ML14050A371
| ML14050A371 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, Nine Mile Point, Ginna  |
| Issue date: | 02/05/2014 |
| From: | Korsnick M G Calvert Cliffs, Constellation Energy Nuclear Group, EDF Group, Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML14050A371 (30) | |
Text
INCLUDES PROPRIETARY INFORMATION WITHHOLD UNDER 10 CFR 2.390Mary G. KorsnickActing Chief Executive OfficerChief Nuclear OfficerOffice 410-470-5133 Fax 443-213-6739 E-mail: Maria.Korsnick@cengllc.com ExelOn.Generation CENG.a joint venture of20eI10 CFR 50.8010 CFR 50.9010 CFR 72.50February 5, 2014U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION:
SUBJECT:
Document Control DeskCalvert Cliffs Nuclear Power Plant, Units 1 and 2Renewed Facility Operating License Nos. DPR-53 and DPR-69Docket Nos. 50-317 and 50-318Calvert Cliffs Independent Spent Fuel Storage Installation Materials License No. SNM-2505Docket No. 72-8Nine Mile Point Nuclear Station, Units 1 and 2Renewed Facility Operating License Nos. DPR-63 and NPF-69Docket Nos. 50-220 and 50-410Nine Mile Point Nuclear Station, Independent Spent Fuel Storage Installation General LicenseDocket No. 72-1036R.E. Ginna Nuclear Power PlantRenewed Facility Operating License No. DPR- 18Docket No. 50-244R.E. Ginna Independent Spent Fuel Storage Installation General LicenseDocket No. 72-67Supplemental Response to NRC's Requests for Additional Information Regarding Application for Order Approving Transfer of Operating Authority and Conforming License Amendments (a) Letter from N. S. Morgan (NRC) to M. G. Korsnick (CENG) and B. P.Wright (Exelon),
dated December 5, 2013 Calvert Cliffs Nuclear PowerPlant, Unit Nos. I and 2, Nine Mile Point Nuclear Station, Unit Nos. 1 and
REFERENCES:
Constellation Energy Nuclear Group, LLC100 Constellation Way, Suite 200C, Baltimore, MD 21202UNRESTRICTED UPON REMOVAL OF ATTACHMENT 2A Document Control DeskFebruary 5, 2014Page 22, and R. E. Ginna Nuclear Power Plant- Request for Additional Information Regarding Order Approving Direct Transfer of RenewedFacility Operating Licenses and Conforming Amendments (TAC No.MF2584, MF2585, MF2586, MF2587, and MF2588) (ML13337A390)
(b) Letter from M. G. Korsnick (CENG) and B. P. Wright (Exelon) toDocument Control Desk (NRC), dated August 6, 2013, Application forOrder Approving Transfer of Operating Authority and Conforming LicenseAmendments (ML 13232A 156)(c) Letter from J. A. Spina (CENG) to Document Control Desk (NRC), datedDecember 17, 2013, Response to NRC's Requests for Additional Information Regarding Application for Order Approving Transfer ofOperating Authority and Conforming License Amendments (ML13360A200)
(d) Email from N. S. Morgan to E. M. Tyler, dated January 24, 2014,CENG/Exelon LTA StatusThe purpose of this letter is to supplement the response of Constellation Energy Nuclear Group, LLC(CENG), acting on behalf of itself, Exelon Generation
- Company, LLC (ExGen),
and its subsidiary licensees, Calvert Cliffs Nuclear Power Plant, LLC , Nine Mile Point Nuclear Station, LLC and R.E.Ginna Nuclear Power Plant, LLC, dated December 17, 2013 (Reference c). That letter responded to theNuclear Regulatory Commission's request for additional information (Reference a) regarding theApplication for Order Approving Transfer of Operating Authority and Conforming License Amendments (Reference b). On January 24, 2014, the NRC Staff relayed two follow-up questions which weretransmitted by email (Reference d) and discussed in two subsequent telephone conferences.
Responses tothe requests for additional information are provided in Attachment (1) along with supplemental information provided as Attachments (2) through (3).Please note that Attachment (2A) is being provided in a separately-bound proprietary enclosure.
Attachment (2A) contains confidential financial, commercial, and proprietary material non-public information of CENG and its subsidiaries and Exelon Corporation and its subsidiaries.
