RS-15-245, Submittal of Supplement to Foreign Ownership Control or Influence Package
| ML15328A211 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Oyster Creek, Byron, Braidwood, Limerick, Ginna, Clinton, Quad Cities, LaSalle, Crane |
| Issue date: | 11/18/2015 |
| From: | Simpson P Exelon Generation Co |
| To: | Document Control Desk, Division of Security Operations |
| Shared Package | |
| ML15328A228 | List: |
| References | |
| RS-15-245 | |
| Download: ML15328A211 (8) | |
Text
Exelon Generation@
4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office Attachments 2, 3 and 5 contain business sensitive and/or personally identifiable information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 2, 3, and 5, this cover letter is decontrolled.
RS-15-245 November 18, 2015 ATTN: Document Control Desk Director, Division of Security Operations Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission 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 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 10 CFR 95.17 Attachments 2, 3, and 5 contain business sensitive and/or personally identifiable information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 2, 3, and 5, this cover letter is decontrolled.
Attachments 2, 3, and 5 contain business sensitive and/or personally identifiable information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 2, 3, and 5, this cover letter is decontrolled.
November 18, 2015 U.S. Nuclear Regulatory Commission Page2 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRC Docket Nos. 50-220 and 50-410 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket Nos. 50-219 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265 RE. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 N RC Docket No. 50-244 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289
Subject:
Supplement to Foreign Ownership Control or Influence Package for Exelon Generation Company, LLC
References:
- 1. Letter from P.R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Submission of Standard Practice Procedure Plans and Foreign Ownership Control or Influence Package," dated July 2, 2014
- 2. Letter from P. R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Dissolution of Exelon Ventures Company, LLC," dated October 27, 2014
- 3. Letter from P. R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Advisement of Leadership Changes for Exelon Generation Company, LLG,"
dated December 2, 2014
- 4. Letter from P. R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Submission of Standard Practice Procedures Plans," dated December 16, 2014 Attachments 2, 3, and 5 contain business sensitive and/or personally identifiable information. Withhold from public disclosure under 1 O CFR 2.390. When separated from Attachments 2, 3, and 5, this cover letter is decontrolled.
Attachments 2, 3, and 5 contain business sensitive and/or personally identifiable information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 2, 3, and 5, this cover letter is decontrolled.
November 18, 2015 U.S. Nuclear Regulatory Commission Page 3
- 5. Letter from P.R. Simpson (Exelon Generation Company, LLC) to U.S. NRG, "Advisement of Leadership Changes for Exelon Generation Company, LLC,"
dated February 10, 2015
- 6. Letter from P.R. Simpson (Exelon Generation Company, LLC) to U.S. NRG, "Advisement of Leadership Changes for Exelon Generation Company, LLC,"
dated July 23, 2015
- 7. Letter from P.R. Simpson (Exelon Generation Company, LLC) to U.S. NRG, "Advisement of Leadership Changes for Exelon Generation Company, LLC,"
dated August 11, 2015 In Reference 1, Exelon Generation Company, LLC (EGG) submitted an updated Foreign Ownership, Control, or Influence (FOCI) package to the NRG for review for the nuclear power plants listed above. Supplemental information to support the NRC's review was provided in References 2 through 7.
EGG has identified that two holding companies were inadvertently omitted from the Reference 1 FOCI package. Accordingly, EGG is providing the following revisions to some of the filed documents and some additional documents to correct and complete the filing. Additional changes during the intervening time are also reflected in some amended documents.
- 1. Attachment 1 provides a portion of the Exelon Corporation entity chart to assist in following the corporate ownerships.
- 2. Attachment 2 provides revised SF328 and OODEP forms for Constellation Nuclear, LLC and for Constellation Energy Nuclear Group, LLC. EGG has revised the footnotes explaining the relationship of the parties on the SF328 and OODEP documents.
Revisions to the audited financial statements for EGG and Constellation Nuclear, LLC are also provided in Attachment 2.
