RS-10-051, Submittal of Decommissioning Funding Assurance Calculations

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Submittal of Decommissioning Funding Assurance Calculations
ML100700098
Person / Time
Site: Byron, Braidwood  Constellation icon.png
Issue date: 03/10/2010
From: Simpson P
Exelon Corp, Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-10-051
Download: ML100700098 (26)
v • d • e


Text

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Exelon Nuclear 4300 Winfield Road Nuclear Warrenville, lL 60555 10 CFR 50.75(f)(I)

RS-10-051 March 10,2010 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

Submittal of Decommissioning Funding Assurance Calculations

Reference:

1. Letter from Keith R. Jury (Exelon Generation Company) to U.S. NRC, "Decommissioning Funding Assurance Plan," dated July 29, 2009
2. Letter from Patrick R. Simpson (Exelon Generation Company) to U.S.

NRC, "Submittal of Byron Station Site-Specific SAFSTOR Decommissioning Cost Estimate," dated November 16, 2009

3. Letter from Patrick R. Simpson (Exelon Generation Company) to U.S.

NRC, "Submittal of Braidwood Station Site-Specific SAFSTOR Decommissioning Cost Estimate," dated January 11, 2010 In the Reference 1 letter, Exelon Generation Company, LLC (EGC) committed to establish a financial guarantee, as allowed by NRC regulations, for any difference in funding assurance for Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, based on site-specific SAFSTOR Decommissioning Cost Estimates (DCEs) and decommissioning trust fund values as of December 31,2009.

Attachment 1 shows the radiological decommissioning (license termination) cash flow for Braidwood Station Units 1 and 2, based on the DCE submitted in Reference 3.

March 10,2010 U.S. Nuclear Regulatory Commission Page 2 Attachment 2 shows the radiological decommissioning (license termination) cash flow for Byron Station Units 1 and 2, based on the DCE submitted in Reference 2.

These cash flows are escalated to December 31, 2009, by using the latest site-specific escalation factors, which are re-calculated on an annual basis.

For Braidwood Station Units 1 and 2, and Byron Station Units, 1 and 2, the decommissioning funding assurance is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(l)(i). There are no additional amounts to be collected from ratepayers, nor are there any contracts relied upon pursuant to 10 CFR 50.75(e)(l)(v). presents the calculation of radiological decommissioning funding assurance for Braidwood Station. Attachment 4 presents the calculation of radiological decommissioning funding assurance for Byron Station. The Tables in Attachments 3 and 4 compare the funding assurance, calculated using the NRC generic formula, as recently published by the NRC, to the funding assurance calculated using the site-specific DCE methodology, as allowed by 10 CFR 50.75(e)(l)(i).

Based on the site-specific methodology, and December 31,2009, trust fund values, Byron Station, Unit 1 meets all NRC radiological decommissioning funding assurance requirements. For Braidwood Station, Units 1 and 2, and Byron Station, Unit 2, additional funding assurance is required. Based on the calculations in Attachments 3 and 4, the amount of additional funding assurance required is:

Additional Parent Funding Guarantee Unit Assurance Amount Required Established Braidwood, Unit 1 $10.2M $14.2M Braidwood, Unit 2 $7.3M $10.5M Byron, Unit 2 $13.9M $19.5M Total $31.4M $44.2M Parent guarantees have been established to cover the difference in funding assurance above in a total amount of $44.2 million. The amount of the parent guarantees was established based on recent NRC interaction's that indicated that the amount of the guarantees should cover the potential difference at the time of shutdown, and not allow for growth during the remaining operating period. EGC maintains that this growth should be allowed as long as the amount of the guarantees are updated annually, as EGC has previously committed to do in Reference 1. Since there is currently a lack of definitive guidance on this subject, EGC has established the amount of the parent guarantees to conservatively cover the amount of the difference at shutdown. The amount of the parent guarantees may be adjusted pending further resolution of this issue. Copies of the parent guarantees are included as Attachment 5.

There are no new regulatory commitments contained in this letter.

March 10,2010 U.S. Nuclear Regulatory Commission Page 3 If you have any questions about this letter, please contact Patrick Simpson at (630) 657-2823.

