete, S/cu yd 862.86 l Scarify contaminated concrete surfaces, S/sq ft-5.72 Decontaminate large components, S/sq. ft 14.83 Decontamination rig hookup, each-3635.54 -Remove concrete anchored steel liner,.S/sq. ft 14.49 3

Decon flush of components / systems, S/ gallon 3.96 Remove free-standing steel liner, S/sq. ft 18.91 l

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.s es ? Exhibit V I N s; -) i Trust Agreement Dated December,8, 1988 Between + Commonwealth Edison Company and. m' The Northern Trust Company l-Y (Tax Qualified Decommissioning Trust) 'I I ^i' i -) i lh I e -7687C/5 i

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9 4 (Conformed Copy) t ' TRUST AGREEMENT Dated Decemberi8, 1988 Between COMMONWEALTH EDISON-COMPANY and THE NORTHERN TRUST COMPANY (Tax Qualified Decommissioning Trust) y e 4 i j

'E. 7 v-t V 1 o 1 3 4 i Lo Table of Content s E EA92 i ARTICLE-It DEFINITIONS, NAME AND PURPOSE 1.1 Definitions 1 ) o 1.2 Names of Trusts 3 'l.3 Purpose of Trust-Agreement 3-1 ARTICLE IIt ESTABLISHMENT OF SEPARATE TRUSTS AND DISPOSITIVE PROVISIONS 2.1 Establishment of Separate Trusts 3 2.2 Payment of' Nuclear Decommissioning Costs 3 2.3 Additions to Trusts........................ 4 2.4. Subsequent Adjustments....-................ 4 2.5 Payment of Taxes.....'........-............. 5' 1 2.6 No Transferability of Interest in any Trust 5 2.7-Time of Termination.....-................... 5 2.8 Distribution of Trust Upon Termination.... 6 2.9 Alterations and Amendments......-.......... 6 2.10 No Authority to Conduct Business..........- 6 L ARTICLE III: GENERAL' PROVISIONS RELATING TO THE TRUSTEE' F 3.1 Designation and Qualification of Successor Trustees 7 3.2 Compensation and Reimbursement 7 3.~3 Transactions With Third Parties 7 3.4 Financial Statements '...................... 7 3.5 Tax Returns and Other Reports............. 8 3.6 Nominees; Depositories 8 3.7 . Future Orders 9 L-3.8 ~ Appointment of Investment Manager '......... 9 3.9 Certain~ Duties and-Responsibilities of the Trustee........................ 10 3.10 Certain Rights of Trustee................. 11 ARTICLE IV:. TRUSTEE'S POWERS l 4.1 Payment of Expenses of Administration..... 12- ~4. 2 Prudent Investments 12 i 4.3' Investment of Trust Fund.................. 12 4.' 4 Management of Trusts....................... 13 4.5 Extension of Obligations and Negotiation i. of Claims 14 4.6 Registration of. Securities 14 4.7 Location of Assets 14 4.8 Retention and Removal of Professional Service Providers 14 4.9 Delegation of Ministerial Powers 14 4.10 Discretion in Exercise of Powers 14 .......... t

~ + + 2. -i 2192 ARTICLE.V: ' MISCELLANEOUS PROVISIONS 5.1 Headings.................................. 15 5.2 Particular Words ........................... 15; 5.3 Severability of Provisions................ 15 l 5.4 Form and Content of Communications........ 15 5.5-Delivery of Notices.Under Agreement....... 15 5.6 Successors and Assigns...................-. 716 5.7 Counterparts of Agreement.................. 16._ a 5.8 Governing Jurisdiction ....................-.-16 '5.9 Miscellaneous ............................. 16 i EXHIBIT At Form of Disburrament Certificate EXHIBIT B: Form of, Withdrawal Certificate 'f W T l: I t 7 ~

t h TRUST AGREEMENT -THIS TRUST AGREEMENT (" Agreement").is=made this 8th day-of December, 1988,- between Commonwealth Edison Company, an Illinois _ corporation (the " Company"), and The Northorn -Trust Company, a banking association, having trust powers (hereinafter, together with any. successors in office,' called the " Trustee"). WHEREAS, the Company is the owner in whole or in .n part of each of the Plants (as hereinafter defined); I WHEREAS, the Company is subject to regulation by 1 .the Illinois Commerce Commission ("ICC") and'the Nuclear j Regulatory Commission ("NRC"); WHEREAS, under the Code (as hereinafter defined),- including Section 468A thereof, certain income tax benefits-are available_to the Company by funding qualified " nuclear 1 decommissioning reserve funds"; WHEREAS,-this Agreement is established and intended to be maintained and be and remain qualified under'Section j 468A of the. code and the regulations promulgated. thereunder, and any successor or amendments thereto; NOW, THEREFORE, the Company shall deliver Schedules to this Agreement to the Trustee, and the Trustee shall 1 acknowledge receipt of any funds described thereon repre - ?l senting the initial funding-of the. Trusts (as hereinafter l defined) with respect to the Plants described or referenced p ~on such Schedules;- L L TO HAVE AND TO HOLD, such Trusts and such addition-l al funds as may from time to time be added thereto as pro-l L 'vided herein, together with the proceeds and reinvestments L thereof-(hereinafter collectively called the " Trust Fund") unto the Trustee; l IN TRUST NEVERTHELESS, for the use and purposes and [ upon the terms and conditions hereinafter set forth: ARTICLE I DEFINITIONS, NAME AND PURPOSE 1.1'. Definitions. As used in this Agreement, the following terms shall have the following meanings: i L

.4 "- Agrek. ant," L " Trust > Agreement" and the terms "here-of," "herein," " hereto,"~and " hereunder," when used in this Agreement, shall mean and include this Agreement as the-same may from time to' time be. amended, modified, or supplemented. " Code" shall'mean the Internal Revenue. Code of' 1986,' including Section 468A thereof, as it may be amended from time to: time, and the regulations promulgated thereun-der. "Section 468A" shall mean that section of the Code, as it'may be amended from time to time, and any successor provi-sion thereto, and the regulations promulgated thereunder. " Disbursement Certificate" shal1~mean a document properly completed and executed by the Company substantially in the form of Exhibit A hereto. " Excess Contribution" shall have the meaning set . forth in Section 2.4 hereof. " Future Orders" shall mean any orders of.the ICC, NRC or Federal Energy Regulatory Commission issued, and any. g Federal or state laws: adopted, in connection with the reten-tion, investment and utilization of funds for the costs of. decommissioning-of any Plant, y '" Illinois' Statute" shall mean Section 8-508.1 of-the Illinois Public Utilities Act (Ill'. Rev. Stat. ch. 111-2/3,.58-508.1) as it may hereafter be amended. .) "NRC Rule" shall mean the " General Requirements for Decommissioning Nuclear Facilities" of the NRC-(53 Fed. Reg. 24018, June 27, 1988) as it may hereafter be amended. " Plant".shall mean each, and " Plants" shall mean= l all, of the nuclear-power-plants listed on the-separate -Schedules attached to this Agreement (as such Schedules.may be supplemented from time to time by the Company-by written f notice to the Trustee). Each unit of a multi-unit nuclear power plant site shall be considered as a separate Plant for- - the purposes of this Agreement. " Qualified Costs" shall mean the Company's costs incurred in'the decommissioning of a Plant, to the extent that such costs may be paid out of a Trust pursuant to Sec-4 tion 468A of the Code. " Service" shall mean the Internal Revenue Service. " Trust" shall mean each, and " Trusts" shall mean all, of the separate funds created and listed on the separate Schedules attached to this Agreement as such Schedules may be j supplemented from time to time by the Company by written - notice to the Trustee. ) i

-= g ' ;w' X aj " Withdrawal Certificate" shallLmean a document 2' properly-completedJand executed by the Company substantially-7 in the form <of Exhibit B. hereto. q 1.2 Names of'Trustsi Each Trust shall be-known as .the " Commonwealth Edison Company Tax Qualified Decommis-1 sioning Trust - [name of-Plant)". The Trusts, collectively, shall-be known as-the-" Commonwealth Edison Company Tax-Quali-S .fied Decommissioning Trust Fund". j 1.3 Purpose of Trust Acreement. The purpose of thin Trust Agreement is to provide; funds for the contemplated decommissioning of the Plants' listed on the separateLSched. ules attached hereto, to comply:with the Illinois StatuteDand the NRC Rule, and-to constitute " nuclear decommissioning e reserve funds" within.the meaning of Section 468A of the Code i and to comply withrany Future Orders. r ARTICLE II: ESTABLISHMENT OF SEPARATE TRUSTS AND DISPOSITIVE PROVISIONS- -1 L and reinvest and, q The Trustee shall manage, invest, L after payment of the expenses described in Section 4.1 here-of, distribute-each Trust as follows: 3 2.1 Establishment of Separate Trusts. The Trustee shall establish a separate Trust hereunder for each Plant. .Each time the Company makes a contribution to the Trust ~ Fund, it shall designateJthe amount of such contribution allocable to each such separate Trust. The Trustee shall maintain' separate: records-for each Trust-and shall credit thereto its pro rata share of.all: income of the Trust Fund and charge O L thereto its: pro rata: share of all expenses (other than ex-pensesLattributablefto a particular Plant which shall be -l expenses charged to the Trust named for such' Plant) and any losses. Until otherwise instructed in writing by the Compa-ny, nothing in this Section-2.1 or elsewhere herein shall be deemed to require the Trustee to segregate'or separately. .i invest assets of the Trust Fund, it being intended that the assets of the Trust Fund may be maintained and invested and reinvested as a common pool, but shall not be required to be so maintained or invested. 2.2 Payment of Nuclear Decommissionino Costs. The Trustee shall make payments of Qualified costs in accordance -with the'following procedures: (a) Disbursements to Third Parties. The 4 Trustee shall make payments of Qualified Costs to any person (other than'the Company) for goods provided or labor or other services rendered to the i Company in connection with the decommissioning of a Plant within five business days of the receipt of y the Disbursement Certificate..

a g -(b). Reimbursement to the Company. The Trust-eeDshall make payments to the' Company in reimburse-- ment!of Qualified Costs actually incurred by the Company and paid'to any other person within five business days of receipt of-a Withdrawal Certifi-cate.- 'The Trustee shall be under no duty.to inquire into the cor-rectness or accuracy of matters contained in a Disbursement ? Certificate or Withdrawal Certificate unless representatives of the Trustee then approving any withdrawal or disbursement

l based on such certificate have actual knowledge of the falsi-ty of any statements made therein.

The; Company will indemni-fy the Trustee and hold it-harmless from any tax imposed. pursuant to Section.4951 of the Code with' respect to a dis-- bursement or reimbursement made by the Trustee pursuant to this Section 2.2 in reliance on a Disbursement Certificate or

a. Withdrawal Certificate, respectively, orovided.representa-tives of the Trustee then approving such disbursement or L

reimbursement-do not have actual knowledge of the falsity of any-statements made in the related Disbursement Certificate or Withdrawal Certificate that would have prevented the imposition of such tax. p 2.3. Additions to Trusts. From time to time prior L to the termination of each Trust held hereunder,'the Company j may make, and-the Trustee shall accept, additional contribu-f tions of funds to any separate Trust held hereunder to satis-L fy the purpose of this Trust Agreement as set forth in L Section 1.3 hereof. The making of a contribution by the L Company shall constitute the-certification of the Company. that the contribution meets the requirements of_Section 468A of the Code, and that all necessary' consents andsapprovals'to such~ contribution have been obtained. 2.4 Subsecuent Adiustments. The. Trustee and the Company understand that the contributions made by the Company and allocated to a Trust'from time to time may subsequently be determined to. exceed the amounts determined' pursuant to L Section 468A of the Code and paragraph (c)(2)(ii) of Sl.468A-ST thereunder (any such excess being hereinafter referred to as anf" Excess Contribution"). Upon the written certification of the Company, setting forth the amount of the Excess Con-tribution, and upon receipt of the opinion of legal counsel ~ described below, the Trustee shall distribute such amount to the Trustee of the Commonwealth Edison Company Non-Tax Quali-fled Decommissioning Trust created and existing pursuant to a trust agreement dated December 8, 1988, between the Company and the trustee named therein, or, if so requested in such written certification, transfer all or a portion of such amount to one or more other separate Trusts held hereunder. Distributions and transfers of any Excess Contribution shall., _ L

A notLbe?made"unless!the Company ~ furnishes the: Trustee with an opinion'of-legalicounsel-to_the-effect=that such distribution: or transfer will not; result in disqualification of the Trust under Section 468A~of the Code or constitute a violation of Ethe Illinois _ Statute, the;NRC Rule.or any Future Orders and-that all necessary consents and. approvals toisuch distribu-tion: or transfer: have been obtained. :Any income attributable to any_such_ Excess Contribution shall be allocated to the. .~ Trust to.which such Excess Contribution.fclates. 2.5 Payment'of Taxes. The Trustee shall pay out of each separate Trust any federal and, if applicable,Lstate income taxes on the income of such Trust as rnd when due in accordance with the returns prepared in accordance: with' Section 3.5 hereof.

2. 6' No Transferability of Interest in any Trust.

r The interest of the Company in any-Trust is not transferable, E 1 whetherJyoluntarily or involuntarily, by the Company nor L subject to the claims of creditors of the. Company; provided, j however,'that any' creditor of the Company as to which a. u , Disbursement ~ Certificate for a Trust-has been properly 1com ' l pletediand: submitted to ths: Trustee may assert.a claim di-rectly'against such Trust in an amount not to exceed either-l. the_ amount specified on such Disbursement Certificate or the' . amount of~such Trust available to pay costs other than amounts;then owing the Trustee under Section 3.2 hereof. 2.7 Time of Termination. Each Trust hereunder d L shall terminate, to the extent.provided in this.Section 2.7, j p upon the earlier to occur of the following events: j c l~' (a) In'whole,'upon the substantia 11 completion of-the nuclear decommissioning of the Plant for.- which such Trust was created and named as provided in.Section 468A(e)(7) of the Code and'as evidenced i to the. Trustee by the written certification of the i Company. L L (b) To the extent allowed or provided under Section 468A of the Code, the Illinois Statute, the NRC Rule or any Future Order, upon the disposition by the Company of any interest in the Plant for which such Trust was named. i (c) In whole, upon the distribution of all of the assets from the Trust. t The Trust Fund shall terminate when all of the separate Trusts have terminated..