- 3. Attachment 3 provides a new FOCI package for the two holding companies (i.e., CE Nuclear, LLC and Constellation Holdings, LLC) that were inadvertently omitted from the Reference 1 FOCI package.
In accordance with 1 O CFR 95.17, "Processing facility clearance," EGG is notifying the NRG of a change that affects information included in the References. Specifically, recent organizational changes that affect the Owners, Officers, Directors, and Executive Personnel (OODEP) lists became effective. Attachment 5 supplements the referenced submission, and provides updated OODEP lists for Exelon Corporation; EGG; Calvert Cliffs Nuclear Power Plant, LLC; Nine Mile Point Nuclear Power Plant, LLC; and R.E. Ginna Nuclear Power Plant, LLC.
Attachments 2, 3, and 5 contain business sensitive and/or personally identifiable information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 2, 3, and 5, this cover letter is decontrolled.
Attachments 2, 3, and 5 contain business sensitive and/or personally identifiable information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 2, 3, and 5, this cover letter is decontrolled.
November 18, 2015 U.S. Nuclear Regulatory Commission Page4 Portions of Attachments 2, 3, and 5 contain Personally Identifiable Information that, if made public, would constitute a clearly unwarranted invasion of personal privacy. Additionally, Attachments 2 and 3 contain information that EGC considers business sensitive information.
Accordingly, as supported by the affidavit provided in Attachment 4, it is respectfully requested that the information in Attachments 2, 3, and 5 be withheld from public disclosure in accordance with 10 CFR 2.390, "Public inspections, exemptions, requests for withholding," paragraphs (a)(4) and (a)(6). Because EGC seeks to withhold these Attachments in their entirety, non proprietary versions of the Attachments have not been prepared.
There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact me at (630) 657-2823.
R~
Patrick R. Simpson Manager - Licensing Attachments:
f
- 1. Excerpt from Exelon Corporation Entity Chart
- 2. Revised SF328 Forms, OODEP Forms, and Audited Financial Statements
- 3. Foreign Ownership, Control, or Influence Package for CE Nuclear, LLC and Constellation Holdings, LLC
- 4. Affidavit Supporting Request for Withholding
- 5. Updated OODEP Lists Attachments 2, 3, and 5 contain business sensitive and/or personally identifiable information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 2, 3, and 5, this cover letter is decontrolled.
bee:
C. B. Hollman - Department of Energy Douglas W. Hase - U.S. NRC Manager, Licensing - Byron, Braidwood, LaSalle (Cover letter only (CL))
Manager, Licensing - Dresden, Quad Cities, Clinton Manager, Licensing - Limerick, Oyster Creek, Peach Bottom (CL)
Manager, Licensing - Calvert Cliffs, Ginna, Nine Mile Point (CL)
Regulatory Assurance Manager - Braidwood (CL)
Regulatory Assurance Manager - Byron (CL)
Regulatory Assurance Manager - Calvert Cliffs (CL)
Regulatory Assurance Manager - Clinton (CL)
Regulatory Assurance Manager - Dresden (CL)
Regulatory Assurance Manager - Ginna (CL)
Regulatory Assurance Manager-LaSalle (CL)
Regulatory Assurance Manager - Limerick (CL)
Regulatory Assurance Manager - Nine Mile Point (CL)
Regulatory Assurance Manager - Oyster Creek (CL)
Regulatory Assurance Manager - Peach Bottom (CL)
Regulatory Assurance Manager - Quad Cities (CL)
Regulatory Assurance Manager - TMI (CL)
Exelon Nuclear Document Control Desk - Licensing (Electronic Copy)
Commitment Tracking Coordinator, East - R. Gropp (CL)
Commitment Tracking Coordinator, West - M. Mathews (CL)
Ken Nicely
ATTACHMENT 1 Excerpt from Exelon Corporation Entity Chart EXELON CORPORATION Exelon Generation Company, LLC Constellation Nuclear, LLC Constellation Holdings, LLC ~=-i 95% ExGen; 5% Constellation Holdings, LLC
~T~
=--*--~-------
l Constellation Energy Nuclear
Group, LLC i
I 49.11% CN; 0.90% CEN
- ~~,,,,. ~-,.. -.-..,;. """"""'-**-*
I i Constellation Nuclear Power" Plants, LLC l
~-,,,. :='~*~+?.-* *~....,~c~*=;=-~.,,,,,:.
