ML072750459

Request for Exemption from 10 CFR 50.82(a)(8)

ML072750459
Person / Time
Site:	South Texas
Issue date:	09/19/2007
From:	Sheppard J South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-07002210, STI: 32205487
Download: ML072750459 (74)

Text

Nuclear Operating Company South Texas Promed Electric Generating Station PO. Box 289 Wadsworth, Texas 77483 AA A September 19, 2007 NOC-AE-0700221 0 File No.: G25 10 CFR 50.82 U.S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 South Texas Project Units 1 and 2 Docket Nos. STN 50-498 and STN 50-499 Request for Exemption from 10 CFR 50.82(a)(8)

Pursuant to 10 CFR 50.12, STP Nuclear Operating Company (STPNOC), acting on behalf of NRG South Texas LP (NRG South Texas), the City Public Service Board of San Antonio (CPS) and the City of Austin, Texas (Austin Energy) (together, the "STP Owners"), hereby requests an exemption from Nuclear Regulatory Commission (NRC) regulations to permit the immediate withdrawal of certain funds from the nuclear decommissioning trust funds (NDTs) maintained by the STP Owners for South Texas Project Electric Generating Station Units 1 and 2 (the "Facility").

Specifically, the STP Owners request an exemption from provisions of 10 CFR 50.82(a)(8)(i) and (ii) which may restrict the withdrawal of funds from NDTs until after permanent plant shutdown.

The purpose of this exemption request is to permit the use of NDT funds, not to exceed

$20 million per unit, in order to pay for the prompt disposal of certain major radioactive components (MRCs).

These MRCs are the reactor pressure vessel (RPV) heads to be removed from the Facility in the upcoming Fall 2009 Unit 1 outage and the Spring 2010 Unit 2 outage, as well as the steam generators that were removed from the Facility in 2000 and 2002.

If an exemption cannot be granted by July 1, 2008, to permit the use of NDTs for the immediate permanent disposal of the Unit 1 RPV head, STPNOC will need to initiate contracts to plan, design and construct a mausoleum for on-site RPV head storage at a projected cost of

$1.4 million.

This cost, as well as the cost of ongoing maintenance and eventual decommissioning of the mausoleum, would be avoided altogether if NDT funds can be used to fund disposal of the RPV heads upon removal in 2009 and 2010.

The cost of disposal of these MRCs is included in the site-specific decommissioning cost estimates for the Facility, and funds are being accumulated in the NDTs to cover these costs. If approved, this exemption will facilitate the prompt removal of radiologically contaminated material from the Facility, reduce overall decommissioning costs, and reduce unnecessary regulatory burdens on the STP Owners associated with maintaining the MRCs on-site.

As described more fully in the attachment, the STP Owners collect funds in their NDTs through rates established by their City rate-setting authorities or by the Public Utility Commission of Texas (PUCT) for the purpose of decommissioning the Facility, including MRC disposal. The ST,: 32205487

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NOC-AE-0700221 0 Page 2 of 4 rate-setting authorities do not set any limitation on the timing of decommissioning activities and use of funds for such expenditures, but NRC regulations appear to restrict the use of such commingled funds prior to permanent shutdown of the plant. The requested exemption would provide clear authorization for the STP Owners to use NDT funds for prompt disposal of MRCs prior to permanent plant shutdown.

STPNOC requests that the NRC grant the exemption because:

The exemption is "authorized by law, will not present an undue risk to the public health and safety, and [is] consistent with the common defense and security," in accordance with 10 CFR 50.12(a)(1), and Special circumstances are present that satisfy 10 CFR 50.12(a)(2).

STPNOC demonstrates in the attachment that the request satisfies these provisions.

Granting this exemption will be consistent with the NRC decommissioning regulations as it:

(1) would not foreclose release of the site for possible unrestricted use (in fact, it would enhance STPNOC's ability to achieve unrestricted release);

(2) would not result in significant environmental impacts not previously reviewed by the NRC; and (3) would not undermine the existing and continuing reasonable assurance that adequate funds will be available for decommissioning.

Disposal of the MRCs would facilitate eventual unrestricted release of the Facility, thus improving environmental conditions.

In addition, authorizing prompt disposal would give STPNOC the ability to take advantage of cost effective disposal alternatives and thereby eliminate the uncertainty associated with the future cost and availability of disposal capacity. Prompt disposal of MRC source terms that otherwise would remain on-site until much later in time is prudent and consistent with the underlying purpose of the Commission's decommissioning regulations.

In sum, granting this request will facilitate the decommissioning process by removing the MRCs from the site so that: (1) the inventory of radioactive waste and associated source term at the site will be reduced; (2) the costs and inconveniences associated with maintaining the MRCs on-site will be avoided; (3) the overall cost to decommission the site will be reduced; (4) uncertainty regarding future disposal cost and capacity for these MRCs will be eliminated; and (5) assurance of adequate funds to decommission the reactors at the time the reactors cease operation will be maintained.