We request thatAttachment (2A) be withheld from public disclosure pursuant to 10 CFR §§ 2.390(a)(3) and (4) and9.17(a)(3) and (4). Attachment (2) is provided as a non-proprietary version suitable for public disclosure.
An affidavit supporting the request for withholding Attachment (2A) from public disclosure is providedas Attachment (3).This correspondence does not contain any regulatory commitments.
If there are any questions regarding this transmittal, please contact Bruce Montgomery at (443)-532-6533.
Document Control DeskFebruary 5, 2014Page 3I declare under penalty of perjury that the foregoing is true and correct.
Executed on February 5, 2014.Sincerely, Mary NG. orsnickAttachments:
(1) Supplemental Response to NRC Request for Additional Information (2) Additional Financial Information (Non-Proprietary Version)(2A)Additional Financial Information (Proprietary, Restricted Version)(3) 10 CFR 2.390 Affidavit of Bryan P. Wrightcc: (With Attachment 2A)NRC Project Manager, Calvert CliffsNRC Project Manager, GinnaNRC Project Manager, Nine Mile PointRegional Administrator, NRC Region ISusan Uttal, NRC Office of General Counsel(Without Attachment 2A)USNRC, Director, Office of Nuclear Reactor Regulation USNRC, Director, Office of Nuclear Material Safety and Safeguards NRC Resident Inspector
-Calvert CliffsNRC Resident Inspector
-Nine Mile PointNRC Resident Inspector
-R.E. GinnaS. Gray, Maryland DNRA. L. Peterson, NYSERDAB. Frymire, NYSDPS ATTACHMENT (1)SUPPLEMENTAL RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION Constellation Energy Nuclear Group, LLCFebruary 5, 2014 ATTACHMENT (1)SUPPLEMENTAL RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION For convenience of the reader, references are placed at the end of this attachment.
Requested Information 1: Financial Oualifications In accordance with 10 CFR 50.3369(2),
the Applicants provided financial information on Constellation and the licensees to demonstrate that they possess, or have reasonable assurance of obtaining the fundsnecessary to cover the projected operating costs of Calvert Cliffs, Calvert Cliffs ISFSL, Ginna, GinnaISFSI, NMP 1, and a pro rata share of the estimated operating costs of NMP 2 associated with a total82% undivided ownership interest for the period of their respective licenses.
Based on the application, Constellation states that it currently "maintains a cash pooling arrangement with an Inter-Company Credit Agreement that provides an additional vehicle for managing the workingcapital needs of the Licensees" This cash pooling arrangement was reviewed by the NRC in connection with the indirect license transfer related to corporate restructuring in 2011.Under 10 CFR 50.33(l) a non-utility applicant must provide information sufficient to demonstrate itsfinancial qualifications to carry out the activities for which the license is being sought. In addition, perNUREG 1577, Rev. 1, the reviewer "will also consider relevant financial information (i.e., information oncash or cash equivalents that would be sufficient to pay fixed operating costs during an outage of at least6 months..
.and any other relevant factors)."
- Finally, 10 CFR 50.33(t)(4) states, in part:The Commission may request an established entity or newly-formed entity to submit additional ormore detailed information respecting its financial arrangements
.... [T]his may include information regarding a licensee's ability to continue the conduct of the activities authorized by the license...
License transfer financial qualification reviews provide an opportunity for NRC staff to review andultimately address any new financial qualification concerns.
The finding of reasonable assurance thatfunds will be available to cover estimated operating costs for the period of the license relies on theapplicant providing sufficient information regarding availability of credit or support agreements, banklines of credit or other specifically identified sources of funds, sufficient to fund the estimated fixedoperating and maintenance costs the period of the license.Based on the information provided in the application, provide the following additional information, pursuant to 50.3369 regarding financial qualification:
f On September 3, 2013, Federal Energy Regulatory Commission (FERC) issued an Orderapproving Exelon and subsidiaries' petition for a Declaratory Order requesting that FERC findthat section 305(a) of the Federal Power Act (FPA) is not a bar to the payment of dividends fromcertain capital accounts from Constellation subsidiaries (Acquired Subsidiaries).