Patrick R. Simpson ()

Manager - Licensing Exelon Generation Company, LLC Attachments: 1. Braidwood Station, Units 1 and 2 Radiological Decommissioning Projected SAFSTOR Cash Flow

2. Byron Station, Units 1 and 2 Radiological Decommissioning Projected SAFSTOR Cash Flow
3. Braidwood Station, Units 1 and 2 NRC Funding Assurance Calculations
4. Byron Station, Units 1 and 2 NRC Funding Assurance Calculations
5. Braidwood Station, Units 1 and 2 and Byron Station, Unit 2 Parent Guarantees

ATTACHMENT 1 Braidwood Station, Units 1 and 2 Radiological Decommissioning Projected SAFSTOR Cash Flow (dollars, thousands)

Braidwood Unit 1 Braidwood Unit 1 Radiological Decommissioning Cost Radiological Decommissioning Cost less Year (December 31, 2009 dollars) Decommissioning Period Credit 2026 $9,819 $9,723 2027 $53,297 $51,737 2028 $12,862 $12,240 2029 $3,739 $3,489 2030 $3,739 $3,420 2031 $3,739 $3,353 2032 $3,746 $3,294 2033 $3,734 $3,219 2034 $3,734 $3,156 2035 $3,734 $3,094 2036 $3,745 $3,042 2037 $3,734 $2,974 2038 $3,734 $2,916 2039 $3,734 $2,858 2040 $3,745 $2,810 2041 $3,734 $2,747 2042 $3,734 $2,694 2043 $3,734 $2,641 2044 $3,745 $2,596 2045 $3,734 $2,538 2046 $3,710 $2,472 2047 $3,710 $2,424 2048 $3,720 $2,383 2049 $3,710 $2,330 2050 $3,710 $2,284 2051 $3,710 $2,239 2052 $3,720 $2,201 2053 $3,710 $2,152 2054 $3,710 $2,110 2055 $3,710 $2,069 2056 $3,720 $2,034 2057 $3,710 $1,988 2058 $3,710 $1,949 2059 $3,710 $1,911 2060 $3,720 $1,879 2061 $3,710 $1,837 2062 $3,710 $1,801 2063 $3,710 $1,765 2064 $3,720 $1,736

ATTACHMENT 1 Braidwood Station Units 1 and 2 Radiological Decommissioning Projected SAFSTOR Cash Flow (continued)

(dollars, thousands)

Braidwood Unit 1 Braidwood Unit 1 Radiological Decommissioning Cost Radiological Decommissioning Cost less Year (December 31, 2009 dollars) Decommissioning Period Credit 2065 $3,710 $1,697 2066 $3,710 $1,664 2067 $3,710 $1,631 2068 $3,720 $1,603 2069 $3,710 $1,568 2070 $3,710 $1,537 2071 $3,710 $1,507 2072 $3,720 $1,481 2073 $3,710 $1,448 2074 $3,710 $1,420 2075 $3,710 $1,392 2076 $3,720 $1,369 2077 $3,710 $1,338 2078 $3,710 $1,312 2079 $14,085 $4,883 2080 $52,128 $17,716 2081 $101,665 $33,873 2082 $81,365 $26,578 2083 $43,658 $13,982 2084 $34,244 $10,752 2085 $2,233 $687 2086 $22,580 $6,814 2087 $88 $26 2088 $88 $25 2089 $24 $7 Total $614,187 $300,412 Total Decommissioning Period Credit: $313,775

ATTACHMENT 1 Braidwood Station, Units 1 and 2 Radiological Decommissioning Projected SAFSTOR Cash Flow (continued)

(dollars, thousands)

Braidwood Unit 2 Braidwood Unit 2 Radiological Decommissioning Cost Radiological Decommissioning Cost less Year (December 31, 2009 dollars) Decommissioning Period Credit 2027 $1,954 $1,935 2028 $52,885 $51,337 2029 $43,060 $40,980 2030 $3,753 $3,501 2031 $3,753 $3,433 2032 $3,763 $3,375 2033 $3,748 $3,295 2034 $3,744 $3,228 2035 $3,744 $3,164 2036 $3,755 $3,111 2037 $3,744 $3,041 2038 $3,744 $2,982 2039 $3,744 $2,923 2040 $3,755 $2,874 2041 $3,744 $2,810 2042 $3,744 $2,755 2043 $3,744 $2,701 2044 $3,755 $2,655 2045 $3,744 $2,596 2046 $3,732 $2,536 2047 $3,732 $2,487 2048 $3,742 $2,444 2049 $3,732 $2,390 2050 $3,732 $2,343 2051 $3,732 $2,297 2052 $3,742 $2,258 2053 $3,732 $2,208 2054 $3,732 $2,165 2055 $3,732 $2,122 2056 $3,742 $2,086 2057 $3,732 $2,040 2058 $3,732 $2,000 2059 $3,732 $1,961 2060 $3,742 $1,927 2061 $3,732 $1,884 2062 $3,732 $1,848 2063 $3,732 $1,811 2064 $3,742 $1,781 2065 $3,732 $1,741

