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Early Plant Retirements (Exelon and Generation)
 6 Months Ended
Jun. 30, 2020
Property, Plant and Equipment [Abstract]  
Early Plant Retirements (Exelon and Generation) Early Plant Retirements (Exelon and Generation)
Exelon and Generation continuously evaluate factors that affect the current and expected economic value of Generation’s plants, including, but not limited to: market power prices, results of capacity auctions, potential legislative and regulatory solutions to ensure plants are fairly compensated for benefits they provide through their carbon-free emissions, reliability, or fuel security, and the impact of potential rules from the EPA requiring reduction of carbon and other emissions and the efforts of states to implement those final rules. The precise timing of an early retirement date for any plant, and the resulting financial statement impacts, may be affected by many factors, including the status of potential regulatory or legislative solutions, results of any transmission system reliability study assessments, the nature of any co-owner requirements and stipulations, and NDT fund requirements for nuclear plants, among other factors. However, the earliest retirement date for any plant would usually be the first year in which the unit does not have capacity or other obligations, and where applicable, just prior to its next scheduled nuclear refueling outage.
Nuclear Generation
In 2015 and 2016, Generation identified the Clinton and Quad Cities nuclear plants in Illinois, Ginna and Nine Mile Point nuclear plants in New York and Three Mile Island nuclear plant in Pennsylvania as having the greatest risk of early retirement based on economic valuation and other factors. In 2017, PSEG made public similar financial challenges facing its New Jersey nuclear plants, including Salem, of which Generation owns a 42.59% ownership interest. PSEG is the operator of Salem and also has the decision-making authority to retire Salem.
Assuming the continued effectiveness of the Illinois ZES, New Jersey ZEC program and the New York CES, Generation and CENG, through its ownership of Ginna and Nine Mile Point, no longer consider Clinton, Quad Cities, Salem, Ginna or Nine Mile Point to be at heightened risk for early retirement. However, to the extent the Illinois ZES, New Jersey ZEC program or the New York CES do not operate as expected over their full terms, each of these plants could again be at heightened risk for early retirement, which could have a material impact on Exelon’s and Generation’s future financial statements. In addition, FERC’s December 19, 2019 order on the MOPR in PJM may undermine the continued effectiveness of the Illinois ZES and the New Jersey ZEC program unless Illinois and New Jersey implement an FRR mechanism under which the Generation plants in these states would be removed from PJM’s capacity auction. See Note 2 — Regulatory Matters for additional information on the New Jersey ZEC program, New York CES and FERC's December 19, 2019 order and Note 3 — Regulatory Matters of the 2019 Form 10-K for additional information on the Illinois ZES.
In Pennsylvania, the TMI nuclear plant did not clear in the May 2017 PJM capacity auction for the 2020-2021 planning year, the third consecutive year that TMI failed to clear the PJM base residual capacity auction and on May 30, 2017, based on these capacity auction results, prolonged periods of low wholesale power prices, and the absence of federal or state policies that place a value on nuclear energy for its ability to produce electricity without air pollution, Generation announced that it would permanently cease generation operations at TMI. On September 20, 2019, Generation permanently ceased generation operations at TMI.
As a result of the early nuclear plant retirement decision at TMI, Exelon and Generation recognized incremental non-cash charges to earnings stemming from shortening the expected economic useful lives primarily related to accelerated depreciation of plant assets (including any ARC) and accelerated amortization of nuclear fuel, as well as operating and maintenance expenses. The total impact for the three and six months ended June 30, 2019 are summarized in the table below.
Income statement expense (pre-tax)
 
Three Months Ended June 30, 2019
 
Six Months Ended June 30, 2019
Depreciation and amortization
 
 
 
 
Accelerated depreciation
 
$
71

 
$
145

Accelerated nuclear fuel amortization
 
4

 
9

Operating and maintenance(a)
 
—

 
(83
)
Total
 
$
75

 
$
71

_________
(a)
Primarily reflects the net impacts associated with the remeasurement of the TMI ARO. See Note 9 — Asset Retirement Obligations of the 2019 Form 10-K for additional information.
Generation’s Dresden, Byron and Braidwood nuclear plants in Illinois are also showing increased signs of economic distress, which could lead to an early retirement, in a market that does not currently compensate them for their unique contribution to grid resiliency and their ability to produce large amounts of energy without carbon and air pollution. The May 2018 PJM capacity auction for the 2021-2022 planning year resulted in the largest volume of nuclear capacity ever not selected in the auction, including all of Dresden, and portions of Byron and Braidwood. While all of LaSalle's capacity did clear in the 2021-2022 planning year auction, Generation has become increasingly concerned about the economic viability of this plant as well in a landscape where energy market prices remain depressed and energy market rules remain fatally flawed. Exelon continues to work with stakeholders on state policy solutions, while also advocating for broader market reforms at the regional and federal level. The absence of such solutions or reforms could result in future impairments of the Midwest asset group, or accelerated depreciation for specific plants over their shortened estimated useful lives, both of which could have a material unfavorable impact on Exelon's and Generation's future results of operations.
The following table provides the balance sheet amounts as of June 30, 2020 for Exelon's and Generation's significant assets and liabilities associated with these four nuclear plants. Depreciation provisions are based on the estimated useful lives of these nuclear generating stations, which reflect the first renewal of the operating licenses.
 