Calvert Cliffs Nuclear*
Power Plant, LLC Nine Mile Point Nuclear Station,.LLC ~
~------]
~~~~
ATTACHMENT 4 Affidavit Supporting Request for Withholding
Affidavit in Support of Request to Withhold Information from Public Disclosure Pursuant to 1 O CFR 2.390 I, Patrick R. Simpson, Manager-Licensing, state that:
- 2. EGC is submitting a supplement to the Foreign Ownership, Control, or Influence Package to the Nuclear Regulatory Commission (NRC) for its review and for the purpose of obtaining a renewal of its non-possessing facility clearance (FCL) at the Secret-National Security Information Level.
- 3. Portions of the information being submitted in Attachments 2, 3, and 5 contain Personally Identifiable Information (Pll) that is appropriate to be withheld from public disclosure in accordance with 10 CFR 2.390(a)(6).
- 4. Other information being submitted in Attachments 2 and 3 contains confidential business information and records related to EGC that should be held in confidence by the NRC, pursuant to 10 CFR 9.17(a)(4) and 10 CFR 2.390(a)(4). The following factors, as specified in 10 CFR 2.390(b)(4), justify withholding this information from public disclosure in its entirety:
- a. This information is and has been held in confidence by EGC.
- b. This information is a type that is held in confidence by EGC, and there is a rational basis for doing so because the information contains sensitive business information related to the business structure of the companies.
- c. This information is being transmitted to the NRC in confidence.
- d. This information is not available in public sources and could not be gathered readily from other publically available information.
- 5. Accordingly, EGC requests that the designated information be withheld from public disclosure pursuant to 10 CFR 9.17 and 10 CFR 2.390.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 18th day of November 2015.
Patrick R. Simpson Manager - Licensing t
Exelon Generation Company, LLC
Exelon Generation@
4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office Attachments 2, 3 and 5 contain business sensitive and/or personally identifiable information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 2, 3, and 5, this cover letter is decontrolled.
RS-15-245 November 18, 2015 ATTN: Document Control Desk Director, Division of Security Operations Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission 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 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 10 CFR 95.17 Attachments 2, 3, and 5 contain business sensitive and/or personally identifiable information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 2, 3, and 5, this cover letter is decontrolled.
Attachments 2, 3, and 5 contain business sensitive and/or personally identifiable information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 2, 3, and 5, this cover letter is decontrolled.
November 18, 2015 U.S. Nuclear Regulatory Commission Page2 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRC Docket Nos. 50-220 and 50-410 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket Nos. 50-219 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265 RE. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 N RC Docket No. 50-244 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289
Subject:
Supplement to Foreign Ownership Control or Influence Package for Exelon Generation Company, LLC
References:
- 1. Letter from P.R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Submission of Standard Practice Procedure Plans and Foreign Ownership Control or Influence Package," dated July 2, 2014
- 2. Letter from P. R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Dissolution of Exelon Ventures Company, LLC," dated October 27, 2014
- 3. Letter from P. R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Advisement of Leadership Changes for Exelon Generation Company, LLG,"
dated December 2, 2014
- 4. Letter from P. R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Submission of Standard Practice Procedures Plans," dated December 16, 2014 Attachments 2, 3, and 5 contain business sensitive and/or personally identifiable information. Withhold from public disclosure under 1 O CFR 2.390. When separated from Attachments 2, 3, and 5, this cover letter is decontrolled.
Attachments 2, 3, and 5 contain business sensitive and/or personally identifiable information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 2, 3, and 5, this cover letter is decontrolled.