s if - i It t 5: M-q 31 '2.8. Distribution of Trust Uoon Termination._ Upon termination of each Trust,-the Trustee shall distribute the i entire remaining amount of the Trust, including all accrued, t ' accumulated, and undistributed net income, to the Company; 4 provided, however, that no such distribution shall be made unless either (a) orders of the ICC and the NRC specifically authorizing such distribution are:in effect, as evidenced to the Trustee by the written certification of the Company, and which certification specifies further that all necessary consents and approvals to such distribution have been ob-tained or (b)- the Company has furnished the Trustee with an l opinion of-counsel to the effect that no such orders are l necessary to authorize such distribution and that all neces-sary consents and-approvals to such distribution have been i obtained. 2.9 Alterations and Amendments. The Trustee and. the Company understand and agree that amendments may be required to this Agreement from time to time'to effectuate i the purpose of this Trust Agreement and to comply with amend-l ments to or changes in the Illinois Statute, the NRC Rule, '[ Future Orders, changes in tax laws:(including Section 468A of the Code), regulations or rulings-(whether published or. private) of:the Service (whether.or not directly relating to Section 468A of the Code), and any other changes in the laws ( applicable to the~ Company, the Plants or the Trusts created hereunder. The Company and the Trustee may amend this. Agree ' i ment to the extent necessary or desirable-to effectuate such purpose or to comply with such changes. The Company shall furnish the Trustee with an opinion of legal counsel that any such amendment does not violate the Illinois Statute, the-NRC Rule or uny Future Orders and would not result.in the dis-qualification of-the Trust ~ Fund as " nuclear decommissioning reserve funds" under Section 468A of.the Code and that all necessary approvals'to such amendment have been_obtained;. provided, however, sin any event, the-Trustee may decline to adopt such amendment, if such amendment materially increases 4 L the expenses or responsibilities of the Trustee and no ade-quate provision has been made to compensate the Trustee for such increase, or.if the Trustee would be unable with reason-able effort to comply with its duties as to be amended. 2.10 No Authority to Conduct Business. The pur-l pose of this Trust Agreement is limited to the matters set L forth in Section 1.3 above. This Agreement shall not be construed to confer upon the Trustee any authority to conduct business. L i ARTICLE III: GENERAL PROVISIONS RELATING TO THE TRUSTEE The appointment of any successor Trustee, provi-sions governing resignation and compensation of the Trustee, p L. ~

p i' Jnto X and the general.-rules l governing the relationships.of the q TrusteeDand the Company and any third parties are as fol-lows:- l t </ 3.-1 Desionation and Oualification of successor ~ ~ Trustees. _At.any time during the term of this Agreement, the .l t Company shall have the'right to remove the Trustee acting hereunder and' appoint another qualified entity as a successor trustee upon 30 days' notice in writing to the Trustee, or upon such shorter notice as may be acceptable toLthe Trustee. Any. Trustee shall have-the right to. resign at any time upon 30 days notice in writing to the Company and upon such resignation the Company shall appoint another qualified entity as-a successor Trustee. Notwithstanding the fore-going, no such removal or resignation shall be effective until the:ICC'has approved the successor Trustee. Any successor Trustee shall qualify by a duly acknowledged acceptance of this Agreement and the trusts created hereunder, delivered to the Company. Upon acceptance 1 of such appointment by the successor Trustee, the Trustee shall transfer to such successor Trustee the Trust Fund. 'Any successor Trustee shall have all the rights, powers, duties and obligations herein granted to the original Trustee. If for any reason the Company is unable to or:does not, in the event of the resignation or removal of the Trust-ee as provided above, appoint and have approved by the ICC a. successor Trustee within 90 days after such resignation or removal, either the Company or the Trustee may apply to a court of competent. jurisdiction for the appointment of a successor. Trustee. 3.2 Compensation and Reimburs_ement. The Trustee-t shall be. entitled to compensation from1each Trust held here-under at such rates as may be approved in writing from time H, to time by the Company.. Subject to the approval of the Company (which shall not be unreasonably withheld or de-layed), the Trustee shall be entitled to be reimbursed.from each Trust held hcieucder for out-of-pocket expenses, in-cluding, but not limited to, expenses of agents, auditors and counsel, incurred in cornection with the administration of such Trust. 3.3 Transactions With Third Parties. No person or organization dealing with the Trustee hereunder shall be required to inquire into or to investigate its authority for entering into any transaction or to see to the application of the proceeds of any such transaction. 3.4 Financial St6tements. The Trustee shall furnish monthly financial statements (audited by the Trust-ee's internal audit staff) for each Trust to the Company not later than the 15th business day of the following month. The,

(( 'l y financial statementsishall show the financial condition of the Trust,-including,cwithout11 imitation, the market value of f - the assets, and the-income _and expenses of each Trust for.the JX - period since the preceding statement. Any such financial 6 - statement may be approved.by'the Company byfwritten: notice to the Trustee or by failure to object to such" financial state. ment within six months of the date upon which such: financial L . statement was delivered.to the Company.. The approval of.any L such financial statement'shall constitute a full and complete j - discharge of the Trustee as to all matters set forth in such

financial statement; provided, however, that the foregoing shall not relieve or absolve the Trustee from any liability, associated _ with a failure to perfor.n its fiduciary responsi-

- bilities.- The financial statements shall be audited annually by independent certified public accountants employed by!the Trustee,, subject to the limitations contained in Section 4.8-hereof. The Trustee shall furnish such financial statements to the ICC as required by law. 3.5 - Tax Returns and Other ReDorts. The Trustee shall-prepare or cause to be prepared such income or other tax = returns and such reports as may be required from time to time and shall nrovide copies thereof to the Company.in advance of thei:: filing for review by the Company. The Trustee shall provide to the Company all statements, docu-ments, lists, or other information reasonably requested by j the company. 1Nie Trustee shall also sign all such. returns .I and file them or cause them to be filed with the appropriate j government ager.cles. The Trustee shall cooperate with all i requests made by regulatory agencies and shall provide copies -{ to the Company in advance of all information submitted to regulatory agencies. At the Company's request, the Trustee 3 shall testify with respect to the Trusts-and the Trust Fund in' proceedings before reguletory agencies. 9 1 3.6 Nominees; Depositogleg. If the Trustee em-1 ploys an agent or depository, specifically for purposes of providing services related to any Trust held hereunder (other - than a securities broker),:the Trustee shall disclose to such 1 agent or depository that it is employed on behalf of such 1 Trust. Subject to Section 3.9(b) hereof, the Trustee shall be liable for such Trustee's own acts or omissions (and those of its officers and_ employees) occasioned by the willful misconduct or negligence of such Trustee (and that of its i officers and employees), and shall be liable for the acts of its nominee, or of any agent or depository or any nominee of any agent or depository with which any security of any Trust is deposited by the Trustee, as the case may be, with respect to any security registered in the name.of the Trustee's nominee or in the name of the nominee of any such agent or t...

m ~ l depository, or with respect to-any security of such Trust deposited with any agent or depository, and shall be liable for its acts and the acts of.any such agent or depository 1 'with_ respect to the holding of securities in bulk. The Trustee, or the Investment Manager with respect to;an." investment' manager account" (as hereinafter defined)- (and, in either case, not the Trusts), shall also be liable for any tax" imposed' pursuant to Section 4951 of the Code, as such section is made applicable to the Trusts, the Trust Fund, or the Trustee, and any applicable successor provi-sion. 3.7 Future Orders. The Company shall promptly advise the Trustee in writing of the existence of any Future Orders?having the effect of imposing new or different respon- -l sibilities upon the Trustee under this-Agreement, j 3.8 Anoointment of Investment Manacer. The Compa-ny shall have the right from time to time to appoint and remove one or more Investment Managers for any Trust held hereunder and to direct the segregation of any part or all of any such Trust into one or more accounts to be known.as L " investment manager accounts" and it it does so, it shall appoint an individual, partnership, association, or corpora. l tion as Investment Manager to manage the portion of any Trust so segregated._ Written notice of any such appointment and/or-removal shall be given to the Trustee and the Investment q Manager so appointed. The appointment shall be accomplished. using an investment manager agreement-signed by.the Company and the Investment Manager and acknowledged by the Trustee.- As long:as the1 Investment' Manager is acting, the_ Investment Manager shall have full authority to direct the acquisition,. L retention and disposition of the-assets-from time to time comprising the investment manager account being managed by I I the Investment Manager, and.except as set forth in the fol- ) lowing paragraph, the Trustee shall have no duty or obliga-tion to review the assets from time to time comprising such 1 investment manager account, to make any recommendations with respect to the acquisition, retention and disposition there-of,._nor to determine whether any direction from the Invest-- -ment Manager is proper or within the terms of this Agreement. L The Trustee shall have no liability or responsibil- -ity to the Company or the Trusts for acting on the direction L of, or for failure to act in the absence of directions from, the Investment Manager for any investment manager account. The Trustee may assume that any investment manager account previously established and the appointment of any Investment Manager for that account continues in force until receipt of written notice to the contrary from the Company. Pending L receipt of directions from the Investment Manager, any cash _9

y -~ c p, 4 v received:by the Trustee from time.to time:for any investment 0 manager account'shall be-invested'upon receipt-in investments' j ~ from-which such cash:(including any earnings thereon)J may be withdrawn on a daily basis. The Trustee shall' review the-transa;tions in'any such investment manager account on a 1 daily basiscfor.the-purpose'of determining whether any assets acquired;or any pending asset acquisitions (as to which the Trustee has been given information) are permissible invest-ments.under-the guidelines established for such-account and the. provisions of Section 4.3Ehereof. -In making any such~ review with respect-to. unrated debt securities permitted under Section 4.3(b), the Trustee mcy rely upon the writtenL opinion of-the applicable Investment Manager in determining-whether a particular unrated debt security is permitted thereunder. In the event that the Trustee determines as a -result of any such daily review that an investment is not permitted under either-the guidelines established for such account.or the provisions of Section 4.3 hereof, then-it shall-notify the Company and:the applicable Investment Manag-er within one business day of such determination by tele-phone, confirmed-in writing. If the applicable Investment-Manager does not sell the unpermitted investment within two . business days of such oral notice, then the Trustee shall' sell such unpermitted investment within four business ~ days:of. d such oral' notice. The Trustee shall also advise the Invest-ment Manager of information it receives from an issuer or 'similar source regarding calls, redemptions, purchase offers and similar. matters relating-to assets held in any Trust hereunder. The company will indemnify the Trustee and hold it harmless from any liability or expense-in connection with or arising-out of (1-) any action: taken or omitted or any in-- d vestment or: disbursement. of any part of the investment manag-er account made by the Trustee atLthe: direction of the Investment Manager, or (11) any actiont taken by the Trustee F pursuant to a notification of an order.to purchase or sell -securities issued by an Investment Manager directly to a broker or dealer under a power of attorney. 3.9 Certain Duties and Resoonsibilities of the Trustee.- (a) In the absence of bad faith on its pert, the . Trustee may conclusively rely upon' certificates or opinions furnished to the Trustee and conforming to the requirements of this Agreement; but in the case nf any such certificates or opinions which by any provision hereof are specifically required to be furnished to the Trustee, the Trustee shall' have no duty to examine the same to determine whether or not .they conform to the requirements of this Agreement unless the representative of the Trustee involved with the certificate in question has actual knowledge of the fclsity of any state-ment made therein. -

? '[ (b)! No. provision of this Agreement shall=be' con- - struedito relieve the: Trustee from'11 ability for its own negligent 1 action,.its'own-negligent failure to act, or-its I own willful misconduct, except.that (1) this. Subsection sha'11' not beLeonstrued to-limit the effect of Subsection (a).of this section; (ii) the Trustee shall not be liable for any error'of judgment.made in goodcfaith by a responsible officer of Trustee, unless it shall be proved-that the Trustee was negligent'in ascertaining the pertinent facts or was other-wise negligent in making the. judgment; and-(111) no-provision-of this-Agreement shall require the Trustee to expend or risk its own funds.or otherwise incur any financial liability'in' the performanceLof any of-its duties hereunder, or in the f exercise of any of its rights or powers, if it shall have. - reasonable grounds for believing that repayment of such funds or adequate indemnity against such risk or liability is not-reasonably assured to it. 3.10 Certain Richts of Trustee. Except as other-wise provided:in Section 3.9 hereof: (a) Any request or directio.s of the Company mentioned herein shall be sufficiently evidenced.by a. written request c r-direction signed, prepared or furnished by en authorized representative of thet Company or a verbal or telephonic request or. order confirmed within a reasonable time by such'a writ-l ten request or direction, and.any action of the board:of directors of the Company may be suffi-ciently evidenced by a certificate of the Company's secretary or assistant secretary; (b) Whenever in the administration of any Trust' created under this Agreement the Trustee shall deem it desirable that a matter be' proved or L established prior to taking,; suffering or omitting any action hereunder, the-Trustee (unless other L evidence be herein specifically prescribed) may, in the absence of bad faith on its part, rely upon the certificate of an authorized representative of the Company; (c) The Trustee may consult with counsel and the written advice of such counsel or any opinion of such counsel shall be full and complete authori-zation and protection in respect of any action taken or omitted by it hereunder in good faith and !1 in reliance thereon; and (d) The Trustee shall be under no obligation to exercise any of the rights or powers vested in it by this Agreement at the request or direction of the Company pursuant to this Agreement, unless the.. - - - 4

"JE, 1 r 4 y b Company shall ha'e: offered to the Trustee reason-v able security oritndemnity against the costs,- expenses =and/11 abilities which-might be incurred by itcin compliance with such request or' direction. ' ARTICLE IV: TRUSTEE'S POWERS The1 Trustee shall have, with respect lto each Trust held hereunder, the following powers, all of which powers are fiduciary powers tx) be exercised inLa fiduciary capacity and in the best interests'of such Trust,'and which are to be exercised as the Trustee, acting in such fiduciary capacity, in'its discretion, shall determine, except that the Trustee shall_not act in its discretion but'only at the directioniof v. an appointed-Investment Manager in the exercise of those' powers.given-in Sections 4.2, 4.3, 4.4=and 4.5 hereof with: respect to the acquisition, retention, and disposition of.the assets of an investment manager account, and, except as g otherwise provided,-which are intended in no way to 1imit the 1, general powers ofithe office, namely: 4.1 Payment of ExDenses of Administration. To incur and pay any and all charges, taxes,c and expenses upon-or connected with each Trust held hereunder in the discharge of its fiduciary obligations under this Agreement, but-to charge said. amounts.to such. Trust only to the' extent that L such amounts are directed-to be paid 1from=such Trust'by:the-Company _ pursuant to Section 3.2 hereof or may be incurred and paid from such Trust without causing 1the Trust to become 5 disqualified under Section 468A of the Code. 4.2 Prudent' Investments. Subject to the limita-tions provided in Section 4.3 hereof, to invest the assets of each Trust only in assets that are prudent investments for E assets held in trust'and in such a way as to attempt to maximize the after-tax returns thereon. 4.3 Investment of Trust Fund. Pending use of any Trust held hereunder for the purpose of this Trust, to invest s and reinvest all or any part of such Trust, including any i undistributed income therefrom; provided, however, that.no j such investment or reinvestment may be made by the Trustees (a) In any investments not permitted under L Section 468A(e)(4)(C) of the Code; or (b) In any bond or other evidence of indebt-edness (other than an obligation of the United States) that does not have a rating of "A" or better from Moody's Investors Service or "A" or better from Standard & Poor's or in unrated debt securities that, in the opinion of the Investment Manager, are not of at least such "A" or better quality; or _

ml1VL -% 'i cm Ce W iu

(c). In any deposit with-a banking institu-tion unless such. banking institutionLhasinot less than $350 million in equity capitalion a current.

market value basis and the debt securities of which .have:a rating equivalent to (i) an "Aa" or better l from Moody's Investors Servi *e or (ii) an "AA" or -l .better from Standard & Poor's or (111) a "B" or

better from Keefe, Bruyette'& Woods,.Inc.; or P

(d) In any security or asset.cf any operator of a nuclear power plant; or (e) Which would contravene any Future Orders a in effect at the time such investment or- .i reinvestment is made and previously furnished to r e the Trustee with reference to the Trusts, i L Any investment or reinvestment made by an Investment Manager. 1 L shall be reviewed by the-Trustee for compliance with-(a), L -(b), (c), (d) and (e) above as provided in Section 3.8 here-- of. i All investments must be suf ficiently liquid txt enable each-Trust to fulfill the purpose of.this Agreement L and to satisfy obligations as they become due as communicated l in writing to the Trustee, and absent a written communica - tion, the Trustee shall invest each separate Trust as though such Trust had no short or intermediate term cash require-ments. Nothing irr this Section 4.3 shall be construed as requiring the. Trustee to make any investigation as'to.when any of the Plants may be decommissioned or when obligations: relating to'such-decommissioning may be expected'to become r p due. f 4.4 Manacement of Trusts. To sell, exchange or otherwise dispose of all or any part of any Trust held here-under, without prior application to or approval by or order > of any court, upon such terms and in such manner and at such prices as-the Trustee shall determine; to modify, renew, or extend mortgages, bonds, notes, or other obligations or any installment of principal thereof or any interest due thereon and to waive any defaults _in the performance of the terms and conditions thereof; and to execute and deliver any and all assignments, bonds, or other instruments in connection with these powers, at such times, in such manner and upon such terms and conditions as the Trustee may be deemed expedient. ~ The Trustee's determinations of manner of sales, terms, prices and the exercise of other powers granted herein, if reasonably made, are not to be questioned. Notwithstanding anything contained in this Agree-ment to the contrary, the Trustee may not authorize or carry out any sale, exchange, or other transaction between any f 6 + e 4 ,,Qy ' Trust and the Trustee.or any affiliate of the Trustee of the? x' iV kind: described in Treasury Regulation 1,468A-ST(b)lexcept the L payment of compensation and: expenses pursuant;to Section 3.2, 1 < hereof or unless such transaction is not an act of "self-e t[ dealing" within the meaning of Section 4951 of the Code, as M such section is made applicable to each Trust by Section 468A(e)(5) of-the Code. The Trustee shall not cause any Trust to engage in-any act of self-dealing.with-the Company. or any affiliate of the Company. The Company agrees to ag furnish the Trustee with the identity of persons who are L " disqualified persons" within the meaning of said Section 4951 of the Code'by reascn of.their affiliation ~with the i Company. 4.5 -Extension of Oblications and Necotiation:of ( Claims. Subject to the limitations contained in Sections 4.3-and 4.4 hereof, to renew or extend-the time of payment-of-any + l obligation,' secured or. unsecured, payable

or by any Trust,

.for as'long a period or. periods of time and on such terms as -it shall determine; and to adjust,' settle, compromise, and arbitrate claims or demands in favor of or against any Trust,- including claims for taxes, upon such terms as it deems advisable. ] 4.6 Recistration of Securities.. To hold any stocks, bonds, securities, and/or other property in the-name of a nominee, in a street name, or by other title-holding device, without indication of trust. 1 4.7 Location of Assets.. To keep any property f belonging to any Trust at any place in the United States. ,j b 4.8 Retention and' Removal of Professional Ser-- vice Providgrs. To employ attorneys, accountants. and custo-I dians as it shall deem advisable and to make such payments thereof as it shall deem reasonableffor the implementation of l the purpose of this Agreement. The Trustee shall have the absolute right to dismiss any such agents for any reason whatsoever; provided that the Trustee's selection of an accounting firm shall be subject to the prior consent of the Company, which consent shall.not be unreasonably withheld. i h 4.9 Deleaation of Ministerial Powers. To delegate 4 L to other persons such ministerial powers and duties as it may deem to be advisable. 4.10 Discretion in Exercise of Powers. To do any L' and al'1 other acts which the Trustee shall deem proper to l-effectuate the powers specifically conferred upon it by this L Agreement; orovided, however, that this section shall not authorize the Trustee to do anv act or participate in any transaction which would (a) disqualify any of the Trusts as a " nuclear decommissioning reserve fund" under Section 468A of L the Code; (b) contravene any provision of this Agreement; or E l L----

rO.. i 'A I (c) violate' the terms and conditions of, or cause any Trust held hereunder not to satisfy the requirements of, the Illi-t nois Statute,

he NRC Rule or any Future Order.

