ML21193A327

Declaration of David J. Effron

ML21193A327
Person / Time
Site:	Calvert Cliffs, Dresden, Peach Bottom, Salem, Nine Mile Point, Byron, Three Mile Island, Braidwood, Limerick, Ginna, Clinton, Quad Cities, Zion, FitzPatrick, LaSalle, 07201036, 07200077
Issue date:	07/12/2021
From:	Effron D State of IL
To:	NRC/SECY
SECY RAS
References
RAS 56173, Exelon Generation Company, LLC
Download: ML21193A327 (4)

Text

CONTAINS PROTECTED INFORMATION - SUBJECT TO PROTECTIVE ORDER UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE SECRETARY

)

In the Matter of: )

) NRC-2021-0099 EXELON GENERATION COMPANY, )

LLC; EXELON CORPORATION; ) Docket Nos.: STN 50-456, STN 50-457, 72-EXELON FITZPATRICK, LLC; NINE ) 73, STN 50-454, STN 50-455, 72-68, 50-317, MILE POINT NUCLEAR STATION, ) 50-318, 72-8, 50-461, 72-1046, 50-10, 50-237, LLC; R. E. GINNA NUCLEAR POWER ) 50-249, 72-37, 50-333, 72-12, 50-373, 50-374, PLANT, LLC; and CALVERT CLIFFS ) 72-70, 50-352, 50-353, 72-65, 50-220, 50-410, NUCLEAR POWER PLANT, LLC ) 72-1036, 50-171, 50-277, 50-278, 72-29, 50-

) 254, 50-265, 72-53, 50-244, 72-67, 50-272, (Braidwood Station, Units 1 and 2; Byron ) 50-311, 72-48, 50-289, 72-77, 50-295, 50-304, Station, Unit Nos. 1 and 2; Calvert Cliffs ) and 72-1037 -LT Nuclear Power Plant, Units 1 and 2; )

Clinton Power Station, Unit No. 1; ) July 12, 2021 Dresden Nuclear Power Station, Units 1, )

2, and 3; James A. FitzPatrick Nuclear )

Power Plant; LaSalle County Station, )

Units 1 and 2; Limerick Generating )

Station, Units 1 and 2; Nine Mile Point )

Nuclear Station, Units 1 and 2; Peach )

Bottom Atomic Power Station, Units 1, 2, )

and 3; Quad Cities Nuclear Power Station, )

Units 1 and 2; R. E. Ginna Nuclear Power )

Plant; Salem Nuclear Generating Station, )

Unit Nos. 1 and 2; Three Mile Island )

Nuclear Station, Unit 1; Zion Nuclear )

Power Station, Units 1 and 2; and )

Associated Independent Spent Fuel )

Storage Installations) )

DECLARATION OF DAVID J. EFFRON IN SUPPORT OF PEOPLE OF THE STATE OF ILLINOISS REQUEST FOR LEAVE TO INTERVENE AND FOR A HEARING REGARDING EXELON GENERATION COMPANY, LLCs FACILITY OPERATING LICENSE TRANSFER APPLICATION 1

CONTAINS PROTECTED INFORMATION - SUBJECT TO PROTECTIVE ORDER I, David J. Effron, pursuant to the provisions of 28 U.S.C. §1746 declare as follows:

1. My name is David J. Effron. My business address is 12 Pond Path, North Hampton, New Hampshire, 03862.

2. I am a consultant specializing in utility regulation. My professional career includes over thirty years as a regulatory consultant, two years as a supervisor of capital investment analysis and controls at Gulf & Western Industries and two years at Touche Ross & Co.

as a consultant and staff auditor. I am a Certified Public Accountant and I have served as an instructor in the business program at Western Connecticut State College.

3. I have analyzed numerous electric, gas, telephone, and water filings in different jurisdictions. Pursuant to those analyses I have prepared testimony, assisted attorneys in case preparation, and provided assistance during settlement negotiations with various utility companies. I have testified in over two hundred cases before regulatory commissions in Alabama, Colorado, Connecticut, Florida, Georgia, Illinois, Indiana, Kansas, Kentucky, Maryland, Massachusetts, Missouri, Nevada, New Jersey, New York, North Dakota, Ohio, Pennsylvania, Rhode Island, South Carolina, Texas, Vermont, Virginia, and Washington.

4. I have a Bachelor's degree in Economics (with distinction) from Dartmouth College and a Masters of Business Administration Degree from Columbia University, and received the Gold Charles Waldo Haskins Memorial Award for the highest scores in the May 1974 certified public accounting examination in New York State.

5. I reviewed the confidential financial statements prepared by the Applicants in this license transfer proceeding and identified as Enclosures 6A, 8A, and 10A pursuant to the Second 2

CONTAINS PROTECTED INFORMATION - SUBJECT TO PROTECTIVE ORDER Amended Protective Order Governing the Disclosure of Sensitive Unclassified Non-Safeguards Information issued by the ALJ on June 29, 2021.

6. I analyzed the effect of a 10% reduction in market prices for energy and capacity for Exelons nuclear generating units as compared to a 10% for all of Exelon Generations revenues. My analysis is attached as Confidential Exhibit 1A.

I have read this document and know the contents. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information, and belief and the statements made in it are not interposed for delay.

Respectfully submitted, Executed in Accord with 10 C.F.R. §2.304(d)

David J. Effron 12 Pond Path, North Hampton New Hampshire, 03862 Phone: (603) 964-6526 Email: djeffron@aol.com Executed this 12th day of July, 2021 3

CONTAINS PROTECTED INFORMATION - SUBJECT TO PROTECTIVE ORDER CONTAINS PROTECTED INFORMATION - SUBJECT TO PROTECTIVE ORDER Exhibit 1 to the Declaration of David J. Effron EXELON GENERATION TOTAL OPERATIONS - 10% REDUCTION TO TOTAL REVENUES

($ MILLION) 2022 2023 2024 2025 2026 Operating Revenues Price Reduction 10%

Income/Cash Flow Effect Net Income ExGen Total Income 10% Price Reduction - Nuclear Only Cash Flow from Operations Capital Expenditures Cash Flow from Ops. Net of CapX Effect of Price Reduction Net Cash Flow 10% Price Reduction - Nuclear Only 1515 1735 1828 1755 1861 Assumptions:

28% combined income tax rate Expenses other than income taxes unchaged Capital spending not for capacity expasion 4