Finally, assurance of the adequacy of the availability of funds for Facility decommissioning is supported by a site-specific decommissioning cost estimate and the associated funding program.

STPNOC recognizes that on May 29, 2007, EnergySolutions submitted a rulemaking petition to the NRC (RM 50-88) seeking to, amend the Commission's regulations to provide a process for NRC approval of the use of decommissioning trust funds for the disposal of MRCs by licensees for operating reactors. NRC provided Notice regarding this pending petition and an opportunity for public comment on August 21, 2007 (72 FR 46569).

STPNOC is submitting this exemption request now, because timely resolution of this issue is needed in order to support STPNOC's outage planning activities in mid-2008 for the Fall 2009 Unit 1 outage, which will include removal and replacement of the Unit's RPV head. STPNOC currently anticipates construction of onsite facilities to store the RPV heads from Units 1 and 2 unless the STP Owners' NDT funds may be used to pay for prompt disposal.

NRC's consideration of the rulemaking petition is unlikely to be timed to Support STPNOC's schedule.

Accordingly, STPNOC respectfully requests a response from the NRC by July 1, 2008, in order to avoid the resource allocation and other expenses associated with the design and construction of a new storage facility for the RPV heads from Units 1 and 2, and continued onsite storage of

NOC-AE-0700221 0 Page 3 of 4 other MRCs (steam generators previously removed from Units 1 and 2), which would be avoided if NDT funds can be used for the prompt disposal of the MRCs.

This letter and attachment contain no new commitments.

If NRC requires additional information concerning this request, please contact Mr. Scott Head, STPNOC Licensing Manager, at (361) 972-7136.

J. J. Sheppard President & Chief Executive Officer

Enclosures:

1) Exemption Request

2) Decommissioning Cost Update for the South Texas Project Electric Generating Station - May 2004

NOC-AE-0700221 0 Page 4 of 4 cc:

(paper copy)

(electronic copy)

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Mohan C. Thadani Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North (MS 7 D1) 11555 Rockville Pike Rockville, MD 20852 Richard A. Ratliff Bureau of Radiation Control Texas Department of State Health Services 1100 West 4 9 th Street Austin, TX 78756-3189 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 289, Mail Code: MN116 Wadsworth, TX 77483 A. H. Gutterman, Esq.

Morgan, Lewis & Bockius LLP Mohan C. Thadani U.S. Nuclear Regulatory Commission Thad Hill Steve Winn Harry Holloway Eddy Daniels Marty Ryan NRG South Texas LP J. J. Nesrsta R. K. Temple Ed Alarcon Kevin Polio City Public Service C. Kirksey City of Austin Jon C. Wood Cox, Smith & Matthews

ENCLOSURE 1 EXEMPTION REQUEST STI: 32205487

ENCLOSURE 1 EXEMPTION REQUEST NOC-AE-0700221 0 Page 1 of 13 SOUTH TEXAS PROJECT UNITS 1 AND 2 I.

EXEMPTION REQUEST In accordance with the provisions of 10CFR 50.12, "Specific Exemptions," STP Nuclear Operating Company (STPNOC), acting on behalf of NRG South Texas LP (NRG South Texas),

the City Public Service Board of San Antonio (CPS) and the City of Austin, Texas (Austin Energy) (together, the "STP Owners"), requests that the Nuclear Regulatory Commission (NRC) grant an exemption from provisions of 10 CFR 50.82, 'Termination of License." Specifically, the STP Owners request an exemption from the requirements of 10 CFR 50.82(a)(8)(i) and (ii), to the extent required in order to permit the immediate withdrawal of funds from the nuclear decommissioning trust funds (NDTs) maintained by the STP Owners for South Texas Project Electric Generating Station, Units 1 and 2 (the "Facility" or "STP") to cover the cost of disposal of certain contaminated large components prior to the permanent cessation of operations.

The purpose of this exemption request is to permit the use of NDT funds, up to $20 million per unit, in order to pay for the prompt disposal of the following major radioactive components (MRCs): the reactor pressure vessel (RPV) heads to be removed from the Facility in 2009 and 2010 and the eight steam generators that were removed from Facility in 2000 and 2002.

Prompt disposal will result in several benefits, as follows: (1) the inventory of radioactive waste and associated source term at the site will be reduced; (2) the costs and inconveniences associated with maintaining the MRCs on-site will be avoided; (3) the overall cost to decommission the site will be reduced; (4) uncertainty regarding future disposal cost and capacity for these MRCs will be eliminated; and (5) assurance of adequate funds to decommission the reactors at the time the reactors cease operation will be maintained. Finally, assurance of the adequacy of the availability of funds for Facility decommissioning is supported by a site-specific decommissioning cost estimate and the associated'funding program.