ATTACHMENT 1 Braidwood Station Units 1 and 2 Radiological Decommissioning Projected SAFSTOR Cash Flow (continued)

(dollars, thousands)

Braidwood Unit 2 Braidwood Unit 2 Radiological Decommissioning Cost Radiological Decommissioning Cost less Year (December 31, 2009 dollars) Decommissioning Period Credit 2066 $3,732 $1,707 2067 $3,732 $1,673 2068 $3,742 $1,645 2069 $3,732 $1,608 2070 $3,732 $1,577 2071 $3,732 $1,546 2072 $3,742 $1,520 2073 $3,732 $1,486 2074 $3,732 $1,457 2075 $3,732 $1,428 2076 $3,742 $1,404 2077 $3,732 $1,373 2078 $3,732 $1,346 2079 $3,732 $1,319 2080 $16,812 $5,828 2081 $38,172 $12,973 2082 $101,206 $33,721 2083 $76,248 $24,907 2084 $63,106 $20,210 2085 $62,934 $19,759 2086 $27,559 $8,483 2087 $37 $11 2088 $38 $11 2089 $10 $3 Total $670,957 $332,020 Total Decommissioning Period Credit: $338,938

ATTACHMENT 2 Byron Station, Units 1 and 2 Radiological Decommissioning Projected SAFSTOR Cash Flow (dollars, thousands)

Byron Unit 1 Byron Unit 1 Radiological Decommissioning Cost Radiological Decommissioning Cost less Year (December 31, 2009 dollars) Decommissioning Period Credit 2024 $7,931 $7,853 2025 $52,346 $50,814 2026 $17,328 $16,491 2027 $2,783 $2,597 2028 $2,791 $2,553 2029 $2,783 $2,496 2030 $3,405 $2,994 2031 $3,709 $3,197 2032 $3,719 $3,143 2033 $3,709 $3,073 2034 $3,709 $3,013 2035 $3,709 $2,954 2036 $3,719 $2,904 2037 $3,709 $2,839 2038 $3,709 $2,783 2039 $3,709 $2,729 2040 $3,719 $2,683 2041 $3,709 $2,623 2042 $3,709 $2,571 2043 $3,685 $2,505 2044 $3,695 $2,462 2045 $3,685 $2,407 2046 $3,685 $2,360 2047 $3,685 $2,314 2048 $3,695 $2,275 2049 $3,685 $2,224 2050 $3,685 $2,180 2051 $3,685 $2,138 2052 $3,695 $2,102 2053 $3,685 $2,055 2054 $3,685 $2,014 2055 $3,685 $1,975 2056 $3,695 $1,941 2057 $3,685 $1,898 2058 $3,685 $1,861 2059 $3,685 $1,824 2060 $3,695 $1,794 2061 $3,685 $1,754 2062 $3,685 $1,719

ATTACHMENT 2 Byron Station Units 1 and 2 Radiological Decommissioning Projected SAFSTOR Cash Flow (continued)

(dollars, thousands)

Byron Unit 1 Byron Unit 1 Radiological Decommissioning Cost Radiological Decommissioning Cost less Year (December 31, 2009 dollars) Decommissioning Period Credit 2063 $3,685 $1,686 2064 $3,695 $1,657 2065 $3,685 $1,620 2066 $3,685 $1,588 2067 $3,685 $1,557 2068 $3,695 $1,531 2069 $3,685 $1,497 2070 $3,685 $1,467 2071 $3,685 $1,439 2072 $3,695 $1,414 2073 $3,685 $1,383 2074 $3,685 $1,356 2075 $3,685 $1,329 2076 $3,695 $1,307 2077 $11,024 $3,821 2078 $49,747 $16,906 2079 $96,526 $32,161 2080 $83,663 $27,329 2081 $42,390 $13,575 2082 $36,229 $11,375 2083 $2,231 $687 2084 $21,615 $6,523 2085 $88 $26 2086 $88 $25 2087 $27 $8 Total $602,915 $295,377 Total Decommissioning Period Credit: $307,538

ATTACHMENT 2 Byron Station, Units 1 and 2 Radiological Decommissioning Projected SAFSTOR Cash Flow (continued)

(dollars, thousands)