The Orderstated:Applicants
[Exelon and subsidiaries]
explain that the purpose of this petition is toobtain a determination from the Commission that section 305(a) of the FPA doesnot prohibit:
(1) the Acquired Subsidiaries
[Constellation subsidiaries]
fromPage 1 of 3 ATTACHMENT (1)SUPPLEMENTAL RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION paying dividends to their parent company, Exelon Generation, from theirrespective capital accounts in equal measure to the finds that were recorded asretained earnings at the close of the Merger; and (2) Exelon Generation from, inturn, paying dividends to its parent company, Exelon Ventures, from its capitalaccounts to the extent that Exelon Generation has received dividends from any ofthe Legacy Constellation Subsidiaries paid out offunds recorded as miscellaneous paid-in capital.
Applicants state that granting its petition will enable Exelon tomove excess cash out of the Acquired Subsidiaries and Exelon Generation toallow the use of'this cash elsewhere in the Exelon system. Otherwise, Applicants assert that significant corporate funds could be stranded on the books of theApplicants and rendered unavailable for legitimate corporate purposes.
The NRC has previously expressed concern that corporate restructuring can lead to a diminution of assets necessary for the safe operation and decommissioning of a licensee's nuclear powerplant (62 FR 44071), and has previously conditioned license transfer approvals upon arequirement that the licensee not transfer significant assets from the licensee without firstnotifring the NRC.Please explain if the Exelon's removal of assets from the Constellation subsidiaries willimpact the safe operation of the Constellation plants or decommissioning fundingassurance.
On January 24, 2014, the NRC Staff asked CENG to provide information on the amounttransferred.
How much was transferred firom CENG nuclear holdings or any holding companies?
Did this affect the assets of the nuclear facilities or sources of funds? The licensee will need tomake an affirmative statement that there was no impact to the licensees on the docket or elsedescribe the financial impact(s).
Supplemental ResponseThe Federal Energy Regulatory Commission (FERC) Order of September 3, 2013, referenced in this RAI,is not applicable to Constellation Energy Nuclear Group LLC (CENG) or its subsidiary companies.
TheApplicants in the referenced FERC docket, Docket No. EL13-64, are Exelon Generation
- Company, LLC(ExGen),
CER Generation II, LLC, Constellation Mystic Power, LLC, Constellation NewEnergy, Inc.,Constellation Power Source Generation, Inc., and Criterion Power Partners, LLC. Only these companies received the requested authorization from FERC.Constellation Energy Nuclear Group, LLC does periodically make distributions to its parent companies, in accordance with the terms of applicable agreements.
The plans for such distributions were taken intoaccount in developing and preparing the proforma financial statements provided.
- However, CENG notesthat distributions or dividends are not specifically reflected in any of the line items on income statements.
Requested Information 2: Financial Oualifications In its February 22, 2013, 10K filing with the Securities and Exchange Commission, Exelon stated thefollowing (page 18):Page 2 of 3 ATTACHMENT (1)SUPPLEMENTAL RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION As part of reaching a comprehensive agreement with EDF in October 2010, theexisting power purchase agreements with [Constellation Energy Nuclear Group, LLC]CENG were modified to be unit-contingent through the end of their original term in2014. Under these agreements, CENG has the ability to fixr the energy price on aforward basis by entering into monthly energy hedge transactions for a portion of thefuture sale, while any unhedged portions will be provided at market prices by default.Additionally, beginning in 2015 and continuing to the end of the life of the respective plants, Generation agreed to purchase 50.01% of the available output of CENG'snuclear plants at market prices. Generation discloses in the table above commitments to purchase from CENG at fixed prices. All commitments to purchase from CENG atmarket prices, which include all purchases subsequent to December 31, 2014, areexcluded from the table.Identify the source or sources offunds that will be available to cover operational expenses following theend of the power purchase agreements terms in 2014. Indicate if the pro-formas provided in the licensetransfer application reflect projected market prices from 2015 through 2019. Provide supporting documentation to justify the projected market prices per MWh.On January 24, 2014, the NRC Staff raised questions regarding the projections, as compared with thecurrently reported revenues for Exelon Generation, as reported to the SEC.Supplemental ResponseIn addition to the information previously provided regarding sources of funds to cover operational
- expenses, it is worth noting that as a result of the proposed transaction, ExGen will become the licensedoperator of the CENG units. As such, ExGen will be subject to NRC's specific jurisdiction with respectto the CENG units, and ExGen's substantial resources from both nuclear and non-nuclear operations willfully stand behind ExGen's responsibility for the safe operation of the CENG units.Further detailed financial information regarding ExGen's operations is provided in Attachment (2A). Thefinancial information in Attachment (2A) is considered confidential financial, commercial, andproprietary
- material, non-public information of CENG and its subsidiaries and Exelon Corporation and itssubsidiaries.