ARTICLE V MISCELLANEOUS PROVISIONS 5.1 Headinas. The section headings set forth in this Agreement are inserted for convenience of reference only and shall be disregarded in the construction or interpreta-tion of any of the provisions of this Agreement. 5.0 Particular Words. Any word contained in the text of this Agreement shall be read as the singular or plural as mai be applicable in the particular context. 3 Unless otherwise specifically stated, the word " person" shall be taken to mean and include an individual, partnership, association, trust, company, or corporation. 5.3 Severability of Provisions. Yf any provision l of this Agreement or its application to any person or entity L in any circumstances shall be invalid and unenforceable, the application of such provision to persons and in circumstances other than_those as to which it is invalid or unenforceable cnd the other provisions of this Agreement, shall not be affected by such invalidity.or unenforceability. 5.4 Form and content of communications. The names of persons authorised to act on behalf of the Company shall i be certifiec, with the specimen signature of any such person, to the Trustee by the. Company. Until notified in writing to the contrary, the Trustee shall have the right to assume that i there has been no change in the identity or authority of any person previously certified to it hereunder. 5.5 Gglivery of Notices Urdgr Aareement. Any notice required by this Agreement to ?>s given to the Company or the Trustee shall be deemed to have raen properly given -when delivered in person or when mailea postage prepaid, by registered or certified mail. Notices to the Company shall be addressed to: L Commonwealth Edison Company 37th Floor One First National Plasa Chicago, Illinois 60690-0767 Attention: Treasurer L 1.-

E I;, Notices to the Trustee shall be addressed to: The Northern Trust Company 50 South LaSalle Street t Chicago, Illinois 60675 5.6 Successors and Assions. Subject to the provi-sions of Sections 2.6 and 3.1 hereof, this Agreement shall be l binding upon and inure to the benefit of the Company, the Trustee, and their respective successors and assigns. l 5.7 Counterparts of Acreement. This Agreement has been executed in counterparts, each of which shall be deemed i to be an executed original. t 5.8 Governino Jurisdiction. The Trusts created hereunder are Illinois trusts and all questions pertaining to i their validity, construction, and administration shall be determined in accordance with Section 468A of the Code and, to the extent not inconsistent therewith, the laws of the State of Illinois. 5.9 Miscellaneous. The Trusts shall operate on an accounting year which coincides with the calendar year.- 1 IN WITNESS WHEREOF, the Company and the Trustee have as of-the day and year first above written, executed and i delivered this Agreement. F COMMONWEALTH EDISON COMPANY I By /s/ E. M. Roth Vice President THE NORTHERN TRUST COMPANY By /s / Gordon M. Suckow Vice President L L i l L 1

e n i EXHIBIT A DISBURSENENT CERTIFICATE The undersigned, being a duly authorized officer of Commonwealth Edison Company, an Illinois corporation (the " Company"), and, in such capacity, being duly authorized and empowered to e :ecute and deliver this certificate, hereby certifies to the Trustee of the Commonwealth Edison Company Tax Qualified Decommissioning Trust--(name of Plant (s)) (the " Trust (s)"), pursuant to Section.2.2(a) of that certain Trust Agreement dated December 8, 1988 (the " Agreement"), between the Company and the Trustee, as follows: (1) There is due and owing to each Payee (" Payees") (all/e portion of) the invoiced cost to the Company for goods or services provided in connection with the decommissioning of the (name of Plant (s)) as evidenced by the Invoice Schedule (with supporting er.hibits) attached as Exhibit I hereto; (2) All such amounts due and owing to such Payees constitute Qualified Costs; (3) All conditions precedent to the making of this disbursement set forth in any agreement between each such Payee and the Company have been fulfilled; (4) No Payee is a " disqualified person" within the meaning of Section 46BA and 4951 of the Code by reason of an affiliation with the Company or, if any are,. hen the payment constitutes compensation or payment or reimbursement of expenses which are reasonable and necessary to carry out the purpose of the Trust (s) and the payment is not excessive; and (5) The payment of the amounts owing meets the requirements of the Illinois Statute, any Future Orders and the Code, and all necessary consents and approvals for such payment have been obtained. Accordingly, you are directed to permit the disbursement of the amounts indicated on Exhibit I hereto from the Trust (s) in order to permit payment of such sum (s) to be made to the aforementioned Payees for such purpose. You are further directed to disburse such sum (s), once withdrawn, directly to such Payees in the manner indicated on Exhibit I hereto, on-or before the date indicated in such Exhibit 1.

L P 1 Although you are under no obligation to make any further inquiry or investigation or to obtain any further documentation, it is understood that you may, in your discretion, elect to withhold any such disbursement to any i Payee unless and until you receive written releases, in form satisfactory to you, of any liens, security interests, or claims of such Payee against the Company or its property as ) you may, in your discretion, require. ) 1 Capitalized terms used herein without definition shall have the meanings given to such terms in the Agreement. j WITNESS my hand this day of i COMMONWEALTH EDISON COMPANY - i By: q Duly Authorized Officer t s h 9 e i I t l

i e' b i EXHIBIT D WITHDRAWAL CERTIFICATE { The undersigned, being a duly authorized officer of 5 Commonwealth Edison Company, an Illinois. corporation (the " Company"), and, in such capacity, being duly authorized i and empowered to execute and deliver this certificate, hereby i certifies to the Trustee of the Commonwealth Edison Company Tax Qualified Decommissioning Trust--(name of Plant (s)) (the " Trust (s)"), pursuant to Section 2.2(a) of that certain Trust Agreement dated December 8, 1988 (the " Agreement"), between the Company and the Trustee, as follows: l (1) The Company has paid, and is entitled to. [ reimbursement for, amounts paid for goods or services i provided in connection with the decommissioning of the [name of Plant (s)) as described in the schedule (with supporting exhibits) attached as Exhibit I hereto; (2) All such amounts paid constitute Qualified Costs; (3) No Payee was a " disqualified person" within the meaning of Section 466A and 4951 of the Code by reason of an affiliation with the Company or, if any were, then the payment constituted compensation or payment or reimbursement of expenses which were reasonable and necessary to carry out the purpose of the Trust and the payment was not excessive; and I (4) The payment of the amounts met the i requirements of the Illinois Statute, any Future Orders and the Code, and al) necessary consents and approvals for such payment had been obtained. Accordingly, you are directed to permit the disbursement of the amounts indicated on Exhibit i hereto from the Trust (s) l in order to reimburse the Company for such payments. You are further directed to disburse such sums, once withdrawn, directly to " Commonwealth Edison Company" on or before the date indicated in Exhibit I hereto. -w -,---n m. m m m

7:. i' Capitalized terms used herein without definition shall have the meanings given to such terms in the Agreement. i i WITNESS my hand this day of COMMONWEALTH EDISON COMPANY f By: Duly Authorized Officer j 'r I f i i i g I' k s l r a b b l P t 4 i m w n , - + w e,- m--

w ~ i-Exhibit VI t i Trust Agreement Dated December 8. 1988 Between Commonwealth Edison Company and The Northern Trust Company (Non-Tax Qualified Decommissioning Trust) 7687C/6

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[Confornied Copy) TRUST AGREEMENT Dated December 8, 1988 Between y. COMMONWEALTH EDISON COMPANY and [ THE NORTHERN TRUST COMPANY (Non-Tax Qualified Decommissioning Trust) "~ l l l t l l e 1 k i l-i .v

i =. 3 1 a Table of Contents Pace ARTICLE I: DEFINITIONS, NAME AND PURPOSE i 1.1 Definitions............................... 2 1.2 Names of Trusts........................... 3 1.3 Purpose of Trust Agreement'................ 3 ARTICLE II: ESTABLISHMENT OF SEPARATE TRUSTS AND DISPOSITIVE PROVISIONS 2.1 Establishment of Separate' Trusts.......... 3 2.2 Payment of Nuclear Decommissioning Costs.. 4 2.3 Additions to Trusts....................... 4 2.4 Remittance of Taxes....................... 4 2.5 No Transferability of Interest in any Trust 5 2.6 Time of Termination....................... 5 2.7 Distribution of Trust Upon Termination....- 5 2.8 Alterations and Amendments 6 2.9 No Authority to Conduct Business.......... 6 ARTICLE III: GENERAL PROVISIONS RELATING TO THE TRUSTEE 3.1 Designation and Qualification of Successor Trustees..................... 6 3.2 Compensation and Reimbursement 7 3.3 Transactions With Third Parties........... 7 3.4 Financial Statements...................... '7_ 1 r L 3.5 Tax Information Returns and Other Reports. 8 3.6 Nominees; Depositories.................... 8 3.7 Future Orders............................. 8 3.8 Appointment of Investment Manager......... 9 3.9 Certain Duties and Responsibilities of l the Trustee........................... 10 L 3.10 Certain Rights of Trustee............... 11 i i ARTICLE IV: TRUSTEE *S POWERS l 4.1 Payment or Provision for Expenses o l Administration......................... 12 4.2 Prudent Investments....................... 12 4 '. 3 Investment of Trust Fund................. 12 4.4 Management of Trusts...................... 13 l 4.5 Extension of Obligations and Negotiation of Claims.............................. 14 l l

1. i

<c. -4 Page 4.6 Registration of Securities............... 14 4.7 Location of Assets....................... 14 r 4.8 Retention and Removal of Professional i i Service Providers..................... 14 4.9 Delegation of Ministerial Powers.......... 14 4.10 Discretion in Exercise of Powers......... 15 L u ARTICLE V: MISCELLANE0tlS PROVISIONS 5.1 Headings.................................. 15 5.2 Particular Words.......................... 15 5.3 Severability of Provisions................ 15 5.4 Form and Content of Communications 15 5.5 Delivery of Notices Under Agreement 15 5.6 Successors and Assigns.................... 16 5.7 Counterparts of Agreement 16 5.8 Governing Jurisdiction.................... 16 5.9 Miscellaneous 16 -EXHIBIT At Form of Disbursement Certificate EXHIBIT B: Form of Withdrawal Certificate i l l l I l l. I f i 1

i..

1

W TRUST AGREEMENT THIS TRUST AGREEMENT (" Agreement") is made this 8th day of December, 1988, between Commonwealth Edison Company, an Illinois corporation (the " Company"), and The Northern l Trust Company, a banking association, having trust powers (hereinafter, together with any successors in office, called the " Trustee"). WHEREAS, the Company is the owner in whole or in part of each of the Plants (as hereinafter defined); WHEREAS, the Company is subject to regulation by the Illinois Commerce Commission ("ICC") and the Nuclear Regulatory Commission ("NRC"); l WHEREAS, pursuant to the Illinois Statute (as hereinafter defined), the Company has established Qualified Trusts (as hereinafter defined) for each Plant pursuant to a Trust Agreement dated December 8, 1988, between the Company. and the trustee named therein (the " Qualified Trust Agree-ment"),-establishing the Commonwealth Edison Company Tax Qualified Decommissioning Trust Fund; and WHEREAS, pursuant to the Illinois Statute, the Company must establish a non-tax qualified decommissioning trust for each Plant, each of such trusts to be funded by contributions from the Company; NOW, THEREFORE, the Company shall deliver Schedules to this Agreement to the Trustee, and the Trustee shall i acknowledge receipt of any funds described thereon repre-senting the initial funding of the Trusts (as hereinafter-defined) with respect to the Plants described or referenced on such Schedules; TO HAVE AND TO HOLD, such Trusts and such addition-al funds as may from time to time be added thereto as pro-vided herein, together with the proceeds and reinvestments thereof (hereinafter collectively called the " Trust Fund") unto the Trustee; IN TRUST NEVERTHELESS, for the use and purposes and upon the terms and conditions hereinafter set forth:

f a ARTICLE It' DEFINITIONS. NAME AND PUP, POSE 1.1. Definitions. As used in this Agreement, the following terms shall have the following meanings: " Agreement," " Trust Agreement" and the terms "here-of," "herein," " hereto," and " hereunder," when used in this Agreement, shs11 mean end include this Agreement as the same may from time to time be amended, modified, or supplemented. " Code" shall mean the Internal Revenue Code of 1986, as it may be amended from time to time, and the regula-tions promulgated thereunder. " Disbursement Certificate" shall mean a document properly' completed and executed by the Company substantielly in the~torm vf Exhibit A hereto. " Future Orders" shall mean any orders of the ICC, NRC or the Federal Energy Regulatory Commission issued, and any Federal or state laws adopted, in connection with the retention, investment and utilization of funds for the costs of decommissioning of any Plant. '~ " Illinois Statute" shall mean Section 8-508.1 of the Illinois Public Utilities Act (Ill. Rev. Stat. ch. 111-2/3, 58-508.1). as it may hereafter be amended. "NRC Rule" shall mean the " General Rwquirements for Decommissioning Nuclear Facilities" of the NRC (53 Fed. Reg. 24018, June 27, 1988) as it may hereafter be amended. " Plant" shall mean each, and " Plants" shall mean all, of the nuclear power plants listed on the separate L Schedules attached to this Agreement (as such Schedules may-be supplemented from time to time by the Company by written notice to the> Trustee). Each unit of a multi-unit nuclear power plant site shall be considered as a separate Plant for l the purposes of this Agreement. " Qualified Costs" shall mean the Company's costs incurred in the decommissioning of a Plant, to the extent that such costs may be paid out of a Trust without contra-vening the Illinois Statute or any Future Order. " Qualified Trust" shall mean each, and " Qualified i Trusts" shall mean all, of the separate funds established pursuant to the Qualjfied Trust Agreement for each of.the Plants. l l 1