Byron Unit 2 Byron Unit 2 Radiological Decommissioning Cost Radiological Decommissioning Cost less Year (December 31, 2009 dollars) Decommissioning Period Credit 2026 $7,760 $7,683 2027 $57,436 $55,755 2028 $34,392 $32,731 2029 $3,674 $3,428 2030 $3,674 $3,360 2031 $3,674 $3,295 2032 $3,678 $3,233 2033 $3,664 $3,159 2034 $3,664 $3,097 2035 $3,664 $3,036 2036 $3,674 $2,985 2037 $3,664 $2,918 2038 $3,664 $2,861 2039 $3,664 $2,805 2040 $3,674 $2,757 2041 $3,664 $2,696 2042 $3,664 $2,643 2043 $3,652 $2,582 2044 $3,662 $2,539 2045 $3,652 $2,482 2046 $3,652 $2,433 2047 $3,652 $2,386 2048 $3,662 $2,345 2049 $3,652 $2,293 2050 $3,652 $2,248 2051 $3,652 $2,204 2052 $3,662 $2,167 2053 $3,652 $2,118 2054 $3,652 $2,077 2055 $3,652 $2,036 2056 $3,662 $2,002 2057 $3,652 $1,957 2058 $3,652 $1,919 2059 $3,652 $1,881 2060 $3,662 $1,849 2061 $3,652 $1,808 2062 $3,652 $1,773 2063 $3,652 $1,738 2064 $3,662 $1,708

ATTACHMENT 2 Byron Station Units 1 and 2 Radiological Decommissioning Projected SAFSTOR Cash Flow (continued)

(dollars, thousands)

Byron Unit 2 Byron Unit 2 Radiological Decommissioning Cost Radiological Decommissioning Cost less Year (December 31, 2009 dollars) Decommissioning Period Credit 2065 $3,652 $1,670 2066 $3,652 $1,638 2067 $3,652 $1,605 2068 $3,662 $1,578 2069 $3,652 $1,543 2070 $3,652 $1,513 2071 $3,652 $1,483 2072 $3,662 $1,458 2073 $3,652 $1,426 2074 $3,652 $1,398 2075 $3,652 $1,370 2076 $3,662 $1,347 2077 $3,652 $1,317 2078 $13,898 $4,914 2079 $36,224 $12,557 2080 $95,033 $32,297 2081 $79,008 $26,325 2082 $61,414 $20,061 2083 $61,414 $19,668 2084 $29,104 $9,138 2085 $37 $12 2086 $37 $11 2087 $12 $3 Total $655,035 $329,318 Total Decommissioning Period Credit: $325,716

ATTACHMENT 3 Braidwood Station, Units 1 and 2 NRC Funding Assurance Calculations December 31, 2009 (dollars, thousands)

Braidwood, Braidwood, Unit 1 Unit 1 Site-Specific NRC SAFSTOR Generic Decommissioning Formula Cost Estimate Required Minimum at December 31, 2009 (A) $421,500 $614,187 Trust Fund Amount at December 31, 2009 (B) $205,217 $205,217 Shutdown Date 10/17/2026 10/17/2026 Years to Shutdown (C) 16.803 16.803 Earnings Credit to shutdown (D) = (B) x ((1 + 2%) ^ (C) -1) $81,016 $81,016 Projected Trust Fund Amount at shutdown (E) = (B) + (D) $286,233 $286,233 Decommissioning Period Earnings Credit (F) $21,279 $313,775 Total Projected Trust Fund Amount (G) = (E) + (F) $307,512 $600,008 Difference (H) = (G) - (A) ($113,988) ($14,179)

Prepayment Difference - Surplus/(Shortfall)

(J) = (H) / (1 + 2%) ^ (C) ($81,724) ($10,166)

Braidwood, Braidwood, Unit 2 Unit 2 Site-Specific NRC SAFSTOR Generic Decommissioning Formula Cost Estimate Required Minimum at December 31, 2009 (A) $421,500 $670,957 Trust Fund Amount at December 31, 2009 (B) $225,297 $225,297 Shutdown Date 12/18/2027 12/18/2027 Years to Shutdown (C) 17.973 17.973 Earnings Credit to shutdown (D) = (B) x ((1 + 2%) ^ (C) -1) $96,308 $96,308 Projected Trust Fund Amount at shutdown (E) = (B) + (D) $321,605 $321,605 Decommissioning Period Earnings Credit (F) $23,909 $338,938 Total Projected Trust Fund Amount (G) = (E) + (F) $345,514 $660,543 Difference (H) = (G) - (A) ($75,986) ($10,415)

Prepayment Difference - Surplus/(Shortfall)

(J) = (H) / (1 + 2%) ^ (C) ($53,231) ($7,296)

ATTACHMENT 4 Byron Station, Units 1 and 2 NRC Funding Assurance Calculations December 31, 2009 (dollars, thousands)