November 18, 2015 U.S. Nuclear Regulatory Commission Page 3
- 5. Letter from P.R. Simpson (Exelon Generation Company, LLC) to U.S. NRG, "Advisement of Leadership Changes for Exelon Generation Company, LLC,"
dated February 10, 2015
- 6. Letter from P.R. Simpson (Exelon Generation Company, LLC) to U.S. NRG, "Advisement of Leadership Changes for Exelon Generation Company, LLC,"
dated July 23, 2015
- 7. Letter from P.R. Simpson (Exelon Generation Company, LLC) to U.S. NRG, "Advisement of Leadership Changes for Exelon Generation Company, LLC,"
dated August 11, 2015 In Reference 1, Exelon Generation Company, LLC (EGG) submitted an updated Foreign Ownership, Control, or Influence (FOCI) package to the NRG for review for the nuclear power plants listed above. Supplemental information to support the NRC's review was provided in References 2 through 7.
EGG has identified that two holding companies were inadvertently omitted from the Reference 1 FOCI package. Accordingly, EGG is providing the following revisions to some of the filed documents and some additional documents to correct and complete the filing. Additional changes during the intervening time are also reflected in some amended documents.
- 1. Attachment 1 provides a portion of the Exelon Corporation entity chart to assist in following the corporate ownerships.
- 2. Attachment 2 provides revised SF328 and OODEP forms for Constellation Nuclear, LLC and for Constellation Energy Nuclear Group, LLC. EGG has revised the footnotes explaining the relationship of the parties on the SF328 and OODEP documents.
Revisions to the audited financial statements for EGG and Constellation Nuclear, LLC are also provided in Attachment 2.
- 3. Attachment 3 provides a new FOCI package for the two holding companies (i.e., CE Nuclear, LLC and Constellation Holdings, LLC) that were inadvertently omitted from the Reference 1 FOCI package.
In accordance with 1 O CFR 95.17, "Processing facility clearance," EGG is notifying the NRG of a change that affects information included in the References. Specifically, recent organizational changes that affect the Owners, Officers, Directors, and Executive Personnel (OODEP) lists became effective. Attachment 5 supplements the referenced submission, and provides updated OODEP lists for Exelon Corporation; EGG; Calvert Cliffs Nuclear Power Plant, LLC; Nine Mile Point Nuclear Power Plant, LLC; and R.E. Ginna Nuclear Power Plant, LLC.
Attachments 2, 3, and 5 contain business sensitive and/or personally identifiable information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 2, 3, and 5, this cover letter is decontrolled.
Attachments 2, 3, and 5 contain business sensitive and/or personally identifiable information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 2, 3, and 5, this cover letter is decontrolled.
November 18, 2015 U.S. Nuclear Regulatory Commission Page4 Portions of Attachments 2, 3, and 5 contain Personally Identifiable Information that, if made public, would constitute a clearly unwarranted invasion of personal privacy. Additionally, Attachments 2 and 3 contain information that EGC considers business sensitive information.
Accordingly, as supported by the affidavit provided in Attachment 4, it is respectfully requested that the information in Attachments 2, 3, and 5 be withheld from public disclosure in accordance with 10 CFR 2.390, "Public inspections, exemptions, requests for withholding," paragraphs (a)(4) and (a)(6). Because EGC seeks to withhold these Attachments in their entirety, non proprietary versions of the Attachments have not been prepared.
There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact me at (630) 657-2823.