Kv " Service" shall mean the Internal Revenue Service. " Trust" shall mean each, and " Trusts" shall mean all, of the separate funds created and listed on the separate Schedules attached to this Agreement as such Schedules may be supplemented from time to time by the Company by written notice to the Trustee. " Withdrawal Certificate" shall mean a document properly completed and executed by the Company substantially in the form of Exhibit B hereto. 1.2 NAggs_of Trusts. Each Trust shall be known as the " Commonwealth Edison Company Non-Tax Qualified Decommis-sioning Trust - [name of Plant)". The Trusts, collectively, shall be known as the " Commonwealth Edison Company Non-Tax Qualified Decommissioning Trust Fund." 1.3 Purpose of Trust Agreement. The purpose of this Agreement is to provide funds for the contemplated decommissioning of the Plants listed on the separate Sched-ules attached hereto and to comply with the Illinois Statute, the NRC Rule and any Future Orders. i ARTICLE II: ESTABLISHMENT OF SEPARATE TRUSTS AND DISPOSITIVE f>30 VISIONS The Trustee shall manage, invest, reinvest and, after payment of the expenses described in Section 4.1 here-of, distribute each Trust as follows: 2.1 Ettablishment ot _Eeoarate Trusts. The Trustee shall establish a separate Trust hereunder for each Plant. Each time the Company makes a contribu+. ion to the Trust Fund, it shall designate the amount of such contribution allocable to each such separate Trust. The Trusten shall maintain separate records for each Trust and shtIl credit thereto its pro rata share of all income of the Trust Fund and charge thereto its pro rata share of all expenses (other than ex-L penses attributable to a particular Plant which shall be expenses charged to the Trust named for such Plant) and any losses. Until otherwise instructed in writing by the Compa-ny, nothing in this section 2.1 or elsewhere herein shall be deemed to require the Trustee to segregate.or invest sepa-rately. assets of the Trust Fund, it being intended that the L assets of the Trust Fund may be maintained and invested and reinvested ;? a common pool, but shall not be required to be so maintainec,or invested. 1, l L

I

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2.2 Payment of Nuclear Decommissionino Costs. The Trustee shall make payments.of Qualified Costs in accordance. with the following procedures: (a) Disbursements to Third Parties. The Trustee shall make payments of Qualified Costs to any person (other than the Company) for goods providsd or labor or other services rendered to the Company in connection with the decommissioning of a Plant within five business days of receipt of the Disbursement Certificate. (b) Etimbursement to the Company. The Trust-ee shall make payments to the Company in reimburse-ment of Qualified Costs actually incurred by the Company and paid to any other person within-five business days of receipt of a Withdrawal Certifi-cate. The Trustee.shall be under no duty to inquire into the cor-rectness or accuracy of matters contained in a Disbursement Certificate or Withdrawal Certificate unless representatives of the Trustes then approving any withdrawal or disbursement' based on such certificate have actual knowledge of the falsi-ty of any statements made therein. The Company will indemni-fy the Trustee and hold it harmless from any tax imposed pursuant to Section 4951 of the Code with respect to a dis-bursement or. reimbursement made by the Trustee pursuant to this Section 2.2 in reliance on a Disbursement Certificate or a Withdrawal Certificate, respectively, provided representa-tives of the Trustee then approving such disbursement or. reimbursement do not have actuel knowledge of the falsity of-any statements made in the related-Disbursement Certificate or Withdrawal Certificate that would have prevented the imposition of such tax. 2.3 Additions to Tru111 From time to time prior-to the termination of each Trust hald hereunder, the Company may make, and the Trustee shall accept, additional-contribu-tions of funds to any separate Trust held hereunder to satis-fy the purpose of this Trust Agreement as set forth in Section 1.3 hereof. The making of a contribution by the Company shall constitute the certification of the Company that all necessary consents and approvals to such contribu-tion have been obtained. 2.4 ggpittance of Taxes. The Trustee shall remit to the Company annually within 15 business days after the Company's request therefor the amount from each Trust which the Company certifies as the amount by which the Company's federal and, if applicable, state income taxes for the pre-ceding fiscal year were increased by the not income of such "~ust. The Trustee shall be under no duty to inquire into the correctness or accuracy of any such certificate. a .a. + 2.5. No Transferability of Interest in any Trust. The interest of the company in any Trust is not transferable, i whether voluntarily or involuntarily, by the Company nor subject to the claims of creditors of the Company; orovided, however, that any creditor of the Company as to which a ' Disbursement Certificate for a Trust has been properly com-i pleted and submitted to the Trustee may assert a claim di-rectly against such Trust in an amount not to exceed either the amount specified on such Disbursement Certificate or the amount of such Trust available to pay costs other than ) amounts then owing the Trustee under Section 3.2 hereof. ) 2.6 Time of Termination. Each Trust hereunder i shall terminate, to the extent provided in this Section 2.6, upon the earlier to occur of the following events: (a) In whole, upon the substantial completion of the nuclear decommissioning of the Plant for i which such Trust was created and named and as o evidenced to the Trustee by the written certifica-tion of the company. (b) To the extent allowed or provided under " the Illinois Statute, the NRC Rule or any Future Order, upon the disposition by the Company of any L interest in the Plant for which such Trust was j named. (c) In whole, upon the distribution of all of the assets from the Trust. 1 The Trust Fund shall terminate when all of the separate j L Trusts have terminated. ] l I l 2.7 Dietribution of Trust Uoon Termination. - Upon l termination of each Trust, the Trustee shall distribute the entire remaining amount of the Trust, including all accrued, i i l accumulated, and undistributed net income, to the Company; provided, however, that no such distribution shall be made i unless either (a) an order of the ICC and the NRC specifical. 1 l ly authorizing such distribution is in effect, as evidenced to the Trustee by the written certification of the Company, and which certification specifies further that all necessary l consents and approvals to such distribution have been ob-tained or (b) the Company has furnished the Trustee with an opinion of legal counsel to the effect that no such orders l l are necessary to authorize such distribution and that all necessary consents and approvals to such distribution have been obtained, l l + . m a --- m m em-- - s '

3 2.8 Alterations and Amendments. The Trustee and the Company understand and agree that amendments may be required to this Agreement from time to time to effectuate the purpose of this Agreement and to comply with amendments to or changes in the Illinois Statute, the NRC Rule, any Future Orders, changes in tax laws, regulations or rulinge l (whether published or private) of the Service, and_any other changes in-the laws applicable to the Conipany, the Plants or l the Trusts created hereunder. The Company and the Trustee may amend this Agreement to the extent necessary or desirable to effectuate such purpose or to comply with such changes. The Company shall furnish the Trustee with an opinion of legal counsel that any such amendment does not violate the l Illinois Statute, the NRC Rule or any Future Orders and that all necessary approvals to such amendment have been obtained; crovided, however, in any event, the Trustee may decline to adopt such amendment, if such amendment materially increases the expenses or responsibilities of the Trustee and no ade-quate provision has been made to compensate the Trustee for such increase, or if the Trustea would be unable with reason-able effort to comply with its duties as to be amended. 2.9 No Authority to Conduct Business. The pur "' pose of this Agreement is limited to the matters set forth in Section 1.3 hereof. This Agreement shall not be construed to confer upon the Trustee any authority to conduct business. ARTICLE III: GENERAL PROVISIONS RELATING TO THE TRUSTEE The appointment of any successor Trustee, provi-sions governing resignation and compensation of the Trustee, l and the general rules governing the relationships of the Trustee and the Company and any third parties are as fol-lows: 3.1 Desionation and oualification of Successor Trustees. At any time during the term of this Agreement, the Company shall have the right to remove the Trustee acting hereunder and appoint another qualified entity as a successor trustee upon 30 days' notice in writing to the Trustee, or upon such shorter notice as may be acceptable to the Trustee. Any Trustee shall have the right to resign at any time upon 30 days' notice in writing to the Company and upon such resignation the Company shall appoint another qualified entity as a successor Trustee. Notwithstanding the fore-going, no such removal or realgnation shall be effective until the ICC has approved the successor Trustee..

f. b i u. Any successor Trustee shall qualify by a duly ) acknowledged acceptance of this Agreement and the trusts' created hereunder, delivered to the Company. Upon acceptance of such appointment by the successor Trustee, the Trustee j shall transfer to such successor Trustee the Trust Fund. Any successor Trustee shall have_all the rights, powers, duties and obligations herein granted to the original Trustee. If for any reason the Company is unable to or does I not, in the event of the resignation or removal of the Trust-i ee as provided above, appoint and have approved by the ICC a j successor Trustee within 90 days after such resignation or i removal, either the Company or the Trustee may apply to a court of competent jurisdiction for the appointment of a successor Trustee. 3.2 Compensation and Reimbursement. The Trustee shall be entitled to compensation from each Trust held here-i under at such rates as may be approved in writing from time to time by the Company. Subject to the approval of the l Company (which shall not be unreasonably withheld or de-layed), the Trustee shall be entitled to be reimbursed from each Trust held hereunder for out-of-pocket expenses, in-I cluding, but not limited to, expenses of agents, auditors and counsel, incurred in connection with the administration of such Trust. t 3.3 Transactions With Third Parties. No person or organization dealing with the Trustee hereunder shall be required to inquire into or to investigate its authority for l entering into any transaction or to see to the application of the proceeds of any such transaction. 3.4 Finaacial Statements. The Trustee shall furnish monthly financial statements (audited by the Trust-ee's internal audit staff) for each Trust to the Company not later than the 15th business day of the following month. The financial statements shall show the financial condition of the Trust, including, without limitation, the market value of i the assets, and the income and expenses of each Trust for the l period since the preceding statement. Any such financial statement may be approved by the Company by written notice to the Trustee or by failure to object to such financial state-ment within six months of the date upon which such financial statement was delivered to the Company. The approval of any such financial statement shall constitute a full and complete discharge of the Trustee as to all matters set forth in such financial statement; orovided, however, that the foregoing shall not relieve or absolve the Trustee from any liability associated with a failure to perform its fiduciary responsi-7 I -., - ~,

[ bilities. The financial statements shall'be audited annually by independent certified public accountants einployed by the ' Trustee, subject to the limitations contained in Section 4.8 hereof. The trustee shall furnish such financial statements to the_ICC as required by law. 3.5 Tax Information Returns and Other Reports. The Trustee shall prepare or cause to be prepared such income or other tax information returns and such reports as may be required from time to time and shall provide copies thereof to the Company in advance of their filing for review by the Company. The Trustee shall provide to the Company all state-ments, documents,. lists, or other information reasonably requested by the Company. The Trustee shall also sign all such information returns and file them or cause them to be filed with the appropriate government agencies. The Trustee shall cooperate with all requests made by regulatory agencies and shall provide copies to the Company in advance of all information submitted to regulatory agencies. At the Compa- -ny's request, the Trustee shall testify with respect to the Trusts and the Trust Fond in proceedings before regulatory agencies. 3.6 Ngminggar Deoositories. If the Trustee em-ploys an agent or depository, specifically for purposes of providing services related to any Trust held hereunder (other than a securities broker), the Trustee shall disclose to such agent or depository that it is employed on, behalf of such Trust. Subject to Section 3.9(b) hereof, the Trustee shall be liable for such Trustee's own acts or omissions (and those of its officers and employees) occasioned by the willful misconduct or negligence of such Trustee (and that of its officers and employees), and shall be liable for the acts of its nominee, or of any agent or depository or any nominee of any agent or depository with which any security of any Trust is deposited by the Trustee, as the case may be, with respect to any security registered in the name of the Trustee's nominee or in the name of the nominee of any such agent or depository, or with respect to any security of such Trust deposited with any agent or depository, and shall be liable for its acts and the acts of any such agent or depository with respect to the holding of securities in bulk. 3.7 ruture Orders. The Company shall promptly advise the Trustee in writing of the existence of any Future Orders having the effect of imposing new or different respon-sibilities upon the Trustee under this Agreement. _g. I i i

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3.8 Aroointment of Investment Manaae r.. The Compa-1; ny shall have the.right from time to timo to appoint and remove one or more Investment Managers for any Trust held 1 - hereunder and to direct the segregation of any part or all of any such Trust into one or more accounts to be known as " investment manager accounts" and if it does so, it shall appoint an individual, partnership, association, or corpora-tion as Investment Manager to manage the portion of any Trust so segregated. Written notice of any such appointment and/or removal shall be given to the Trustee and the Investment Manager so appointed. The appointment shall be accomplished using an investment manager agreement signed by the Company and the Investment Manager and acknowledged by the Trustee. As long as the Investment Manager is acting, the Investment Manager shall have full authority to direct the acquisition, retention c.nd disposition of the assets from time to time comprising the investment manager account being managed by the Investment Manager, and except as set forth in the fol-lowing paragraph, the Trustee shall have no duty or obliga-tion to review the assets from time to time comprising such investment manager account, to make any recommendations with respect to the acquisition, retention and disposition there-of, nor to determine whether any direction from the-Invest-ment Manager is proper or within the terms of this Agreement. The Trustee shall have no liability or responsibil-ity to the Company or the Trusts for acting on the direction of, or for failure to act in the absence of directions from, the Investment Manager for any investment manager account. The Trustee may assume that any investment manager ac ount previously established and the appointment of any Investment Manager for that account continues in force until receipt of written notice to the contrary from the Company. Pending receipt of directions from the Investment Manager, any-cash received by the Trustee from time to time for any investment manager account shall be invested upon receipt in investments from which such cash (including any earnings thereon) may be withdrawn on a daily basis. The Trustee shall review the transactions in any such investment manager account on a daily basis for the purpose of determining whether any assets acquired or any pending asset acquisitions (as to which the Trustee has been given information) are permissible invest-ments under the guidelines established for such account and the provisions of Section 4.3 hereof. In making any such review with respect to unrated debt securities permitted under Section 4.3(a), the Trustee may rely upon the written opinion of the applicable Investment Manager in determining whether a particular unrated debt security is permitted thereunde; In the event that the Trustee determines as a result of any such daily review that an investment is not 9

l permitted under either the guidelines established for such account or the provisions of Section 4.3 hereof, then it i shall notify the company and the applicable Investment Manag- ) er within one business day of such determination by tels-phone, confirmed in writing. If the applicable Investment Manager does not sell the unpermitted investment within two business days of such oral notice, then the Trustee shall sell such unpermitted investments within four days of such oral notice. The Trustee shall advise the Investment Manager of information it receives from an issuer or similar source regarding calls, redemptions, purchase offers and similar matters relating to assets held in any Trust hereunder. The Company will indemnify the Trustee and hold it l harmless from any liability or expense in connection with or arising out of (1) any action taken or omitted or any invest- ~ ment or disbursement of any part of the investment manager account made by the Trustee at the direction of the Invest-ment Manager, or (ii) any action taken by the Trustee pursu-l ant to notification of an order issued by an Investment L Manager to purchase or sell securities directly to a broker or dealer under a power of attorney. 3.9 certain Duties and Responsibilities of the Trustee. (a) In the absence of bad faith on its part, the i Trustee may conclusively rely upon certificates or opinions furnished to the Trustee and conforming to the requirements of this Agreement; but in the case of any such certificates or opinions which by any provision hereof are specifically required to be furnished to the Trustee, the Trustee shall have no duty to examine the same to determine whether they l conform to the requirements of this Agreement unless the representative of the Trustee involved with the certificate in question has actual knowledge of the falsity of any state-l ment made therein. 1 l (b). No provision of this Agreement shall be con-i L strued to relieve the Trustee from liability for its own i negligent action, its own negligent failure to act, or its 1 own willful misconduct, except that (1) this subsection shall not be construed to limit the effect of Subsection (a) of this section; (ii) the Trustee shall not be liable for any L error of judgment made in good faith by a responsible officer of Trustee, unless it shall be proved that the Trustee was negligent in ascertaining the pertinent facts or was other-i wise negligent in making the judgment; and (iii) no provision of thie Agreement shall require the Trustee to expend or risk its own funds or otherwise incur any financial liability in l the performance of any of its duties hereunder, or in the l 1 ! i m. _ _ _ _ _ _ _ __. _ _ _ _. _ _,. - - -_.. _ _ ~ _,

sc exerc'se of any of its rights or powers, if it shall have i reasonable grounds for believing that repayment of such funds or adequate indemnity against such risk or liability is not reasonably assured to it. 3.10 Certain Richts of Trustee. Except as other-wise provided in Section 3.9 hereof: (a) Any request or direction of the Company mentioned herein shall be'sufficiently evidenced by a written request or direction signed, prepared or furnished by an authorized representative of the Company or a verbal or telephonic request or order confirmed within a reasonable time by such a writ-ten request or direction, and any action of the board of directors of the Company may be suffi-ciently evidenced by a certificate of the Company's i secretary or assistant secretary; (b) Whenever in the administration of any Trust created under this Agreement the Trustee shall deem it desirable that a matter be proved or established prior to taking, suffering or omitting'~ any action hereunder, the Trustee (unless other evidence be herein specifically prescribed) may, in the absence of bad faith on its part, rely upon the certificate of an authorized representative of'the Company; (c) The Trustee may consult with legal coun-i sel and the written advice of such counsel or any opinion of such counsel shall be full and complete authorization and protection in respect of any t 1 action taken or omitted by it hereunder in good faith and in reliance thereon; and i (d) The Trustee shall be under no obligation to exercise any of the rights or powers vested in 3 it by this Agreement at the request or direction of ~ the Company pursuant to this Agreement, unless the Company shall have offered to the Trustee reason-able security or indemnity against the costs, expenses and liabilities which might be incurred by it in compliance with such request or direction. ARTICLE IV: IRUSTEE'S POWERS The Trustee shall have, with respect to each Trust I held hereunder, the following powers, al.1 of which powers are L fiduciary powers to be exercised in a fiduciary capacity and in the best interests of such Trust, and which are to be