Byron, Byron, Unit 1 Unit 1 Site-Specific NRC SAFSTOR Generic Decommissioning Formula Cost Estimate Required Minimum at December 31, 2009 (A) $421,500 $602,915 Trust Fund Amount at December 31, 2009 (B) $228,667 $228,667 Shutdown Date 10/31/2024 10/31/2024 Years to Shutdown (C) 14.841 14.841 Earnings Credit to shutdown (D) = (B) x ((1 + 2%) ^ (C) -1) $78,122 $78,122 Projected Trust Fund Amount at shutdown (E) = (B) + (D) $306,789 $306,789 Decommissioning Period Earnings Credit (F) $22,808 $307,538 Total Projected Trust Fund Amount (G) = (E) + (F) $329,596 $614,327 Difference (H) = (G) - (A) ($91,904) $11,411 Prepayment Difference - Surplus/(Shortfall)

(J) = (H) / (1 + 2%) ^ (C) ($68,501) $8,506 Byron, Byron, Unit 2 Unit 2 Site-Specific NRC SAFSTOR Generic Decommissioning Formula Cost Estimate Required Minimum at December 31, 2009 (A) $421,500 $655,035 Trust Fund Amount at December 31, 2009 (B) $221,945 $221,945 Shutdown Date 11/06/2026 11/06/2026 Years to Shutdown (C) 16.858 16.858 Earnings Credit to shutdown (D) = (B) x ((1 + 2%) ^ (C) -1) $87,956 $87,956 Projected Trust Fund Amount at shutdown (E) = (B) + (D) $309,901 $309,901 Decommissioning Period Earnings Credit (F) $23,039 $325,716 Total Projected Trust Fund Amount (G) = (E) + (F) $332,940 $635,618 Difference (H) = (G) - (A) ($88,560) ($19,417)

Prepayment Difference - Surplus/(Shortfall)

(J) = (H) / (1 + 2%) ^ (C) ($63,425) ($13,906)

ATTACHMENT 5 Braidwood Station, Units 1 and 2 and Byron Station, Unit 2 Parent Guarantees

PARENT GUARANTlEE NRC DECOMMISSIONING FUNDING ASSURANCE Guarantee made February 22, 2010 by Exelon Corporation, a corporation organized under the laws of the Commonwealth of Pennsylvania, herein referred to as "guarantor," to the U.S.

Nuclear Regulatory Commission (NRC), on behalf of our subsidiary Exelon Generation Company, LLC (ExGen) of 300 Exelon Way, Kennett Square, PA 19348, obligor.

Recitals

1. The guarantor has full authority and capacity to enter into this guarantee pursuant to its bylaws, articles of incorporation, and the laws of Pennsylvania, its State of incorporation.

Guarantor has approval from its Board of Directors to enter into this guarantee.

2. This guarantee is being issued so that ExGen will be in compliance with regulations issued by the NRC, an agency of the U.S. Government, pursuant to the Atomic Energy Act of 1954, as amended and the Energy Reorganization Act of 1974. The NRC has promulgated regulations in Title 10, Chapter I of the Code of Federal Regulations, Part 50, which require that a holder of, or an applicant for, a license issued pursuant to 10 CFR Part 50 provide assurance that funds will be available when needed for required decommissioning activities.
3. This guarantee is issued to provide financial assurance for a portion of the costs of decommissioning activities for Braidwood Station. Unit 1 as required by 10 CFR Part 50.

The decommissioning costs for which this guarantee is issued are: $14,200,000.

4. The guarantor meets or exceeds the financial test criteria as stated in NRC 10 CFR 30 Appendix A Section 11, and will comply with the notification requirements as specified in 10 CFR Pat 50 and Appendix A to Part 30.
5. The guarantor is the sole member of Exelon Ventures Company, LLC, which is the sole member of Exelon Generation Company, LLC, the holder of NRC License No. NPF-72 for Braidwood Station, Unit 1,35100 South Route 53, Braceville, IL 60407-9619.
6. Decommissioning activities as used below refers to the activities required by 10 CFR Part 50 for decommissioning of the facility(ies) identified above.
7. For value received, and pursuant to the authority delegated to the officers of guarantor by its Board of Directors, the guarantor guarantees to the NRC that if ExGen fails to perform the required decommissioning activities, as required by License No. NPF-72, due to lack of funds, the guarantor shall either, as the guarantor shall determine:
a. carry out the required activities, 3
b. provide all funds necessary, up to the amount of this guarantee specified in Section 3, to carry out the required activities,
c. set up a trust fund in favor of ExGen in the amount of these current cost estimates or guarantee amount for these activities.
8. The guarantor shall assure that its independent accountant submit revised financial statements, financial test data, and will perform the review specified in NRC 10 CFR 30 Appendix A Section II, B and C,and notify the NRC as required by these sections.
9. The guarantor and ExGen agree that if the guarantor fails to meet the financial test criteria as stated in NRC 10 CFR 30 Appendix A Section II at any time after this guarantee is established, the guarantor and licensee shall send, within 90 days after the end of the fiscal year in which the guarantor fails to meet the financial test criteria, by certified mail, notice to the NRC. If ExGen fails to provide alternative financial assurance as specified in 10 CFR Part 50, as applicable, and obtain written approval of such assurance from the NRC within 180 days after the end of such fiscal year, the guarantor shall provide such alternative

financial assurance in the name of ExGen or make full payment under this guarantee to a standby trust established by ExGen.