 
Dresden
 
Byron
 
Braidwood
 
LaSalle
 
Total
Asset Balances
 
 
 
 
 
 
 
 
 
 
Materials and supplies inventory, net
 
$
70

 
$
70

 
$
82

 
$
108

 
$
330

Nuclear fuel inventory, net
 
182

 
145

 
180

 
244

 
751

Completed plant, net
 
1,057

 
1,334

 
1,416

 
1,588

 
5,395

Construction work in progress
 
18

 
21

 
18

 
19

 
76

Liability Balances
 
 
 
 
 
 
 
 
 
 
Asset retirement obligation
 
(1,317
)
 
(604
)
 
(562
)
 
(915
)
 
(3,398
)
 
 
 
 
 
 
 
 
 
 
 
NRC License First Renewal Term
 
2029 (Unit 2)

 
2044 (Unit 1)

 
2046 (Unit 1)

 
2042 (Unit 1)

 
 
 
2031 (Unit 3)

 
2046 (Unit 2)

 
2047 (Unit 2)

 
2043 (Unit 2)

 
 

Other Generation
On March 29, 2018, Generation notified grid operator ISO-NE of its plans to early retire its Mystic Units 8 and 9 absent regulatory reforms on June 1, 2022, at the end of the then-current capacity commitment for Mystic Units 7 and 8. Mystic Unit 9 was then committed through May 2021.
On May 16, 2018, Generation made a filing with FERC to establish cost-of-service compensation and terms and conditions of service for Mystic Units 8 and 9 for the period between June 1, 2022 - May 31, 2024. On December 20, 2018, FERC issued an order accepting the cost of service agreement, reflecting a number of adjustments to the annual fixed revenue requirement and allowing for recovery of a substantial portion of the costs associated with the Everett Marine Terminal. Those adjustments were reflected in a compliance filing filed March 1, 2019. In the December 20, 2018 order, FERC also directed a paper hearing on ROE using a new methodology. On January 22, 2019, Exelon and several other parties filed requests for rehearing of certain findings in the order. On July 17, 2020, FERC issued three orders, which together affirmed the recovery of key elements of Mystic's cost of service compensation, including recovery of costs associated with the operation of the Everett Marine Terminal. FERC directed a downward adjustment to the rate base for Mystic Units 8 and 9, the effect of which will be partially offset by elimination of a crediting mechanism for third party gas sales during the term of the cost of service agreement. A compliance filing will be due on September 15, 2020. On July 28, 2020, FERC ordered additional briefings in the ROE proceeding, with initial briefs due by September 28, 2020.
On March 25, 2019, ISO-NE filed the Inventoried Energy Program (IEP), which is intended to provide an interim fuel security program pending conclusion of the stakeholder process to develop a long-term, market-based solution to address fuel security. The IEP went into effect by operation of law on August 5, 2019 because FERC did not have a quorum at that time. On October 7, 2019, requests for rehearing were denied and several parties appealed to the D.C. Circuit Court. On April 14, 2020, FERC filed an unopposed motion asking the court for a voluntary remand of the IEP order, noting that FERC now has a quorum of commissioners who can participate in the consideration of ISO-NE’s IEP filing. On April 21, 2020, the D.C. Circuit Court granted the voluntary remand and on June 18, 2020, FERC issued an order finding the IEP just and reasonable and accepting ISO-NE's proposed tariff revisions. Several parties have filed requests for rehearing.
On April 15, 2020, ISO-NE filed its long-term, market-based fuel security proposal, proposing three new, day-ahead ancillary services products intended to compensate generators for operational capabilities that provide fuel security to the region. In the filing, ISO-NE also proposed to sunset the Fuel Security Retention Mechanism, through which Mystic has been retained for fuel security, and the IEP by June 1, 2024. In addition, the filing includes an alternate proposal sponsored by New England Power Pool (NEPOOL), which includes substantive amendments to the ISO-NE proposal. On May 15, 2020, Exelon filed a limited protest to ISO's long-term fuel-security proposal asking FERC to accept ISO-NE's proposal but to direct ISO-NE to revise its tariff so that the IEP remains in place as a safeguard until the long-term solution is in place. A number of other comments in support and protests have been filed. ISO-NE asked for a decision on its proposal by November 1, 2020.
On June 12, 2020, Generation filed a complaint with FERC against ISO-NE on the grounds that ISO-NE failed to follow its tariff with respect to its evaluation of Mystic for transmission security for the 2024 to 2025 Capacity Commitment Period (FCA 15) and that modifications ISO-NE made to its unfiled planning procedures to avoid retaining Mystic should have been filed with FERC for approval. Generation asked for a ruling from FERC by August 10, 2020, but ISO-NE asserts that a ruling is not needed until November 2, 2020. On July 27, 2020, ISO-NE issued a memo to NEPOOL announcing its determination pursuant to its unfiled planning procedures that Mystic Units 8 and 9 are not needed for FCA 15 for transmission security. It had previously determined Mystic Units 8 and 9 are not needed for fuel security. The timing and the outcome of this proceeding is uncertain.
The following table provides the balance sheet amounts as of June 30, 2020 for Exelon's and Generation’s significant assets and liabilities associated with the Mystic Units 8 and 9 and Everett Marine Terminal assets that would potentially be impacted by the failure to adopt long-term solutions for reliability and fuel security.
 
 
June 30, 2020
Asset Balances
 
 
Materials and supplies inventory
 
$
33

Fuel inventory
 
6

Property, plant and equipment, net
 
898

Liability Balances
 
 
Asset retirement obligation
 
(3
)

See Note 8 — Asset Impairments for impairment assessment considerations on the New England Asset Group.