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} exercised as the Trustee, acting in such fiduciary capacity, in its discretion, shall determine, except that the Trustee shall.not act in its discretion but only at the direction of an appointed Investment Manager in the exercise of those powers given in Sections 4.2, 4.3, 4.4 and 4.5 hereof with j respect to the ccqr.isition, retention, and disposition of the i assets of an inves'tment manager account, and, except as ) otherwise pro /ided, which are intended in no way to limit the 1 general powers of the office, namely: i 4.1 Payment or Provision for Expenseg of Admin (A-i tration..To incur, pay or make provision for any and all charges, taxes, and expenses upon or connected with each j Trust held hereunder in the discharge of its fiduciary obli-gations under this Agreement, but to charge said amounts to such Trust only to the extent that such amounts are directed to be paid from such Trust by the Company pursuant to Section 2.4'or 3.2 hereof. l 4.2 Prudent Investments. Subject to the limita-l l tions provided in Section 4.3 hereof, to invest the assets of l each Trust only in assets that are prudent investments for assets held in trust and in such a way as to attempt to maximize the after-tax returns thereon. 4.3 Investment of Trust Fund. Pending use of any Trust-held hereunder for the purpose of_this Agreement, to invest and reinvest all or any part of such Trust, including any undistributed income therefrom; orovided, however, that no such investment or reinvestment may be made by the Trust-i ee i (a) In any bond or other evidence of indebt-edness (other than an obligation of the United ~ States) that does not have a rating of "A" or better from Moody's Investors Service or "A" or better from Standard & Poor's or in unrated debt . securities that, in the opinion of the Investment-Manager, are not of at least such "A" or.better quality; or (b) In any deposit with a banking institu-I tion unless such banking institution has not less l than $350 million in equity capital on a current market valae basis and the debt securities of which have a rating equivalent to (i) an "Aa" or better from Moody's Investors Service or (ii) an "AA" or better from Standard & Poor's or (iii) a "B" or better from Keefe, Bruyette & Woods, Inc.; or i i l

4; (c) In any security or asset of any operator i of a nuclear power plant; or (d) Which would contravene any Future Orders in effect at the time such investment or 1 reinvestment is made and previously furnished to i the Trustee with reference to the Trusts. i Anv investment or reinvestment made by un Investment Manager sh' ell be reviewed by the Trustee for compliance with (a), i (b), (c) and (d) above as provided in Section 3.8 hereof. i Investments and reinvestments of the assets of a Trust may be i made in equity securities, orovided (1) such investments are diversified so as to minimite the risk of large losses, 1 unless under the circumstances it is clearly prudent not to do so, and (ii) such investments are prudently selected and monitoted. All investments must be sufficiently liquid to enable each Trust to fulfill the purpose of this Agreement ) l and to satisfy obligations as they become due as communicated i in writing to the Trustee, and absent a written communica- { tion, the Trustee shall invest each separate Trust as though*~ 1 such Trust had no short or intermediate term cash require-ments. Nothing in this Section 4.3 shall be construed as j requiring the Trustee to make any investigation as to when any of the Plants may be decommissioned or when obligations i relating to such decommissioning eay be expected to become q due. l' 4.4 Manacement of Trusts. To sell, exchange or otherwise dispose of all or any part of;any Trust held here-under, without prior application to or approval by or order 1 of any court, upon such terms and in such manner and at such . prices as the Trustee shall determine; to modify, renew, or i extend mortgages, bonds, notes, or other obligations or any installment of principal thereof or any interest due thereon and to waive any defaults in the performance of the terms and i g conditions thereof; and to execute and deliver any and all u assignments, bonds, or other instruments in connection with l these powers, at such times, in such manner and upon such terms and conditions as the Trustee may be deemed expedient. The Trustee's determinations of manner of sales, terms, prices _and the exercise of other powers granted herein, if reasonably made, are not to be questioned. Notwithstanding anything contained in this Agree-ment to the contrary, the Trustee may not authorize or early out any sale, exchange, or other transaction between any Trust and a " disqualified person" within the meaning of l Section 4951 of the Code except the payment of compensation i

-d l and expenses pursuant to Section 3.2 hereof or unless such transaction is not an act of "self-dealing" within the mean-ing of Section 4951 of the Code, as such section is made applicable to each Trust.by paragraph (c)(3)(vi) of the Illinois Statute. The ".rustee shall not cause any Trust to 4 engage in any act of self-dealing with.the company or any i affiliate of the Company. The Company agrees to furnish the 1 Trustee'with-the identity of persons who are " disqualified persons' within the meaning of said Section 4951 of the Code by reason of their affiliation with the Company. 1 4.5 Extension of Oblications and Neactiation of Claims. Subject to the limitations contained in Sections 4.3 1 and~4.4 hereof, to renew or extend the time of payment of any ) obligation, secured or unsecured, payable to or.by any Trust, for as long a period or periods of time and on such terms as it shall determine; and, subject to the approval of the Company (which shall not be unreasonably withheld or de-layed), to adjust, settle, compromise, and arbitrate claims ) or demands in favor of or against any Trust, including claims for taxes, upon such terms as it deems advisable. I 4.6 Reaistration of Securitigt. To hold any stocks, bonds, securities, and/or other property in the name j of a nominee, in a street name, or by other title-holding device, without indication of trust. 4.7 Location of Assets. To keep any indicia of ownership of any property belonging to any Trust at a place within the jurisdiction of the district courts of the United States, except as otherwise authorized by the regulations j from time to time adopted under Section 404(b) 9f the Employ- ) ee' Retirement Income Security Act of 1974, as amended. ] l 4.8 Eglention and Removal of Professi,gnal Service l Providers..To employ attorneys, accountants, and custodians as it sha11' deem advisable and to make such payments thereof as the Trustee shall deem reasonable for the implementation of the purpose of this Agreement. The Trustee shall have the absolute right to dismiss any such agents for any reason whatsoever; provided that the Trustee's selection of an accounting firm shall be subject to the prior consent of the Company, which consent shall not be unreasonably withheld. l 4.9 Delecation of Ministerial Powers. Tc. delegate to other persons such ministerial powers and duties as it may deem to be advisable. l l l ) 1 . m. m ,--_u m m . m r

i 4,10 Discretion in Exercise of Powers. To do any and all other acts which the Trustee shall deem proper to. effectuate the powers specifically conferred upon it by this Agreement; crovidad, however, that this section shall not authorize the Trustee to do any act or participate in any transaction which would (a) contravene any provision of this Agreement; or-(b)' violate the terms and conditions of, or cause any Trust held hereunder not to satisfy the require-ments of, the Illinois Statute, the NRC Rule, any Future Order or any other applicable law, regulation or ruling. ARTICLE V: MISCELLANEOUS PROVISIONS 5.1 Headinas. The section headings set forth in this Agreement are inserted for convenience of reference only and shall be disregarded in the construction or interpreta-tion of any of the provisions of this Agreement. 5.2 Particular Words. Any word contained in the text of this Agreement shall be read as the singular or plural as may be applicable in the particular context. Unless otherwise specifically stated, the word " person" shall be taken to mean and include an individual, partnership, ~ association, trust, company, or corporation. 5.3 Egyerability of Provisions. If any provision of this Agreement or its application to any person or entity in any circumstances shall be invalid and unenforceable, the application of such provision to persons and in circumstances other than those as to which it is invalid or unenforceable and the other provisions of this Agreement, shall not be affected by such invalidity or unenforceability. 5.4 rorm and content of communications. The names of persons authorized to act on behalf of the Company shall be certified, with the specimen signature of any such person, to the Trustee by the Company. Until notified in writing to the contrary, the Trustee shall have the right to assume that there has been no change in the identity or authority of any person previously certified to it hereunder. 5.5 Delivery of Notices Under Aoreement. Any notice required by this Agreement to be given to the Company or_the Trustee shall be deemed to have been properly given when delivered in person or when mailed postage prepaid, by registered or certified mail. Notices to the Company shall be addressed to: . l

.s I Commonwealth Edison Company 37th Floor one First National Plaza l Chicago, Illinois 60690-0767 Attention: Treasurer i Notices to the Trustee shall be addressed tos The Northern Trust Company 50 South LaSalle Street Chicago, Illinois 60675 5.6 Successors and Assions. Subject to the provi-sions of Sections 2.5 and 3.1 hereof, this Agreement shall be binding upon and. inure to the benefit of the Company, the l Trustee, and +. heir respective successors and assigns. 5.7 Countercarts of Acreement. This Agreement has been executed in counterparts, each of which shall be deemed to be an executed original. i 5.8 Governino Jurisdiction. The Trusts created hereunder are Illinois trusts and all questions pertaining to. their validity, construction, and administration shall be i determined in accordance with the laws of the State of Illi-nois. 5.9 Miscellaneous. The Trusts shall operate on an accounting year which coincides with the calendar year. IN WITNESS WHEREOF, the company and tne Trustee L have as of the day and year first above written, executed and l -- delivered this Agreement. l COMMONWEALTH EDISON COMPANY By /s/ E. M. Roth Vice President .} THE NORTHERN TRUST COMPANY By /s / Gordon M. Suckow Vice President 1 l- ! l

c. EKHIBIT A DISBURSEMENT CERTIFICATE i The undersigned, being a duly authorized officer of Commonwealth Edison Company, an Illinois corporation (tho " Company"), and, in such capacity, being duly authorized and empowered to execute and deliver this certificate, hereby certifies to the Trustee of the Commonwealth Edison Company Non-Tax Qualified Decommissioning Trust--[name of Plant (s)) l (the " Trust (s)"), pursuant to Section 2.2(a) of that certain i Trust Agreement dated December 8, 1988 (the " Agreement"), i between the Company and the Trustee, as follows: (1) There is due and owing to each Payee (" Payees") (all/a portion of) the invoiced cost to the Company for goods or services provided in connection with the decommissioning of the [name of Plant (s)) as evidenced by the Invoice Schedule (with supporting exhibits) attached as Exhibit 1 hereto; i (2) All;such amounts due and owing to such Payees constitute Qualified Costs; ] (3) All conditions precedent to the making of this disbursement set forth in any agreement between each j such Payee and the Company have been fulfilled; (4) No Payee is a " disqualified person" within the meaning of Section 4951 of the Code by reason of an j affiliation with the Company or, if any are, then the payment constitutes compensation or payment or i reimbursement of expenses which are reasonable and ) l necessary to carry out the purpose of the Trust (s) and i the payment is not excessive; and (5) The payment of the amounts owing meets the I requirements of the Illinois Statute and any Future Orders and all necessary consents and approvals for such i l - payment have been obtained. Accordingly, you are directed to permit the disbursement of the amounts indicated on Exhibit I hereto from the Trust (s) in order to permit payment of such sum (s) to be made to the aforementioned Payees for such purpose. You are further directed to disburse such sum (s), once withdrawn, directly to i such Payees, in the manner indicated on Exhibit 1 hereto, on or before the date indicated in such Exhibit 1. J l ^

ix p' Although you are under no obligation to make any f-further inquiry or investigation or to obtain any further documentation, it is understood that you may, in your discretion, elect to withhold any such disbursement to any Payee unless and until you receive written releases, in form satisfactory to you, of any liens, security interests, or cinims of such Payee against.the Company or its property as you may, in your discretion, require. Capitalized terms used herein without definition shall have the meanings given to such terms in the Agreement. WITNES3 iny hand this day of COMMONWEALTH EDISON COMPANY By: Duly Authorized Officer 4 1 l ( 1 1 i i l

i ~ i ? n: l 1c EXHIBIT B b s WITHDRAWAL CERTIFICATE i The undersioned, being a duly authorized: officer of S E4 Commonwealth Edison (*.apany, an Illinois corporation.(the. b " Company"), and, in suci. capacity, being duly authorized and empowered to execute and deliver this certificate, hereby. certifies to the Trustee of the Commonwealth Edison Company lE. Non-Tax Qualified: Decommissioning Trust--[name of Plant (s)) -(the " Trust (s)")', pursuant to Section 2.2(b) of that=certain Trust Agreement dated December 8, 1988 (the " Agreement"), L, hotween.the Company.and.the Trustee, as follows: (1) _The Company has paid, and is entitled to-reimbursement for, amounts paid for goods or services-i providedlin-connection with the decommissioning of the L [name of Plant (s)) as described in the schedulel(with i supporting exhibits) attached as Exhibit I hereto; (2) 'All such amounts paid constitute Qualified 1 Costs; (3) No Payee was a " disqualified person" within H the meaning of Section 4951 of the Code by-reasonLof-an. j affiliation with the Company or, if any were, then the payment constituted compensation or payment or reimbursement of expenses which were reasonable-and necessary to carry out the purpose-of the Trust.and the l payment was not excessive; and (4) The payment of the amounts met the requirements of the Illinois Statute and any Future . Orders and the Code, and all necessary consents and approvals for such payment had been obtained. 3 Accordingly, you are. directed to permit the disbursement of the' amounts indicated on Exhibit'l hereto from the Trust (s) in order to reimburse the Company for-such payments. You are further directed to disburse such sum (s), once withdrawn, directly to " Commonwealth Edison Cc3pany" on or before the date indicated in Exhibit I hereto. d d -N'* m m-m

ro; Capital'ized: terms used.herein without definition shall have the meanings:given to-such terms-in.the Agreement. WITNESS my h'and this-day of COMMONWEALTH EDISott C'.t.PJ:JIY s Duly Authorized Officer -s m_. t s i f

,.6 " :: e G 5 i -Exhibit VII' n:: Commonwealth Edison Company Tax Qualified Decommissioning Trust Funds Financial Statements' as of December 31,=1989 7687C/7 i 4 j 1/

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1

y ARTHUR ANDERSEN & CO.

Cn:CAOO, ILUNOIS REPORT OF INDEPENDENT PUBLIC ACCOUNTANTS To the Trustee of the Commonwealth Edison Company Tax I Qualified Decommissioning Trust Fund: 1 We have audited the accompanying statement of net assets'of-4 the COMMONWEALTH' EDISON. COMPANY TAX QUALIFIED DECOMMISSIONING TRUST FUND (the " Trust") as of Decumber 31, 1989, and the related statement of changes in net assets for the period February 22, 1989 (inception), l. through December 31, 1989. These' financial statements are the respon-sibility o'r the' Trustee. Our-responsibility is to express an opinion on these financial statements based on our audit. We conducted our audit in accordance with generally accepted auditing' standards.- Those standards require that we plan and perform . the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. An audit includes exam-1 ining, on a' test basis, evidence supporting the amounts and disclo-i sures in the financial statements. An audit also includes assessing the~ accounting principles used and significant estimates made by management, as well as evaluating the overall financial statement presentation. We believe that our audit provides a reasonable basis t for our opinion.