10. Independent of any notification under paragraph 9 above, if the NRC determines for any reason that the guarantor no longer meets the financial test criteria or that it is disallowed from continuing as guarantor for the facility under License No. NPF-72, the guarantor agrees that within 90 days after being notified by the NRC of such determination, an alternative financial assttrance mechanism as specified in 10 CFR Part 50 as applicable, shall be established by the guarantor in the name of ExGen unless ExGen has done so.
11. The guarantor as well as its successors and assigns agree to remain bound jointly and severally under this guarantee notwithstanding any or all of the following: amendment or modification of license or NRC-approved decommissioning funding plan for that facility, the extension or reduction of the time of performance of required activities, or any other modification or alteration of an obligation of the licensee pursuant to 10 CFR Part 50.
12. The guarantor agrees that it will be liable for all litigation costs incurred by ExGen or the NRC in any successful effort to enforce this guarantee against the guarantor.
13. The guarantor agrees to remain bound under this guarantee for as long as ExGen must comply with the applicable financial assurance requirements of 10 CFR Part 50, for the previously listed facility(ies) except that the guarantor may cancel this guarantee by sending certified mail to the NRC and to ExGen, such cancellation to become effective no earlier than 120 days after receipt of such notice by both the NRC and ExGen as evidenced by the return receipts. If the licensee fails to provide alternative financial assurance as specified in 10 CFR Part 50, as applicable, and obtain written approval of such assurance within 120 days after the sending of the above notice by the guarantor, the guarantor shall provide such alternative financial assurance.
14. The guarantor expressly waives notice of acceptance of this guarantee by the NRC or by ExGen. The guarantor also expressly waives notice of amendments or modification of the decommissioning requirements and of amendments or modifications of the license.
15. If the guarantor files annual financial reports with the U.S. Securities and Exchange Commission, then it shall prompdy submit them to the NRC during each year in which this guarantee is in effect.

I herby certify that this guarantee is true and correct to the best of my knowledge.

Effective date: Jk- =, Az, O/Q Exelon Corporation d Chief Financial Officer Signature of witness or notary: doAk Exelon Generation Company, LLC istopher M. Crane President and Chief Operating Signature of witness or notary:

PARENT GUARANTEE NRC DECOMMISSIONING FUNDING ASSURANCE Guarantee made Febmary 22, 2010 by Exelon Corporation, a corporation organized under the laws of the Commonwealth of Pennsylvania, herein referred to as "guarantor," to the U.S.

Nuclear Regulatory Commission (NRC), on behalf of our subsidiary Exelon Generation Company, LLC (ExGen) of 300 Exelon Way, Kennett Square, PA 19348, obligor.

Recitals

1. The guarantor has full authority and capacity to enter into this guarantee pursuant to its bylaws, articles of incorporation, and the laws of Pennsylvania, its State of incorporation.

Guarantor has approval from its Board of Directors to enter into this guarantee.

2. This guarantee is being issued so that ExGen will be in compliance with regulations issued by the NRC, an agency of the U.S. Government, pursuant to the Atomic Energy Act of 1954, as amended and the Energy Reorganization Act of 1974. The NRC has promulgated regulations in Title 10, Chapter I of the Code of Federal Regulations, Part 50, which require that a holder of, or an applicant for, a license issued pursuant to 10 CFR Part 50 provide assurance that funds will be available when needed for required decommissioning activities.
3. This guarantee is issued to provide financial assurance for a portion of the costs of decommissioning activities for Braidwood Station. Unit 2 as required by 10 CFR Part 50.

The decommissioning costs for which this guarantee is issued are: $10,500,000.