We request that Attachment (2A) be withheld from public disclosure pursuant to 10 CFR §§2.390(a)(3) and (4) and 9.17(a)(3) and (4). Attachment (2) is provided as a non-proprietary versionsuitable for public disclosure.
An affidavit supporting the request for withholding Attachment (2A) frompublic disclosure is provided as Attachment (3).Page 3 of 3 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)Constellation Energy Nuclear Group, LLCFebruary 5, 2014 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)Additional Information Regarding Revised Financial Projections The following provides a brief overview of the revised financial projections in this Attachment (2A)submitted to supplement the response of Constellation Energy Nuclear Group, LLC (CENG), acting onbehalf of itself, Exelon Generation
- Company, LLC (ExGen),
and its subsidiary licensees, Calvert CliffsNuclear Power Plant, LLC (Calvert Cliffs),
Nine Mile Point Nuclear Station, LLC (Nine Mile Point) andR.E. Ginna Nuclear Power Plant, LLC (Ginna),
dated December 17, 2013 (Reference c).Page lof 20 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)0Page 2of 20 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)ExGen Consolidated Projected Income Statement (millions) 2014 2015 2016 2017 2018Operating revenuesOperating expensesPurchased power and fuelOperating and maintenance Depreciation and amortization Taxes other than incomeTotal operating expensesEquity in loss of unconsolidated affiliates Operating (loss) incomeOther income and (deductions)
Interest expenseInterest income (excluding Decom)Other, netTotal other income and (deductions)
(Loss) income before income taxesIncome (benefit) taxesNet (loss) incomeNet income (loss) attributable to noncontrolling interests Net (loss) income on membership interestNotes1.2.3.4.Page 3 of 20 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)Exelon Nuclear (an operating unit of ExGen)Projected Income Statement (millions) 2014 2015 2016 2017 2018Operating revenuesOperating expensesPurchased power and fuelOperating and maintenance Depreciation and amortization Taxes other than incomeTotal operating expensesEquity in loss of unconsolidated affiliates Operating (loss) incomeOther income and (deductions)
Interest expenseInterest income (excluding Decom)Other, netTotal other income and (deductions)
(Loss) income before income taxesIncome (benefit) taxesNet (loss) incomeNet income (loss) attributable to noncontrolling interests Net (loss) income on membership interestNotes1.2.3.4.Page 4 of 20 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)5.Page 5 of 20 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)Nine Mile PointProjected Income Statement (millions) 2014 2015 2016 2017 2018RevenuePPAMarket SalesRevenuesOperating ExpensesPurchased Fuel and Energy and Cost of SalesO&M, Non-Outage O&M, Refueling OutageO&M, Allocated Nuclear Corporate O&M, Integration ExpensesO&M, ITTransition ExpensesProperty TaxesDecommissioning ExpensesDepreciation Total Operating ExpensesOperating IncomeOther (Income)/Expense O&M, allocated CEG HQ CostsDecommissioning fund earningsTotal Other (Income)/Expense Pretax Income (Loss)Income TaxesNet Income (Loss) After-Tax Page 6 of 20 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)Calvert CliffsProjected Income Statement (millions) 2014 2015 2016 2017 2018RevenuePPAMarket SalesRevenuesOperating ExpensesPurchased Fuel and Energy and Cost of SalesO&M, Non-Outage O&M, Refueling OutageO&M, Allocated Nuclear Corporate O&M, Integration ExpensesO&M, ITTransition ExpensesProperty TaxesDecommissioning ExpensesDepreciation Total Operating ExpensesOperating IncomeOther (Income)/Expense O&M, allocated CEG HQ CostsDecommissioning fund earningsTotal Other (Income)/Expense Pretax Income (Loss)Income TaxesNet Income (Loss) After-Tax Page 7 of 20 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)GinnaProjected Income Statement (millions) 2014 2015 .2016 2017 2018RevenuePPAMarket SalesRevenuesOperating ExpensesPurchased Fuel and Energy and Cost of SalesO&M, Non-Outage O&M, Refueling OutageO&M, Allocated Nuclear Corporate O&M, Integration ExpensesO&M, IT Transition ExpensesProperty TaxesDecommissioning ExpensesDepreciation Total Operating ExpensesOperating IncomeOther (Income)/Expense O&M, allocated CEG HQ CostsDecommissioning fund earningsTotal Other (Income)/Expense Pretax Income (Loss)Income TaxesNet Income (Loss) After-Tax Page 8 of 20 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)Nine Mile Point, Calvert Cliffs and GinnaNotes1.2.3.4.5.6.7.8.9.10.11.12.13.Page 9 of 20 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)Underlying Inputs for the CENG Plant Sites Financial Projections 2014 2015 2016 2017 zDICalvert CliffsRevenues