+ ;p. In our opinion, the financial statements referred to above present fairly, in all material respects, the net: assets of.the Trust-as-of December 31, 1989, and the changes in its net' assets for'the period February 22, 1989 (inception), through December. 31, 1989, in conformity with generally accepted accounting principles. g -Our audit was made for the-purpose of forming.an opinion on the basic financial statements taken as a whole. The supplementary data disclosed in Schedules I and II are presented for purposes of additional analysis and are not a required part of the basic financial statements. This information has been subjected to the auditing pro-cedures applied in our audit of the basic financial statements)and, in our opinion, isfrairly stated in all material respects in relation to-the basic financial statements taken as a whole. b \\b. ARTHUR ANDERSEN & CO. Chicago, Illinois, March 30, 1990. m 5 i )

's 6 Ei -_ ~ COMMONWEALTH EDISON COMPANY TAX QUALIFIED DECOMMISSIONIN0JTRUST FUND = STATEMENT OF-NET ASSETS AS OF DECEMBER 31, 1989 I 1 (In thousands) ASSETS: Receivables-Interest 2,899 Contribution from Commonwealth Edison Company 63,832-4 66,731: Investments, at market value. Short-term investments (aggregate cost $6,501): 6,505 United States government and agency securities ~ (aggregate cost $13,591) 14,409 ' Municipal' bonds (aggregate cost'$139,211) 140,400 4161,314; Total assets -$228,045 LIABILITIES: Accrued' fees payable to the Trustee and ~ 211 investment managers . Income taxes payable 171 s Accumulated deferred income taxes 612 Total liabilities 8 994 Net assets $227,051

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The accompanying notes to financial statements are an integral part of this statement. 2

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p e,

a f i n s b ~ COMMONWEALTH EDISON COMPANY TAX QUALIFIED DECOMMISSIONING TRUST FUND [ ff . STATEMENT OF CHANGES IN NET ASSETS FOR THE PERIOD ~ FEBRUARY 22, 1989 (INCEPTION) THROUGH DECEMBER 31,- 1989 [ (In thousands)- NET ASSETS:- Beginning of period i ~ ADDITIONS: $216,828 Commonwealth Edison Company contributions Investment income 9,908 i Net realized gain on. sale of. investments 1,413 Net unrealized gain on investments 2,011- .i ~ 1 Total additions $230,160 g DEDUCTIONS: Provision for income taxes 2,818 Trustee and investment-managers' expenses 291 l l' Total deductions 3,109 Net additions $227,051 i f NET. ASSETS: End of period $227,051 s E

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The accompanying notes to financial statements are an integral part of this statement. t u 4 {

^ ! 4 h r COMMONWEALTH EDISON COMPANY TAX-QUALIFIED r DECOMMISSIONINO TRUST FUND t NOTES TO FINANCIAL STATEMENTS r DECEMBER 31, 1989 I (1) DESCRIPTIONLOF THE TRUST: Illinois law requires public utility operators of nuclear. power plants,.such as Commonwealth Edison Company (the " Company"),-to ( establish external trusts to hold -funds to-cover the costs of the. t eventual decommissioning of nuclear power plants. In 1988, the Illinois Commerce Commission (the "ICC") issued an order approving, among other things, the Company's proposed. method of funding its-j ' obligations'with respect to decommissioning costs. In accordance with the ICC order, the Company contributed in 1989 approximately $152,996,000 to a Tax Qualified Trust Fund (the " Trust"), representing the maximum tax deduction allowed by rulings of the Internal Revenue Service with respect to certain past collections, and $9,221,000 to a-Non_ Tax Qualified Trust Fund, primarily representing the first. annual payment of the remaining past collections being made ratably over the remaining book lives of the plants to which the payments relate. . With respect to subsequent decommissioning fund collections, the;ICC order requires the Company to contribute such amounts to the - r trusts annually. The ICC allows decommissioning costs of $66 million .to be. recovered annually in rates. Decommissioning costs are esti-mated to aggregate $2.4 billion, in current-year dollars, for all of the Company's nuclear units. Below is an analysis of contributions made and to be made to the Tax Qualified and Non-Tax Qualified Trust Funds (in thousands): Tax Non-Tax Qualified Qualified Total Contributions in 1989 for years prior to 1989 $152,996 $ 9,221 $162,217 Contributions in 1990 for 1989 Amounts recovered in 1989 $ 63,832 $ 2,168 $ 66,000 1989 amortization of amounts collected prior to September 12, 7,929 7,929 1988 Contributions receivable at December 31, 1989 $ 63,832 $10,097 $ 73,929

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Contributions for the period ended December 31, 1989 $216,828 $19,318 $236,146

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HR-, -h . Custody "of the funds' is maintained by' The Northern Trust Chapany ' (th'e " Trustee")~ under a Trust Agreement dated December 8, .1988. : Thel Trustee utilizes four investment management companies to: invest and manage theLTrust Tunds collected.. Investment of funds in the_ Trust is limited to securities permitted under Section 468A(e)(4)(C) of the Internal Revenue Code. The Trust Agreement places. further restrictions on investments in debt of other entities and_ deposits with banks. Investment in any security of an operator of al nuclear power plant is prohibited, per the Trust Agreement. The Trust, which is irrevocable, is scheduled to terminate upon completion of the decommissioning of the nuclear. generating stations.~ Any-unpaid amounts in the Trust are to be' returned'to the Company.. (2)

SUMMARY

OF SIGNIFICANT ACCOUNTING POLICIES: (a) Valuation of Investments-Investments are stated at fair market value as determined by the Trustee, by reference to published market data. The difference - between aggregate _ market value and the aggregate cost (as adjusted for discount or. premium amortization, see Note 2b) of the investments at December 31,_1989, is reflected as net unrealized gain on-investments . in the statement of changes in net assets. (b) Investment Income-Investment interest income earned during the period but not received as of December 31 is accrued for in the accompanying finan-cial statements. !' hen significant, _ discount and premium amortization are included in 1..<estment income in the accompanying financial statements and are-included in the determination of realized and unrealized gains or losses on investments. Het amortization resulted in a $365,000 increase in investment income in 1989. Realized and-unrealized gains or losses also reflect the effects of not amortizing-discounts and premiums. (c)-Investment Transactions-Investment transactions are accounted for on a settlement-date basis. The cost of investments sold is determined on a specific identification basis. (d) Trust Expenses-Expenses of administration and management of the Trust are based upon the market value of the investments held by the Trust and are. paid from the Trust fund. During 1989, Trustee and investment managers' fees totaling $291,000 for the Trust were incurred. w

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1 e ' Trust expenses incurred during the period but not paid 1 as of 1 / December-31 have-been accrued for in the accompanying. financial' statements. ,je)= Income Taxes-( The Internal Revenue Code Section 46BA, enacted in-1984,- I - allows a utility to elect, under certain conditions, a current-year - Federal 11ncome tax deduction for future nuclear power plant decommis- 'sioning costs contributions that are reflected in the utility's currently authorized revenue requirements. The Company has received a Schedule of Ruling Onounts from the -Internal Revenue Service for each of its 13 units qualifying it for such _a deduction. Funds-con-tributed for' eventual decommissioning are~ set aside in an external ' trust. A separate tax. entity has been established.for the Trust. ~ Income earned by the Trust is taxable under' Federal corporate income tax regulations. Taxes due on=the net earnings of the Trust are paid from Trust funds.. Taxes due from underpayments at December 31.have been accrued for in the accompanying financial statements. Deferred 3 income taxes are provided for all book-tax timing differences. The r Trust is exempt from Illinois state income tax. (f) Allocation of Trust Funds to Operating Units-Contributions to the Trust are allocated to each nuclear l generating unit based on the lower-of the -cost-of service amounts l approved by theLICC and the ruling amounts approved by the Internal L RevenueLService. -The income and expenses of the Trust'are allocated-to each-nuclear generating unit based on'the initial contributions allocatedito the units. Schedule II discloses financial. data by-nuclearsgeneratingsunit for the period-ended ~ December 31, 1989. (_3)~ INCOME TAXES: L The components of the provision for income taxes for the period February 22, 1989, through December 31, 1989, are as follows 1 (in-thousands): Current $2,206 Deferred 612 i L Total provision for income taxes $2,818 233332 l J hms +

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The.following. table, reconciles.the differences-between recorded Federal income taxes.and= amounts determined ~on income before taxes by applying.the Federal = statutory tax rate of-34% (dollar =

- amounts :in thousands): ~ Pretax income $13,041 3EE3EES ~ Expected Federal' income taxes at . $ 4,434 statutory rate-Tax-exempt interest income on municipal . bonds. (1,662)' .. Hunicipal bonds-Premium amortization

46

. Total provision for income taxes $ 2,818 333333E Effect'ive tax rate (total provision for income taxes /pretax income) '22% 333 ? L, l~ l 6 4) .-+

~ 4 ~ ?3CNE98LE ~ ^ COMMONWEALTH EDISON ' COMP ANY T AI QU ALIFIED DECOMMISSIONING TRUST FUND SCHEDULE OF INVESTMENTS DECEMBER 31. 1989 Par Value Cost Market Value D e s e r 1 p t'i o n U. S. GOVERNMENT AND AGENCY SECURITIES: U. S. Treasury, Series B-1999, 9 125% note, due $ 11,750,000.00 $ 11,780,768.75 $ 12,598,233 00 U.-S. Treasury, 10.75% bond, due February 15, 2003 1,500,000.00 1,809,843 75 1,S10,305 001 May 15,'1999 Total U. S. Government and agency securities ~ $ 13,250,000.00 $ 13.590,612.50 $ 14,408,538.00 MUNICIPAL BONDS: Alabama State Refun,2ing capital appreciation. 05 bond, due September 1, 2000/ August 31, 1999 8 4,600,000.00 $ 2,164.7 38 34 $ - 2,2 37,118.00. Amarillo, Texas, Health Facilities. Corp. Hospital, Revenue High Plains Baptist PJ-A, variable rate bond, due October.1, 2018/ January 29, 1990, 7-day put 1,000,000.00 1,000,000.00 1,000,000.00' Arizona Educational LN. Marketing Corp. Educational LN, Revenue Series A, due September 1, 2001/ March 1, 1999 - 1,750,C00.00 1,742,790.00 1,747,235.00 Arlington, Texas, Independent School District School Building and Refunding UT, 7.00% bond, due August 15, 1,000,000.00 995,700.00 1.015,580.00 1999/1998 Arlington, Texas, Waterworks and Sewer Revenue Refunding, 1,000,000.00 997.500.00 1,002,470.00 Series A, 6.805 bonds, due June 1, 1998 Aurora, Colorad o, Rerunding G/0, 6.605 bond, due 1,000,000.00 1,000,000.00 1,006,190.00 ~ December 1, 1996 Austin, Texas, Utility System Revenue. - 10.755 bond, due 1,000,000.00 1,294,437.91 1,311.550.00 May 15, 2010, prererundr i..May 15, 2000, at $100 Baltimore County Md. Met. District 60th Issue UT, 1,000,000.00-1,000,000.00' 1,005,260.00-Series 6.505 bond, due July 1, 1999 Bexar County,- Texas, Health Facilities Development Corp. variable Hospital Revenue, Southwest Texas' Methodist, 1,000,000.00 1,000,000.00 1,000,000.00 rate bond, due March 1, 2019, 7-day ' put Birmingham, Alabama, Crossover Refunding, 8.00% bond, 1,000,000.00 1.068.240 36 1,058,040.00 due October 1, 2015/1997 Broward County, Florida, School District UT, 6.75% bond, 2,000,000.00 1,963,500.00 1,991,600.00-due February 15, 2000/1999 California State Veterans Bonds, Series-AY, 6.755 bond, .1.008,290.00 due April 1,.1998/'995, call from special redemption 1,000,000.00 .997,000.00 subject to amount Chesapeake, Virginia, Pub. Impt. UT, 8.505 bond, due 815,000.00 897,884.68 914,463 00' July 1, 1998 \\

a-

SCREDULE.*c Coetinec Marke

,2 5'i Par Value Cost s D e s e r i p'tti on MUNICIPAL BONDS Jcontinued): Building Comm. Building Revenue, Chicago, Illinois, Pub. Series A, Community College District 508, 7.505 bond, . 1,046,610.00 1,000.000.00 $' 1,056,C72272 $. 1, 1999 due January Illinois,' Wastewater Transmission Revenue,. 6.805 bond, due November 15, 1999 1,000,000.00 992,820.00 993,450.00

Chicago, Chicago, Illinois, Water Revenue, 7.00% bond, due 1,400,000.00 1,367,716.00 1,375,626.00, November 1, 2004/1996 Chicago, Illinois, Water Revenue, 0% bond, due 2,700,000.00 1,191,128.74 1,188,621.00 November 15, 2001 Colorado Springs, Colorado, variable purpose, Series 89-A UT, 6.85% bond,' due September 1, 1,000,000.00 986,170.00 998,480.00 2004/1999

. Student Loan, Colorado Student Obligation Bd. Auth. Series B, adjustable rate bond, due December 1, 2002/ July 15, 1989, call for spec. redemption, 7-day put 1,000,000.00 1,000,000.00-1,000,000.00 Connecticut State G/O capital appreciation 0% bond, 3,545,000.00 1,857,779.80 1,907,706.00' due July 1, 1999 Connecticut State Housing Finance Authority, Housing Mtg. Finance Program Series C, 7.00% bond, due November 15, 1999, call from special redemption 1'000,000.00 1,000,000.00 1,003,810.00 subject to amount Cook and Will Counties, Illinois Township High School District No. 206, Series A, 05, capital appreciation 3,075,000.00 1,170,751.57 1,185,351.00 bond, due December 1, 2003/2000 Ctr1. Tx. Higher Education Authority, Inc. Student Loan Revenue, variable rate, due December 1, 2002, 1,000,000.00 1,000,000.00 1,000,000.00 7-day put Dade County, Florida, Solid Waste System Spl. Obligation Revenue, Series A, 10.00% bond, due October 1, 2010, prefunded October 1, 1995, at.$102.00 1,000,000.00 1,148,993 54 1,184,650.00 District of Columbia, G/0, Series C, 7.801 bond, due 1,000,000.00 1,050,431.53 1,069,610.00 June 1, 1997/1996 Escambia County, Florida, Sales Tax Revenue, Series A, 1,960,000.00 1,960,000.00 1,986.950.00 6.95% bond, due January 1, 1999 Florida State Broward County, Expwy. Authority, 9.80% bond, due July 1, 2005, prerunded July 1, 1995, at 1,490,000.00 1,709,513 25 1,742,853.00 $102.00 Florida State Turnpike Authorit Turnpike Revenue, 1,000,000.00 1,047,132.25 1,044,100.00 7.75% bond, due July 1, 2009/ e999 Florida State Board of Education, capital outlay, Series A, 8.10% bond, due June 1, 1995 1,000,000.00 1,063,402.85 1,080,020.00 Garland. Texas, Independent School District School Building UT, 6.20% bond, due February 15, 2002/1997 -1,000,000.00 919,340.00 947,860.00 Georgia State G/0, Series B, 6.60% bond, due 1,000,000.00 1,003,169.42 1,001,610.00 July 1, 2002/1999 Georgia State G/C UT, Series D, 8.40% bond, due 1,000,000.00 1.092,487.29 1,113,680.00 June 1, 1997 Harris County, Texas,:. Health Facilities Developeent Corp., Spl. Facilities Revenue, variable rate bond, 1,500,000.00 1,500,000.00 1,500,000.00 due February 1, 2010, 7-day put

~ 2 a ~ ;. ~.. 1__ - c. r - SC#EDULE !