4. The guarantor meets or exceeds the financial test criteria as stated in NRC 10 CFR 30 Appendix A Section 11, and will comply with the notification requirements as specified in 10 CFR Part 50 and Appendix A to Part 30.
5. The guarantor is the sole member of Exelon Ventures Company, LLC, which is the sole member of Exelon Generation Company, LLC, the holder of NRC License No. NPF-77 for Braidwood Station, Unit 2,35100 South Route 53, Braceville, IL 60407-9619.
6. Decommissioning activities as used below refers to the activities required by 10 CFR Part 50 for decommissioning of the facility(ies) identified above.
7. For value received, and pursuant to the authority delegated to the officers of guarantor by its Board of Directors, the guarantor guarantees to the NRC that if ExGen fails to perform the required decommissioning activities, as required by License No. NRF-77, due to lack of funds, the guarantor shall either, as the guarantor shall determine:
a. cany out the required activities, or
b. provide all funds necessary, up to the amount of this guarantee specified in Section 3, to carry out the required activities, 3
c. set up a trust fund in favor of ExGen in the amount of these current cost estimates or guarantee amount for these activities.
8. The guarantor shall assure that its independent accountant submit revised financial statements, financial test data, and will perform the review specified in NRC 10 CFR 30 Appendix A Section 11, B and C, and notify the NRC as required by these sections.
9. The guarantor and ExGen agree that if the guarantor fails to meet the fiiancial test criteria as stated in NRC 10 CFR 30 Appendix A Section I1 at any time after this guarantee is established, the guarantor and licensee shall send, within 90 days after the end of the fiscal year in which the guarantor fails to meet the financial test criteria, by certified mail, notice to the NRC. If ExGen fails to provide alternative financial assurance as specified in 10 CFR Part 50,as applicable, and obtain written approval of such assurance from the NRC within 180 days after the end of such fiscal year, the guarantor shall provide such alternative

financial assurance in the name of ExGen or make full payment under this guarantee to a standby trust established by ExGen.

10. Independent of any notification under paragraph 9 above, if the NRC determines for any reason that the guarantor no longer meets the financial test criteria or that it is disallowed from continuing as guarantor for the facility under License No. NPF-77, the guarantor agrees that within 90 days after being notified by the NRC of such determination, an alternative financial assurance mechanism as specified in 10 CFR Part 50 as applicable, shall be established by the guarantor in the name of ExGen unless ExGen has done so.
11. The guarantor as well as its successors and assigns agree to remain bound jointly and severally under this guarantee notwithstanding any or all of the following: amendment or modification of license or NRC-approved decommissioning funding plan for that facility, the extension or reduction of the time of performance of required activities, or any other modification or alteration of an obligation of the licensee pursuant to 10 CFR Part 50.
12. The guarantor agrees that it will be liable for all litigation costs incurred by ExGen or the NRC in any successful effort to enforce this guarantee against the guarantor.
13. The guarantor agrees to remain bound under this guarantee for as long as ExGen must comply with the applicable financial assurance requirements of 10 CFR Part 50, for the previously listed facility(ies) except that the guarantor may cancel this guarantee by sending certified mail to the NRC and to ExGen, such cancellation to become effective no earlier than I20 days after receipt of such notice by both the NRC and ExGen as evidenced by the return receipts. If the licensee fails to provide altemative financial assurance as specified in 10 CFR Part 50, as applicable, and obtain written approval of such assurance within 120 days after the sending of the above notice by the guarantor, the guarantor shall provide such altemative financial assurance.
14. The guarantor expressly waives notice of acceptance of this guarantee by the NRC or by ExGen. The guarantor also expressly waives notice of amendments or modification of the decommissioning requirements and of amendments or modifications of the license.
15. If the guarantor files annual financial reports with the U.S. Securities and Exchange Commission, then it shall promptly submit them to the NRC during each year in which this guarantee is in effect.

I herby certify that this guarantee is true and correct to the best of my knowledge.

Effective date: f i e t&

Exelon Corporation t and Chief F i n a n 9 Officer Signature of witness or notary:

Exelon Generation Company, LLC Signature of witness or

PARENT GUARANTEE NRC DECOMMISSIONING FUNDING ASSURANCE Guarantee made February 22, 2010 by Exelon Corporation, a corporation organized under the laws of the Commonwealth of Pennsylvania, herein referred to as "guarantor," to the U.S.

Nuclear Regulatory Commission (NRC), on behalf of our subsidiary Exelon Generation Company, LLC (ExGen) of 300 Exelon Way, Kennett Square, PA 19348, obligor.

Recitals

1. The guarantor has full authority and capacity to enter into this guarantee pursuant to its bylaws, articles of incorporation, and the laws of Pennsylvania, its State of incorporation.

Guarantor has approval from its Board of Directors to enter into this guarantee.