($M)PPAMarket SalesEnergyCapacityTotal Market SalesTotal RevenuesAverage Price Per MWhPPAMarket SalesEnergyCapacityPurchased Fuel and Energy and Cost of Sales (SM)Purchased Fuel and Energy and Cost of Sales Per MWhTotal Plant MWh Capacity (MWh)Projected Capacity FactorNine Mile PointRevenues
($M)PPAMarket SalesEnergyCapacityTotal Market SalesTotal RevenuesAverage Price Per MWhPPAMarket SalesEnergyCapacityPurchased Fuel and Energy and Cost of Sales (SM)Purchased Fuel and Energy and Cost of Sales Per MWhTotal Plant MWh Capacity (MWh)Projected Capacity FactorGlnnaRevenues
($M)PPAMarket SalesEnergyCapacityTotal Market SalesTotal RevenuesAverage Price Per MWhPPAMarket SalesEnergyCapacityPurchased Fuel and Energy and Cost of Sales (SM)Purchased Fuel and Energy and Cost of Sales Per MWhTotal Plant MWh Capacity (MWh)Projected Capacity FactorPage 10 of 20 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)Notes1.2.3.4.5.Page 11 of 20 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)Mackenzie Wood Mackenzie North America Power ServiceNosember 15, 2013Average Power Prices (All-In Energy + Capacity, Nominal $IMWh)1 2014 2015 2016 2017 2018+PJM W*eisf HukbNYI80 Zn APage 12 of 20 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)Sensitivity Scenarios Page 13 of 20 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)ExGen Consolidated Projected Income Statement Projected Income Statement
-(millions) 2014 2015 2016 2017 2018Operating revenuesOperating expensesPurchased power and fuelOperating and maintenance Depreciation and amortization Taxes other than incomeTotal operating expensesEquity in loss of unconsolidated affiliates Operating (loss) incomeOther income and (deductions)
Interest expenseInterest income (excluding Decom)Other, netTotal other income and (deductions)
(Loss) income before income taxesIncome (benefit) taxesNet (loss) incomeNet income (loss) attributable to noncontrolling interests Net (loss) income on membership interestNotes1234Page 14 of 20 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)56Page 15 of 20 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)Exelon Nuclear (an operating unit of ExGen)Projected Income Statement Projected Income Statement
-(millions)
Operating revenuesOperating expensesPurchased power and fuelOperating and maintenance Depreciation and amortization Taxes other than incomeTotal operating expensesEquity in loss of unconsolidated affiliates Operating (loss) incomeOther income and (deductions)
Interest expenseInterest income (excluding Decom)Other, netTotal other income and (deductions)
(Loss) income before income taxesIncome (benefit) taxesNet (loss) incomeNet income (loss) attributable to noncontrolling interests Net (loss) income on membership interestNotes234Page 16 of 20 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)567Page 17 of 20 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)Nine Mile PointProjected Income Statement
-Assumes 10% Reduction in Market Revenue(millions) 2014 2015 2016 2017 2018RevenuePPAMarket SalesRevenuesOperating ExpensesPurchased Fuel and Energy and Cost of SalesO&M, Non-Outage O&M, Refueling OutageO&M, Allocated Nuclear Corporate O&M, Integration ExpensesO&M, ITTransition ExpensesProperty TaxesDecommissioning ExpensesDepreciation Total Operating ExpensesOperating IncomeOther (Income)/Expense O&M, allocated CEG HQ CostsDecommissioning fund earningsTotal Other (Income)/Expense Pretax Income (Loss)Income TaxesNet Income (Loss) After-Tax Notes:Revenue sensitivity reflects a 10% decline in market sales (energy and capacity revenues);
PPA sales are not impacted.