R~
Patrick R. Simpson Manager - Licensing Attachments:
f
- 1. Excerpt from Exelon Corporation Entity Chart
- 2. Revised SF328 Forms, OODEP Forms, and Audited Financial Statements
- 3. Foreign Ownership, Control, or Influence Package for CE Nuclear, LLC and Constellation Holdings, LLC
- 4. Affidavit Supporting Request for Withholding
- 5. Updated OODEP Lists Attachments 2, 3, and 5 contain business sensitive and/or personally identifiable information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 2, 3, and 5, this cover letter is decontrolled.
bee:
C. B. Hollman - Department of Energy Douglas W. Hase - U.S. NRC Manager, Licensing - Byron, Braidwood, LaSalle (Cover letter only (CL))
Manager, Licensing - Dresden, Quad Cities, Clinton Manager, Licensing - Limerick, Oyster Creek, Peach Bottom (CL)
Manager, Licensing - Calvert Cliffs, Ginna, Nine Mile Point (CL)
Regulatory Assurance Manager - Braidwood (CL)
Regulatory Assurance Manager - Byron (CL)
Regulatory Assurance Manager - Calvert Cliffs (CL)
Regulatory Assurance Manager - Clinton (CL)
Regulatory Assurance Manager - Dresden (CL)
Regulatory Assurance Manager - Ginna (CL)
Regulatory Assurance Manager-LaSalle (CL)
Regulatory Assurance Manager - Limerick (CL)
Regulatory Assurance Manager - Nine Mile Point (CL)
Regulatory Assurance Manager - Oyster Creek (CL)
Regulatory Assurance Manager - Peach Bottom (CL)
Regulatory Assurance Manager - Quad Cities (CL)
Regulatory Assurance Manager - TMI (CL)
Exelon Nuclear Document Control Desk - Licensing (Electronic Copy)
Commitment Tracking Coordinator, East - R. Gropp (CL)
Commitment Tracking Coordinator, West - M. Mathews (CL)
Ken Nicely
ATTACHMENT 1 Excerpt from Exelon Corporation Entity Chart EXELON CORPORATION Exelon Generation Company, LLC Constellation Nuclear, LLC Constellation Holdings, LLC ~=-i 95% ExGen; 5% Constellation Holdings, LLC
~T~
=--*--~-------
l Constellation Energy Nuclear
Group, LLC i
I 49.11% CN; 0.90% CEN
- ~~,,,,. ~-,.. -.-..,;. """"""'-**-*
I i Constellation Nuclear Power" Plants, LLC l
~-,,,. :='~*~+?.-* *~....,~c~*=;=-~.,,,,,:.
Calvert Cliffs Nuclear*
Power Plant, LLC Nine Mile Point Nuclear Station,.LLC ~
~------]
~~~~
ATTACHMENT 4 Affidavit Supporting Request for Withholding
Affidavit in Support of Request to Withhold Information from Public Disclosure Pursuant to 1 O CFR 2.390 I, Patrick R. Simpson, Manager-Licensing, state that:
- 2. EGC is submitting a supplement to the Foreign Ownership, Control, or Influence Package to the Nuclear Regulatory Commission (NRC) for its review and for the purpose of obtaining a renewal of its non-possessing facility clearance (FCL) at the Secret-National Security Information Level.
- 3. Portions of the information being submitted in Attachments 2, 3, and 5 contain Personally Identifiable Information (Pll) that is appropriate to be withheld from public disclosure in accordance with 10 CFR 2.390(a)(6).
- 4. Other information being submitted in Attachments 2 and 3 contains confidential business information and records related to EGC that should be held in confidence by the NRC, pursuant to 10 CFR 9.17(a)(4) and 10 CFR 2.390(a)(4). The following factors, as specified in 10 CFR 2.390(b)(4), justify withholding this information from public disclosure in its entirety:
- a. This information is and has been held in confidence by EGC.
- b. This information is a type that is held in confidence by EGC, and there is a rational basis for doing so because the information contains sensitive business information related to the business structure of the companies.
- c. This information is being transmitted to the NRC in confidence.
- d. This information is not available in public sources and could not be gathered readily from other publically available information.
- 5. Accordingly, EGC requests that the designated information be withheld from public disclosure pursuant to 10 CFR 9.17 and 10 CFR 2.390.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 18th day of November 2015.
Patrick R. Simpson Manager - Licensing t
Exelon Generation Company, LLC