Authorization of the use of NDT funds for prompt disposal of the MRCs is in the public interest, because it will immediately reduce on-site waste inventories, eliminate risks associated with future disposal, and reduce the eventual cost and complexity of decommissioning the Facility.

Consequently, authorization to expend NDT funds for prompt disposal of the MRCs would further the purpose of 10 CFR 50.82(a)(8), which is to provide reasonable assurance that the decommissioning trust funds will be adequate to accomplish their intended purpose.

Ih.

REQUIREMENTS The NRC regulations in 10 CFR 50.82(a)(8)(i) provide that decommissioning trust funds may be used by licensees if:

(A) The withdrawals are for expenses for legitimate decommissioning activities consistent with the definition of decommissioning in section 50.2; (B) The expenditure would not reduce the value of the decommissioning fund below an amount necessary to place and maintain the reactor in a safe storage condition if unforeseen conditions or expenses arise; and (C) The withdrawals would not inhibit the ability of the licensee to complete funding of any shortfalls in the decommissioning trust needed to ensure the availability of funds to ultimately release the site and terminate the license.

NRC has further conditioned the withdrawal of decommissioning trust funds by limiting the withdrawal rate from the trust. Section 50.82(a)(8)(ii) provides:

NOC-AE-0700221 0 Page 2 of 13 Initially, 3 percent of the generic amount specified in § 50.75 may be used for decommissioning planning. For licensees that have submitted the certifications required under § 50.82(a)(1) and commencing 90 days after the NRC has received the [post-shutdown decommissioning activities report] PSDAR, an additional 20 percent may be used.

A site-specific decommissioning cost estimate must be submitted to the NRC prior to the licensee using any funding in excess of these amounts.

Section 50.82 refers to the definition of "decommissioning" in section 50.2, which defines the term "decommission" rather than "decommissioning."

By that definition, the term "decommission" means:

to remove a facility or site safely from service and reduce residual radioactivity to a level that permits (1) release of the property for unrestricted use and termination of the license; or (2) release of the property under restricted conditions and termination of the license.

These provisions restrict the ability of the STP Owners to use NDT funds for the disposal of MRCs, even though removal of the MRCs would reduce the level of radioactivity at the STP site and would not adversely impact the ability to fund future decommissioning.

A request for an exemption from these requirements must satisfy the requirements of 10 CFR 50.12. As demonstrated below, this exemption request satisfies the provisions of section 50.12.

III.

BACKGROUND In the Statements of Consideration for the 1996 amendments to 10 CFR 50.82, NRC stated in response to a comment as follows:

The NRC has concluded that allowing decommissioning trust funds withdrawals for disposals by nuclear power plants that continue to operate is not warranted.

These activities are more appropriately considered operating activities and should be financed that way.

(61 FR 39278, 39293).

Consequently, licensees have been precluded from using decommissioning trust funds for prompt disposal of radioactive waste, including MRCs that are prematurely removed from service! and effectively "decommissioned." The estimated cost of disposal of MRCs is very substantial and is specifically addressed in plant-specific decommissioning cost estimates.

Unlike other waste routinely generated during normal plant operations, replacement of MRCs is not an anticipated operating activity, but rather these MRCs were originally expected to remain in service throughout the life of the plant.

As it has become necessary to replace MRCs, STPNOC has stored them on-site rather than expend funds from limited annual budgets to pay for near-term permanent disposal.

STPNOC understands that such on-site storage is a common practice in the industry, and that of the approximately 200 steam generators that have been removed or are planned to be removed from reactors in the United States, about 150 are stored on-site, or are planned to be stored, in specially constructed mausoleums.

Significantly, NRC's rules do not address the reality that MRCs need to be removed from service during plant operating life.

For example, the definition of "major decommissioning activities" in 10CFR50.2 includes removal of "major radioactive components," which specifically includes reactor vessels and steam generators.

In fact, 10CFR50.82(a)(5) contemplates that "major decommissioning activities," i.e., removal of MRCs, would not be performed by licensees until after permanent cessation of operations. This regulatory scheme NOC-AE-0700221 0 Page 3 of 13 implicitly acknowledges that removal and disposal of MRCs such as steam generators and RPV heads is not a routine operational activity, but rather is a decommissioning activity.

Further support for this conclusion is found in the 1996 rulemaking history where NRC stated that removal and disposal of some "large components" would be considered "routine operations," but specifically excluded from such routine operations the removal of any large components that fall within the definition of "major radioactive componenf' (61 FR 39286).