Page 18 of 20 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)Calvert CliffsProjected Income Statement
-Assumes 10% Reduction in Market Revenue(millions) 2014 2015 2016 2017 2013RevenuePPAMarket SalesRevenuesOperating ExpensesPurchased Fuel and Energy and Cost of SalesO&M, Non-Outage O&M, Refueling OutageO&M, Allocated Nuclear Corporate O&M, Integration ExpensesO&M, ITTransition ExpensesProperty TaxesDecommissioning ExpensesDepreciation Total Operating ExpensesOperating IncomeOther (Income)/Expense O&M, allocated CEG HQ CostsDecommissioning fund earningsTotal Other (Income)/Expense Pretax Income (Loss)Income TaxesNet Income (Loss) After-Tax Notes:Revenue sensitivity reflects a 10% decline in market sales (energy and capacity revenues);
PPA sales are not impacted.
Page 19 of 20 ATTACHMENT (2)ADDITIONAL FINANCIAL INFORMATION (NON-PROPRIETARY VERSION)GinnaProjected Income Statement
-Assumes 10% Reduction in Market Revenue(millions) 2014 2015 2016 2017 2018RevenuePPAMarket SalesRevenuesOperating ExpensesPurchased Fuel and Energy and Cost of SalesO&M, Non-Outage O&M, Refueling OutageO&M, Allocated Nuclear Corporate O&M, Integration ExpensesO&M, ITTransition ExpensesProperty TaxesDecommissioning ExpensesDepreciation Total Operating ExpensesOperating IncomeOther (Income)/Expense O&M, allocated CEG HQ CostsDecommissioning fund earningsTotal Other (Income)/Expense Pretax Income (Loss)Income TaxesNet Income (Loss) After-Tax Notes:Revenue sensitivity reflects a 10% decline in market sales (energy and capacity revenues);
PPA sales are not impacted.
Page 20 of 20 ATTACHMENT (3)10 CFR 2.390 AFFIDAVIT OF BRYAN P. WRIGHTConstellation Energy Nuclear Group, LLCFebruary 5, 2014 AFFIDAVIT UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSION In the Matter of ))Constellation Energy Nuclear Group, LLC, et al. )AFFIDAVIT I, Bryan P. Wright, Senior Vice President and Chief Financial Officer for Exelon Generation Company,LLC do hereby affirm and state:I1. I am authorized to execute this affidavit on behalf of the entities requesting protection of theinformation.
The information reflected in Attachment (2A) is provided in support of the application ofConstellation Nuclear Energy Group, LLC (CENG), on behalf of itself, ExGen, and the CENGsubsidiary Licensees, for an Order approving license transfers.
The information provided inAttachment (2A) contains ExGen's, Exelon Corporation's, and CENG's commercial financial and proprietary information and financial projections related to the ownership and operation oftheir businesses and proprietary financial projections generated by Wood Mackenzie.
Thisinformation should be held in confidence by the NRC pursuant to the policy reflected in 10 CFR§§ 2.390(a)(3) and (4) and 9.17(a)(3) and (4), because:i. This information is and has been held in confidence by ExGen, Exelon Corporation, andCENG.ii. This information is of a type that is customarily held in confidence by ExGen, ExelonCorporation, and CENG, and there is a rational basis for doing so because the information contains ExGen's, Exelon Corporation's, and/or CENG's sensitive financial information concerning projected revenues and operating expenses.
iii. This information is being transmitted to the NRC voluntarily and in confidence.
iv. This information is not available in public sources and could not be gathered readily fromother publicly available information.
- v. Public disclosure of this information would create substantial harm to the competitive position of ExGen, Exelon Corporation, and/or CENG by disclosing their internal financial projections.
This information constitutes material non-public information regarding ExGen,Exelon Corporation, and CENG. A leak or other limited or selective disclosure of thisinformation would enable those who come into possession of the information to trade, orallow others to trade, in the securities of Exelon Corporation or its subsidiaries while inpossession of material non-public information.
Trading in securities of Exelon Corporation or its subsidiaries while in possession of this information may violate United States laws andthe laws of the various states.Page 1 of 2