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i Continee5-l- r D e s e r.1 pt ion. Q value Cost-Market Value MUNICIPAL' BONDS (continued): Harris County, Texas. Health Facilities Development ~ Corp. Health Care System Revenue Sisters Charity Incarnate World Refunding, 6.601 bond, due . January 1, 1999/1991 870,000.00. $ 836,000.30 $ 842,047.00-Harris County, - Texas, Perm. Impt. - Refunding L7, ' 9.10% Harrisburg, Pennsylvania, Water and: Sewer Authority, ' 549,165.00 bond, due October 1, 1998/1995 500,000.00' '551,637.56 Sewer Revenue Refunding, Second Series capital appreciation, Of bond, due October 15, 1998 775,000.00 434,631.08 433,155.00 Harrisburg, Pennsylvania, Water and Sewer Authority, Sewer Revenue Refunding, Second Series capital appreciation, 0% bond, due October 15, 1999 1,165,000.00 608,794.62 603,703.00 Hawaii State, Series BN G/0, 7.00% bond, due June 1, 2001/1998 1,000,000.00 1,008,025.42. 1,018,200.00 i Honolulu, Hawaii, City. and County, Series B UT, 6.90% t bond, due October 1, 1997 1,000,000.00 1,008,823.60 1,024,880.00 Houston, Texas, G/0, Refunding, 6.955 bond, due February 1, 1999 ~ 3,900,000.00 3,900,000.00 3,953,859.00 Houston, Texas, Water System Revenue Pr. Lien, 8.20% bond, due December 1, 2016/1996 1,000,000.00 1,057,757.51 1.058.200.00. Houston, Texas, Water System Revenue, 5.255 bond..due December 1, 2007 1,800,000.00 1,455,552.00 1,510,128I00 Illinois State G/O, 7.005 bond, due Apell 1, 2002/1996 800,000.00 806,440.53 807,752.00 Illinois State Sales Tax Revenue Refunding, Series C, 6.8755 bond, due-June 15, 2015/1997 1,500,000.00 1,441,140.00 1,460,415.00 Illinois State Toll Highway-Authority, Northern Illinois. Toll Highway Revenue, 9.255 bond, due January 1, 2009/1996 1,000,000.00 1,137,143.62 1,152,780.00' Illinois State Sales Tax Revenue, Series I, 7.005 bond, due June 15,'2001/1999-1,000,000.00 1,007,535.66 1,015.070.00 Indianapolis, Indiana, Economic Development Revenue, Series 1989 Bowes Seal Fast Corp. Project, 7 3755 bond, due July 1, 2001 185,000.00 185,000.00 177.600.00 [ndianapolis, Indiana. Economic Development Revenue, Series 1989, Bowes Seal Fast Corp. ' Project. 7 3755 bond, due July'1, 2003 190,000.00 190,000.00 178,600.00 Indianapolis, Indiana. Economic Development Revenue, Series 1989, Bowes Seal Fast Corp. Project, 7.3755 bond, due July 1,11998 175,000.00 175,000.00 173,250.00 Indianapolis, Indiana, Economic Development Revenue, Series 1989 Bowes Seal. Fast Corp. Project, 7 3755 bond, due July 1,-1997-165,000.00 165,000.00 162,525.00 Indianapolis, Indiana, Economic Development Revenue, Series 1989, Bowes Seal Fast Corp. Project, 7.3755 ~ bond, due July 1,.1996 165,000.00 165,000.00 163,350.00 Indianapolis, Indiana, Economic Development Revenue, .l Series 1989, Bowes' Seal' Fast Corp. Project', 7.3755 bond, due July 1, 1999 175,000.00 .s75,000.00 171,500.00

is: e: .. ScusesLs 1J '*.Contineeej Descript i=o n Per Value Cost ' Market Value~ MUNICIPAL' BONDS (continued): Indianapolis, Indiana, Economic Development Revenue,. -Series 1989 Bowes Seal Fast Corp.. Projecti 7 3755 .185,000.00 4 179,450.00' bond, due July ~1, 2000 8 185,000.00 $ Indianapolis, Indiana, Economic Development Revenue, Series 1989, Bowes Seal Fast Corp.. Project. 7.3755 bond,'due July 1, 2002 190,000.00 190,000.00 '180,500.00 Indianapolis, Indiana, Economic Development Revenue, Series' 1989, Bowes Seal Fast Corp. Project, 7.3755 186,082.00-bond,'due. July 1, 2004 200,000.00 200,000.00 Indianapolis, Indiana, ' Economic Development Revenue, i Series 1989, Bowes Seal Fast Corp. Project, 7 3755 bond, due July 1, 1995. 155,000.00 155,000.00 .154,225.00 Intermountain Power Agency, Utah,. Power Supply Revenue Refunding, Series I, 9.005 bond,-due July 1, 2019/1995 1,800,000.00 1,986,809 33-2,006,928.00 Jacksonville, Florida, Electric Authority Revenue, St. Johns River Power Pk. System, Series 5, 9.505 bond, due October 1,-2020, prerefunded October 1, 1995, at $102.00 1,500,000.00 1,717.611.42 1,741,380.00 Kenal Peninsula Boro Alaska, G/0, 8.305 bond, due January 1, 1999 1,700,000.00 1,845,140.96 -1,858,865.00 Kentucky Turnpike Authority, Toll Road Revenue Refunding.. Series of. January 1, 1981, 6.1255 bond, due July i, 2008/1982 1,520,000.00 1,392,563 20 1,423,450.00 Los Angeles County California Transportation Comen. Sales ' Tax Revenue Rfdg., Series A, 8.005 bond, due July 1, 2018/1998 1,000,000.00 1,063,596.03 1,061,260.00 Louisiana Public Facilities Authority Revenue, Alton

i Ochsner Med. Foundation, Series C, adjustable rate bond, due May 1, 2025/ July 2, 1989, 7-day put 1,000,000.00 1,000,000.00 1,000,000.00 Louisiana Public Facilities Authority Hospital Revenue Refunding, General Health, Series:A, 6.505 bond,.

due November 1, 2014/1999 1,750,000.00 1,623,125.00 1,616,580.00 Louisiana State G/0,' Series C, 9.405 bond, due October 1, 2005, prerefunded October 1,

1995, at $102.00 1,500,000.00 1,702,875.87 1,731.120.00 Louisiana State Recovery District Sales Tax Revenue, 7.755 bond, due July 1,

1998/1995 1,000,000.00 1,043,092.49 1,046,180.00' Louisiana State, Series B, G/O 9 305 bond, due May 1, 2002, prerefunded May 1, 1995, at $ 102.00 1,000,000.00 1,131,214.54' 1,141,480.00 Madison County, Mississippi, School District UT, 6.255 921,250.00 930,930.00 4 bond, due June'1, 2009/1999~ Madison, Wisconsin, Met. Sewer District UT, 8.355 . 1,000,000.00 bond, due~ June 1, 2000 900,000.00 985,055.96 1,009,638,00 Marion County, Indiana, Hospital Authority, Hospital Facility Revenue Refunding, Methodist Hospital of Indiana, 7.205' bond, due. September 1.-1998 1,000,000.00 ~ 1,000,000.00 1,012,800.00-i Massachusetts Bay Transportation Authority, Massachusetts Transit System--TCRS FGIC,.6.805 bond, 1,991,940.00 due March 1, 2001' 2,000,000.00 2.013,037.48 .t s. .~ _,3, ,m -.,m, ,,~,4..

... ~ ~.,.... 'f . SCHED01.E ^ Continue D e s e r-1 p t ion Par Value Cost Market Value ~ MUNICIPAL BOND.i (continued): Massachusetts State Health and.. Educational Facilities Authority -Rovenue, Harvard University, Series J, 1,000,000.00 $ 1,09 4,728.67 $ - 1,111,590.00 8.75% bond, clue December-1, 2005/1995-Paul Metropolitan Co incil Minnesota, Minneapolis, St. Metropolitan Acea-Sewer, Series A 6.10% bond, due December 1, 1998/1995. 1,750,000.00 1,671,477.50 1,718,115.00 Milwaukee County, Wisconsin, UT, 7.10% bond,-due October 10, 2001/1996 1,000,000.00 1,016,449.81 ,1,014,830.00 Milwaukee, Wisconsin, Series BV G/O UT, 6.50% bond, 1,2 30,CGo.00 1,188,192 30 1,197,663 00 due June--1, 2004 -1,033,010.00 Minneapolis, Minnesota, G/O UT, 7.00%. bond, due 1,000,000.00 1,925,125.27 December 1, 1999 Minnesota State G/O UT, 6.805 bond, due August 1, 1,045,000.00 1,05C.519.24 1,059,714.00-2000/1998 Minnesota State Variable Purpose UT, 6.605 bond, due August 1, 2000/1999 1,000,000.00 1,001,0.?.24 1,003,810.00 Mississippi State G/0, 6.75% bond, due October 1, 1,000,000.00 988,940.90 1,002,090.00 2002/1999 Mississippi, State or, General Obligation, Highway Refunding, 1978 Series, 6.20% bond, due February 1, 2008, optional August 1 -1988 1,385,000.00 1,297,772.70 1,312,855.00 Monroe County, New York, G/0, Series B UT ' 7.00% bond, due June 1, 2002/1998 1,350,000.00 1,361,049.68 1,377,648.00 Mashv111e and Davidson County Metropolitan Government Tennessee Water and Sewer Revenue, 6.505 bond, 1,000,000.00 997,500.00 989,900.00 due April 1, 2002 Nevada State Refunding LT, 6.805 bond, due August 1, 2,000,000.00 '.1,992,500.00 1,997,820.00-2000/1999 Nevada State Series A G/0, 6.45% bond, due August 1, 1,000,000.00

996,250.00 989,670.00 1998 New Hampshire State Rerunding, Series A, 6.60% bond, 1,000,900.00 998,000.00 996,010.00 due April 1, 2001/1999 Trenton Orrice Complex, 0% bond, due June 15, 2002 4,600,000.00 2,002,624.56 1,986.510.00'-

New Jersey Economic: Development Authority Revenue. New Jersey State G/O Refunding, Series C, 6.505 bond, 1,000,000.00 996,960.00 997,080.00 due January 15, 2001/1999 New Jersey State G/0, 7.10% bond, due April 15, 2000/ 1,000,000.00 1,030,344.36 1,033,550.00 1997 New Jersey State G/0, 7.25% bond, due April 15, 2003/ 1,010,000.00 1,033,776.84 -1,052,935.00 1999 New York City Educational Constr. Fd. Revenue, Series A. 6.875% bond due April 1, 2001/ October 1, 1999 1,900,000.00 1,875,623 00 1,906,327.00 New York State Dorm. Authority Revenues, Rockefeller University College,'9.625% bond, due July 7, 2014/ 1,750,000.00 2,020,324.05 2,035,635.00 1995 New York State Dorm. Authority Revenues Refunding, SPL Obligation State University Educational Facilities, issue A capital appreciation, 0% bond, due 760,000.00 456,893.00 454,845.00 November 1, 1997 I

~ 3,; MN3. Coatiseee D'e s c'r'i p t ion' Par Valo? - -Cost' Market Value MUNICIPA'L BONDS (continued)- New York State Dorm. Authority Facilities Revenues Herunding, SPL Obligation State University Educational Facilities, Series A, capital appreciation. 05 bond, 1,400,851.52 8. 1,391,355.00- $ 2,250,000.00 $ due May 1, 1997 New York State Urban Development Corp. Revenue Correccional Facilities, Series G, 7.00% bond, due January 1, 2017 2,000,000.00 1,906,800.00 1,929,660.00 North Slope Boro Alaska, Series Y G/0, 7.15% bonds, 1,750,000.00 1,750,000.00 1,784,703.00 due July 1, 1999 Ohio State Building Authority Correctional Facilities. Series A, 7.155 bond, due March 1, 1999 1,000,000.00 1,000,000.00 1,025,390.00. Uhio St ate Liquor Profits Revenue Refunding, 6.805 bond, due March 1, 1998 1,000,000.00-996,660.00 .1,009,120.00 Ohio State Liquor Profits Revenue Refunding. 0% bond capital appreciation, due September 1, 1999 3,720,000.00 1,955,314.63-1,947,160.00-Oklahoma City, Oklahoma, G/O UT, 6.605 bond, due 1,000,000.00 976,250.00 1,001,260.00-June 1, 1998 Pennsylvania State G/0, Second Series, Series A UT, 6.8755 bond, due November 1, 2000/1999 2,000,000.00 1,991,080.00 2,032,500.00-Phoen i x, Arizona, Civic Plaza Building Corp. Excise Tax Revenue, Civic Plaza Garage, capital appreciation, 0% bond, due July 1, 1996 1,000,000.00 641,285.01 fo47,000.00 Plano, Texas, G/0, 8.505 bond, due July 1, 2000 1,240,000.00 1,386,580.25-1.426,620.00-Puerto Rico Electric Power Authority Revenue Rerunding, Series N, capital appreciation, OS bond, 4,300,000.00 2,057,293.95 2,013,733.00, due July 1, 2001 Rhode Island State Solid Waste Management Corp., Solid Waste Disp. Revenue Quanset Point adjustable cate bond, due December 1, 2008, subject to special 1,000,000.00 1,000,000.00 1,000,000.00 redemption, 7-day put Salt Lake City, Utah, Hospital Revenue IHC Hospital, Inc., Series A Refunding, 7.60% bond, due 1,000,000.00 1,000,000.00 1,015,610.00 February 15, 2020/1999 South Carolina State G/O Series U. Subuser U-A.. 6.80% bond, due February 1, 2002/1998 1,000,000.00 1,010,748.51 1,019,610.00 South Dakota State' Health and Education Facilities Authority Revenue, McKennan Hospital, Series 1985. Series A, 9.6255 bond, due July 1, 2015, prererunded 1,000,000.00 1,125,202.76 1,147,550.00: i I July 1, 1995, at $100.00 Texas State. Texas Public Financial Authority, Series A, 6.005 bond, due October 1, 2006/1998 2,100,000 00 1,861,041.00 1,918,896.00. I I Triborough Bridge and Tunnel Authority, New York l Revenues,' general purpose, Series P, 6.705 bond, due January 1, 1999 1,000,000.00 996,490.00-998,350.00 ~ Triborough Bridge and ' Tunnel Authority, New York ~ Revenues, general purpose, Series P 6.805 bond, .1.000,000.00 996,020.00' -996,830.00 due January 1, 2001/'999

SCHE 9tM.E' I '*' Continmed Deseript ion. Par'Yalue Cost Market Value MUNICIPALLBONDS (continued): Utah Housing Finance. Agency,'Ref.--Single Family Mortgage Pur.--Insured Federal Insured or GTD Mortgage Loans, Series A,'8.50% bond, 2 ~~ $ 2,000,000.00 $ 2,103,871.52 $ - 2,104.000.00 due July ' 7, ' 2004/1996 = Valdez, Alaska, C/0, 6.90% bond, due June 1, 2004 1,000,000.00 1,000,000.00 ~ 1,013,600.00, Vermont State Pub. Impt., 7.005 bond, due 1,000,000.00 1,012,500.78 1,027,100.00 October 1, 2003/1998 Virginia State Housing Development Authority Commonwealth Mt g., Series A, Subser. A-2, 8.1255 bond, due^ July 1, 2017/ January 1, 1998, call 2,000,000.00 2,052,684.45 2 C56,000.00 from special redemption Washington State G/0, 7.105 bond, due May 1, 1,000,000.00. 1,003,614.02 1,020,290.00 2000/1999 Washington Suburban Sanitation District MD. Sewer Disp.. ' Third Series UT, 7.00% bond, due December 1, 1998 1,250,000.00 1,274,834.59 '1.289,788.00-West Virginia State Parkways Economic Development and Tourism Authority Parkway Revenue, Series 1989, 6.905 bond, due July 1, 2000/1998 2,000,000.00 1,992,300.00 2.012,800.00-Wiscensin State G/O Refunding.. Series A, 7.10% bond, doe May 1, 2000/1998 750,000.00 761,787.43 768,398.00 Wisconsin, State of, general obligation, Series A, 9.40% bond, due April 1, 2000/1995 1,000,000.00 1,130,251.40 1,142,590.00 $ 15 3,740,000.00 $ 139,210.898.9 4 $ 140,400,310.00 Total municipal bonds SHORT-TERM INVESTMENTS: Illinois Health Facilities Authority Revenue Revolving Fund Pooled, Series D, 6.50%, IBN, due 500,000.00 $- 500,000.00 $ 501,577.00 January 10, 1990, Mand. put U. S. Treasury bill, due May 10, 1990 1,000,000.00 971,041.66 972.970.00 U. S. Treasury-bill, due January 25, 1990 15,000.00 14,714.87 14,942.00 Corp. Money Market Demand Fund invested cash 5.015.334.64 5,015.334.64 5,015,335.00 Total short-term investments $ 6,530,334.64 s 6,501,091.17 $ 6,504,824.00

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== $159.302,6v2.61 $161,313,672.00 Total investments

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~ armemmu e g 3 ] COMMONNEALTH EDISON COMP ANY T AI QUtt.lFIED -DECOMMISSIONING TRUST FUND-l i sea _ECTED FINANCI Al. DATA BY GENERATiteC UNIT FOR THE PERIOD FEBRUARY 22 1989 (INCEPTION) THROUGH DECEMflER 11 1989 (In tesousands) I j Quad-Quad-Dresden Dresden Dresden Cities Cities Zion Zion LaSa l l e t.aSa l l e ~= Py ron p ren -Braidwned Braldes y i Total Unit 1 Unit 2 Unit 3 Unit i Unit 2 tintt i Unit 2 Unit t tinit 2 ten t t t t3 nit 2 Unit 1 _tpa s t ?' NET ASSETS, BEGINtlING OF PERIOD '3 .' 8 8-Commonwealth Edtson Company .22,136 22.t?9 16,583. 16,574. 18.209 18,205 25,365 23.947.15.126. 10,300 '_10.295- ' 7.157 contributions 216,828 10.802 Investment income 9.908-555' t 070 't.070 793 193 882 882 8.238 1.139 654 347 -347 t )# Net realized gain on sale of insestments t.413 79 153 153 113 113 126 126 177 e62 +3 49l 49

2ts Deductions 3.109 174 336.