2. This guarantee is being issued so that ExGen will be in compliance with regulations issued by the NRC,an agency of the U.S. Govetnment, pursuant to the Atomic Energy Act of 1954, as amended and the Energy Reorganization Act of 1974. The NRC has promulgated regulations in Title 10, Chapter I of the Code of Federal Regulations, Part 50, which require that a holder of, or an applicant for, a license issued pursuant to 10 CFR Part 50 provide assurance that funds will be available when needed for required decommissioning activities.
3. This guarantee is issued to provide financial assurance for a portion of the costs of decommissioning activities for Byron Station, Unit 2 as required by 10 CFR Part 50. The decommissioning costs for which this guarantee is issued are: $19,500,000.
4. The guarantor meets or exceeds the financial test criteria as stated in NRC 10 CF'R 30 Appendix A Section 11, and will comply with the notification requirements as specified in 10 CFR Part 50 and Appendix A to Part 30.
5. The guarantor is the sole member of Exelon Ventures Company, LLC, which is the sole member of Exelon Generation Company, LLC, the holder of NRC License No. NPF-66 for Byron Station, Unit 2,4450 North German Church Road, Byron, IL 6 1010-9794.
6. Decommissioning activities as used below refers to the activities required by 10 CFR Part 50 for decommissioning of the facility(ies) identified above.
7. For value received, and pursuant to the authority delegated to the officers of guarantor by its Board of Directors, the guarantor guarantees to the NRC that if ExGen fails to perform the required decommissioning activities, as required by License No. NPP-66, due to lack of funds, the guarantor shall either, as the guarantor shall determine:
a. carry out the required activities, g
b. provide all funds necessary, up to the amount of this guarantee specified in Section 3, to carry out the required activities,
c. set up a trust fund in favor of ExGen in the amount of these current cost estimates or guarantee amount for these activities.
8. The guarantor shall assure that its independent accountant submit revised financial statements, financial test data, and will perform the review specified in NRC 10 CFR 30 Appendix A Section 11, B and C, and notify the NRC as required by these sections.
9. The guarantor and ExGen agree that if the guarantor fails to meet the financial test criteria as stated in NRC 10 CFR 30 Appendix A Section II at any time after this guarantee is established, the guarantor and licensee shall send, within 90 days after the end of the fiscal year in which the guarantor fails to meet the financial test criteria, by certified mail, notice to the NRC. If ExGen fails to provide alternative financial assurance as specified in 10 CFR Part 50, as applicable, and obtain written approval of such assurance from the NRC within 180 days after the end of such fiscal year, the guarantor shall provide such alternative

financial assurance in the name of ExGen or make full payment under this guarantee to a standby trust established by ExGen.

10. Independent of any notification under paragraph 9 above, if the NRC determines for any reason that the guarantor no longer meets the financial test criteria or that it is disallowed fiom continuing as guarantor for the facility under License No. NPF-66, the guarantor agrees that within 90 days after being notified by the NRC of such determination, an alternative financial assurance mechanism as specified in 10 CFR Part 50 as applicable, shall be established by the guarantor in the name of ExGen unless ExGen has done so.
11. The guarantor as well as its successors and assigns agree to remain bound jointly and severally under this guarantee notwithstanding any or all of the following: amendment or modification of license or NRC-approved decommissioning funding plan for that facility, the extension or reduction of the time of performance of required activities, or any other modification or alteration of an obligation of the licensee pursuant to 10 CFR Part 50.
12. The guarantor agrees that it will be liable for all litigation costs incurred by ExGen or the NRC in any successful effort to enforce this guarantee against the guarantor.
13. The guarantor agrees to remain bound under this guarantee for as long as ExGen must comply with the applicable financial assurance requirements of 10 CFR Part 50, for the previously listed facility(ies) except that the guarantor may cancel this guarantee by sending certified mail to the NRC and to ExGen, such cancellation to become effective no earlier than 120 days after receipt of such notice by both the NRC and ExGen as evidenced by the return receipts. If the licensee fails to provide alternative financial assurance as specified in 10 CFR Part 50, as applicable, and obtain written approval of such assurance within 120 days after the sending of the above notice by the guarantor, the guarantor shall provide such alternative financial assurance.
14. The guarantor expressly waives notice of acceptance of this guarantee by the NRC or by ExGen. The guarantor also expressly waives notice of amendments or modification of the decommissioning requirements and of amendments or modifications of the license.
15. If the guarantor files annual financial reports with the U.S. Securities and Exchange Commission, then it shall promptly submit them to the NRC during each year in which this guarantee is in effect.

I herby certify that this guarantee is true and correct to the best of my knowledge.

Effective date: A A 4 s 7 ",

Exelon Corporation Signature of witness or notary:

Exelon Generation Company, LLC M.Crane Signature of witness or notary: L

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