336 249 249 277 277 398 357 2f 5 .109 - 199 ~49 Book value $225.040 $ 31.262 $23.02) $23.016 $ 17.240 $ 17.23 8 $18,940 $18,936 $26.392 $24,89 8 $ 15,6' 8 $ t0,587 $10.582 ,7.272-Net unrealized gain on investments 2.059 113 217. 2t7 161 161 179 179 252 231 1.43 -70 70 29 NET ASSETS, END OF PERIOD ' $227.051 $18.375 $23,240 $23.233 $17,40 t $17,392 $19.119 $19,115 $26,644 $25,122 $15,80 s $10,657 8:0,652 $7. 300, assesses s:::::: assassa sssssas asssss: sassans asssses asssses assssas sass=== sessss: assenes mass.. ~ essess in e J- ~; ,__.._m_._-.-- ..wm.c I- .mm.a_m., e i- =... -... .-wa

's, i-c;p-p Exhibit VIII Commonwealth' Edison Company-Non-Tax Qualified Decommissioning Trust fund Financial Statements as of December 31, 1989' 7687C/8 i

L. ARTFUR. ANDERSEN 1 R r .c .c .. e u. i: COMMONWEALTH EDISON COMPANY - l ? NON TAX QUALIFIED-1 (-) DECOMMISSIONING TRUST FUND-FINANCIAL STATEMENTS i J AS OF DECEMBER 31,1989-L TOGETHER WTTH AUDITORS' REPORT I' l l t ? t '\\ r q l: l l-

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,f-4.. ARTHUR ANDERSEN & CO. CHICAOO. II.UNOIS REPORT OF' INDEPENDENT PUBLIC' ACCOUNTANTS L To the1 Trustee of the Commonwealth Edison Company Non-Tax Qualified-Decommissioning Trust Fund: l We have audited the accompanying statement of net' assets of the COMMONWEALTH EDISON COMPANY NON-TAX QUALIFIED DECOMMISSIONING

TRUST FUND :(the " Trust") as of. December 31, 1989, and'the related statement.of changes in net-assets for~the period September 6, 1989 (inception), through December 31, 1989.

These financial statements are-the responsibility of the Trustee. Our responsibility is to express;an' opinion on'these financial statements based on our-audit. We conducted our audit-in accordance with generally accepted auditing standards. Those standards require that we plan and perform 1 the: audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. An audit includes exam-ining, on a2 test. basis, evidence supporting the amounta and disclo- =sures'in the financial state,ments. An audit also includes assessing' the' accounting principles used and significant estimates made by management, as well as evaluating the overall financial statement presentation. We believe that our audit provides a reasonable basis for'our opinion. l l

t 2 s In',our -opinion,. the financial statements referred to above y 1 present fairly, in all' material respects, the netfassets of the Trust-i as' of December 31, 1989, and the changes in its net assets for the ) h December 31, 1989, in . period, September 6, 1989 (inception, throug conformity with generally accepted accounting principles. Our: audit was made for the purpose of forming an' opinion on g/c the basic financial statements taken as a whole.- The supplementary data disclosed in Schedules I and II are presented for purposeslof i additional analysisLand'are not a required part of-the basic financial l). 1 This information has been subjected to the auditing L statements. procedures applied in our audit of the basic financial statements and, 'in our opinion, is fairly stated in all material respects in relation s to the basic financial statements taken as a whols. & W w. ARTHUR ANDERSEN & CO. Chicago, Illinois, March-30,.1990. i l f. [ a $$\\

c -i '^ , L +; i COMMONWEALTH EDISON' COMPANY NON. TAX QUALIFIED DECOMMISSIONING TRUST FUND STATEMENT OF NET ASSETS AS OF DECEMBER 31, 1989 (In thousands) ASSETS: Receivables-Interest-6 ' Dividends 39 e Contribution from Commonwealth-Edison Company 10,097 $10,142 Investments, at market value. Short-term' investments (aggregate cost $2,292) $.2,298 Convertible-corporate bonds (aggregate 97 cost'$100) Convertible preferred stock (aggregate C cost $377)- 401 Common stock (aggregate cost $6,541) 6,407 $ 9,203 Total assets $19,345 LIABILITIES: Accrued fees payable to the-Trustee-and 23 investment manager Charge in' lieu of tax. payable to Commonwealth Edison Company. 1-Current Deferred 11 ' Total ~ liabilities 35 Net assets $19,310

==23E33 The accompanying notes to financial statements are an integral nart of this statement. .w

UQ 4 i 4 COMMONWEALTH EDISON COMPANY NON-TAX QUALIFIED DECOMMISSIONING TRUST FUND 1 STATEMENT OF-CHANGES IN NET ~ ASSETS FOR THE PERIOD SEPTEMBER 6,-1989 (INCEPTION) THROUGH DECEMBER 31, 1989. (In thousands) 1 NET ASSETS: BeginninF of period ADDITIONS:. Commonwealth Edison Company contributions $19,318 Investment, income-180~ Net realized loss-on sale of investments (46) Net unrealized loss.on investments (107) . Total additions $19.345 DEDUCTIONS:- Charge inElieu of income taxes 12 Trustee and~1nvestment manager expense 6 23 Total deductions 4 35 Net additions $19,310 NET ASSETS: End of period $19,310 23==333 The' accompanying. notes to financial statements are an intvgral part of this statement.

8 5 COMMONWEALTH-EDISON COMPANY'NON_ TAX QUALIFIED DECOMMISSIONING-TRUST FUND NOTES TO FINANCIAL STATEMENTS DECEMBER 31, 1989 1 (1) DESCRIPTION OF THE TRUST: Illinois law requires public utility operators of nuclear power plants, such as Commonwealth Edison Company (the " Company"), to establish external trusts to hold funds to cover the costs of the eventual decommissioning of nuclear power plants. In 1988, the Illinois Commerce Commission l(the "ICC")-issued an order approving, among other things, the Company's proposed method of funding its obli. i gations with respect to decommissioning costs. In accordance with the ICC order, the Company contributed in 1989 approximately $152,996,000 i to a Tax Qualified Trust Fund, representing the maximum tax deduction allowed by rulings of the Internal Revenue Service with respect to certain past collections, and $9,221,000 to a Non-Tax Qualified Trust Fund'(the " Trust"), primarily representing the first annual payment of the remaining past collections being made ratably over the remaining book lives-of the plants to which the payments relate. With respect to subsequent decommissioning fund collections, the ICC order requires the Company to contribute such amounts to'the trusts annually. -The ICC allows decommissioning costs of $66 million to be recovered annually in rates. Decommissioning costs are esti-mated to aggregate $2.4 billion, in current-year dollars, for all of the Company's nuclear units. Below is an analysis of contributions made and to be made to the Tax Qualified and Non-Tax Qualified Trust Funds (in thousands): L Tax Non-Tax Qualified Qualified Total _ Contributions in 1989 for years t prior to 1989 $152,996 $ 9,221 $162,217 Contributions in 1990 for 1989-Amounts recovered in 1989 $ 63,832 4 2,168 $ 66,000 1989 amortization of amounts collected prior to September 12, 1988 7,929 7,929 l Contributions receivable at December 31, 1989 $ 63,832 $10,097 $ 73,929 Contributions for the period ended December 31, 1989 $216,828 $19,318 $236,146

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.c- .f i t Custody of the funds isLmaintained by'The Northern Trust b . Company-(the " Trustee") under a Trust Agreement dated December 8,- 1988. The Trustee. utilizes _an investment management company to invest and manage the Trust funds collected.. Investment of funds in the Trust may be made in highly: rated debt or demand deposits of other entities or banks, respectively. Equity securitiesfalso may be purchased, subject to-limitations, and no securities may be purchased from an operator of a nuclear power plant, per the Trust: Agreement. i The Trust, which is irrevocable, is scheduled to terminate .upon completion of the decommissioning of the nuclear generating 3 stations. Any unpaid amounts in the Trust are to be returned to the Company. (2)

SUMMARY

OF:SIGNIFICANT ACCOUNTING POLICIES: la) Valuation of Investments-t Investments are-stated at fair market value as determined.by the Trustise, by reference to published market data. The difference between aggregate market value and the aggregate cost of the invest-ments at December 31, 1989, is reflected as net unrealized loss on-investments in the statement of changes iu nat assets. L (b) Investment Income-Investment interest and dividend income earned during the year but nc'. received as of December 31 is accrued for in the accom-panying financial statements. Icji Investment Transactions- . Investment transactions are accounted for on a settlement- .- date basis. .The cost of investments sold is-determined on a-specific L identification' basis. L (d) Trust Expenses-Expenses of administration and management of the Trust are based upon the market value of the investments held by the Trust and are paid from~the Trust fund. During 1989, Trustee and investm3nt J manager ~ fees totaling $23,000 for the Trust were incurred. Trust expenses incurred during the year but not paid as of December 31 have been accrued fpr in the accompanying financial L L statements. (e) Income Taxes-L Taxes due on the net earnings of the Trust are included in the Company's corporate tax return and paid from Company funds. The incremental taxes paid by the Company are reimbursable from the i =

e 3 l -p Trust. -Therefore, a "charme in lieu of income taxse" nas been reflected in the accompanyinp. statement of changes in net ansets, based on~ the pretax income of the Trust, after considering the tax attributes of the Company. The Trust income is ezempt from Illinois state income. tax. (f) Allocation of Trust Furgds to Operating Units. Contributions to the Trust are allocated to each nuclear generating unit based on approved'ICC rate rulings. The income and expenses of the Trust are.211ocated to each nuclear generating unit ' based on the initial contributions alle,cated to the units. Schedule II discionen financial data ry nuclear generating unit for the period ended December 31, 1989. (3) INCOME TAXES: The charge in lieu of i.;?ome taxes includes the current tax liabilityLfrom operations and deferred is.come taxes provided on certain items of income and expense which are reported in different periods for tax and financial reporting purposes. The current and deferred components of the charge in lieu of income taxes for the period er.ded December 31, 1989, are as follows (in thousands): Current $1 Deferred 11 Total charge in 119u of income taxes $12 The following table renonciles the differences between the recorded charge in lieu of income taxes and amounts determined on income before such chcrga by applying the Federal statutory tax rate of 241 to pretax accounting ine:ome of $4,000 (in ti;ousands): Expected Federal income taxes at statutory rate $1 Unrealized loss on investments-- no-tax benefit realized 37 Dividends received deduction (26) Total charge in lieu of income taxes $12 333 a.m

SCNESOLE I COMMO# WEALTH EDIS0W COMPANY NON-TAI QUALIFIED DECOMMISSIONING TRUST Ft;WD SCHEDULE OF INVESTMENTS DECEM9ER 31, 1989 Shares or Deser1pt 1on Far volve Cost Market valve COMMON S7OCK: ADT Ltd., American Depositary receipt. 8,680 $ 28C,427.24 $ 177,760.00 Aluminge Co. of America, common stock, $1 par 4,000 298,390.00 300,000.00 American Nealth PPTYS Inc., common stock ?2,300 276,113 00 279,825.00 BCE Inc., common stock 4,800 174,898.00 188.400.00 Burlington Northern Inc., common stock, no par 6,200 173,197.00 195,300.00 Citicorp, common stock, $4 par 6,500 200,932.89 187,688.00 Consolidated Freightways Inc., common stock, 8.625 par 4,100 134,574.00 108 650.00 Continental Corp., cosason stock, $1 par 7,500 278,869.30 232,500.00 fanon Corp., common stock, no par 4,700 207,082.00 235,000.00 First Bank System, Inc., capital stock, $2.50 par 19,6Tr 468,426.00 328,300.00 GTE Corp., common stock, $3.33-1/3 par 4,57J 273,082.50 315,000.00 Mong Kong Telecoe:monications Ltd. sponsored American Depositary receipt 6,000 108,000.00 120,000.00 International Business Machines Corp., capital stock, $1.25 par 2,300 269,238.00 216,488.00 Lubrizol Corp., common stock, no par 4,700 177,641.20 176,250.00 Meditrust, shares or beneficial interest 13,500 275,872.50 271,688.00 Montana Fower Co., common stock, no par 7,000 282,170.00 295,750.00 J. P. Morgan & Co., Inc., common stock, $2.50 par 2,700 107.824.50 118,800.00 JIIPSCO Industries Inc., common stock 15,400 281,974.00 298,375.00 Northrop Corp., common stock, no par 11,600 237,287.29 203,000.00 Pactric Enterprises, common stock 5,700 277,253 13 287,850.00 Philip Morris Companies Inc., common stock, $1 par 6,400 266,496.00 266,400.00 Repsol SA, sponsored American Depositary receipt 13,800 283,728.00 317,400.00 Royal Dutch Pete Co. N.Y. registry SM par n 5 gler 1.400 95,459.00 108,500.00 Sears, Roebuck and Co., common stock, 8.75 par 3,100 140,461.00 118,188.0e Tenaco. Inc., common stock, $6.25 par 4,000 202,240.00 235,500.00 TNT Ltd., American Depositary receipt 24,000' 313,920.00 265,440.00 Westpac Skg. Ltd., sponsored American Depositary receipt 13,800 281,378.00 298,425.00 Weyerhaeuser Co., common stock, $e.875 par 5,800 174,2e9.40 160.225.00 Total common stock 224.080 $6,541,173 95 $6,406,702.00 ,=. =,

-_m Semenes s 3 _2-Coettooed. Shares or Descr 1pt ion Far Value Cost Market Value CCNVERTIBLE PREFERRED STOCK: Baxter International Inc., $3 50 cumulative convertible exchangeable Series B, preferred stock 3,900 $ 271,284.00 $ 292,500.00 i Newscorp Cayman Island, $3 50 erch preferred 1,800 105,750.00 108,000.00' stock Total convertible preferred stock 5,700' $ 377,034.00 $ 400,500.00 r====== CONYERTIBLE CORPORATE BOND: Comcast Corp. subordinated convertible 7.005 debenture, due November 1, 2014 100,000.00 $ 100,000.00 $ 97,500.00 SHORT-TERM INVESTMENTS: Discover Credit Corp., 8.535 IBN, due January 25, 1990 300,000.00 300,000.00 300,205 00 l General Electric Capital Corp., 8.505 IBN, due January 25, 1990 300,000.00 300,000.00 300,204.00 General Electric Capital Corp., 8.405 IBM, due January 19, 1990 500,0GO.00 500,000.00 501.032.00 Heller Financial Corp., 8.655 IBM, due 400,*00.00 400,000.00 401,478.00 January 12, 1990 U. S. Treasury bill, due January 4, 1990 500,000.00 496,446.53 499,930,00 Benchmark Government Fd Invested Cash 295,292.L5 295.292.45 295,292.00 $2,295,292.45 $2.291.738.98 $2,298,141.00 Total short-term investments

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$9,309,946.93 $9,202,84 3 00 Total assets

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