In fact, the response to comments made clear that a definition of "major radioactive component" was added for this very purpose, i.e., to distinguish the removal and disposal of certain equipment during normal operations from the removal of components such as steam generators and RPVs that would constitute "major decommissioning activity" per se.

STPNOC and the STP Owners have elected to improve plant operations and long term performance by replacing the specified MRCs with components made of improved materials.

The eight original steam generators were removed from the Facility in 2000 and 2002, and they are now stored on-site in a storage facility specifically constructed for that purpose. STPNOC estimates that its ongoing cost to maintain this storage facility is approximately $10,000 per year. Moreover, since the time when this storage facility was first planned and constructed, STPNOC has developed plans for the construction of two additional units at the STP site, and it is preparing an application for licenses to construct and operate those new units. The old steam generator storage facility is adjacent to the planned location of the new units, and occupies space that would otherwise be used for construction activities. For example, this land could be used as a convenient lay down area to support on-site construction activities.

There are significant advantages to disposing of the MRCs now rather than waiting until the cessation of operations and complete decommissioning of the plant. STPNOC is planning RPV head improvements to STP Units 1 and 2 that will result in the replacement of the existing RPV head from STP Unit 1 in a planned Fall 2009 outage and replacement of the existing RPV head from STP Unit 2 in a planned Spring 2010 outage. If the STP Owners are unable to use NDT funds to pay approximately $4.5 million for the near-term permanent disposal of these RPV heads, the STP Owners will instead use funds from the STP annual budget to plan, design and construct a new storage facility for the RPV heads, at a cost of approximately $1.4 million. This expenditure will not reduce the future cost of permanent disposal, but rather will simply defer the

$4.5 million expense until NDT funds can be accessed to pay for it. However, the $1.4 million for the RPV head mausoleum, as well as the eventual cost to then decommission it, could be avoided altogether if the STP Owners could access existing NDT funds to pay for permanent disposal upon their replacement.

Moreover, STPNOC has an opportunity to enter into favorable contractual arrangements for disposal of the existing steam generators, eliminating risks associated with future changes in disposal cost and/or availability of disposal capacity. The cost of disposal of the old steam generators was estimated to exceed $35 million in 2004, but STPNOC now projects that it can be accomplished in 2008 for less than $31 million.

In addition, prompt disposal will eliminate the need for ongoing maintenance of the existing storage facility, allowing its removal to make more room for construction activities. It also would reduce the on-site inventory of waste.

By using NDT funds to pay for prompt disposal, the STP Owners will be paying in current dollars to eliminate this future cost of decommissioning, and they will forgo future earnings on these funds. However, the loss of the benefit of future earnings is off-set by the elimination of future risk and uncertainty relating to the cost and availability of disposal capacity, as well as the benefits of eliminating the burdens associated with on-site storage and reducing the on-site NOC-AE-0700221 0 Page 4 of 13 inventory of waste. Moreover, the remaining funds and planned ratepayer contributions will be sufficient to fully decommission the site consistent with the activities planned in the site-specific estimate.

IV.

BASIS The permanent disposal of an MRC is a decommissioning activity, because such disposal involves the removal from service of a "major radioactive component," which is a large item of capital equipment.

However, the NRC definition of "decommission" implies that an entire reactor facility must be removed from service before related activities fall within NRC-sanctioned decommissioning (10 CFR 50.2).

Further, when the NRC promulgated the decommissioning rule in 1988, it noted in the Statements of Consideration to the final rule that "[d]ecommissioning activities are initiated when a licensee decides to terminate licensed activities" (53 FR 24,018, 24,019).

If this exemption is granted, the MRCs will be disposed by STPNOC during plant operation rather than waiting until the entire site is being decommissioned. The cost of disposal would be paid from NDT funds placed there for the purpose of disposing of just such components.

The MRCs at issue here have been or will be removed from service well in advance of the rest of the Facility. Absent this exemption, the MRCs would remain on-site until the facility ceases operation.

Accordingly, an exemption with respect to 10 CFR 50.82(a)(8)(i)(A) is needed because the Facility and site are not being removed from service, and therefore, payment for MRC disposal falls outside the definition "decommissioning activity" as the NRC Staff has interpreted 10 CFR 50.82(a)(8)(i)(A). It should be noted, however, that the regulations and this interpretation appear to be internally inconsistent, because 10 CFR 50.2 also provides that the permanent removal of "major radioactive components" is a "major decommissioning activity" and steam generators and RPVs are included as examples in the definition of "major radioactive component."

An exemption also is needed because section 50.82(a)(8)(ii) provides only for planning costs to be paid from decommissioning trust funds in advance of submittal of a PSDAR, implying that no other pre-PSDAR decommissioning costs are allowed.

The expenditures for which the exemptions are being requested are not planning activities.

Rather, they are necessary to remove the MRCs from the plant site and dispose of them, and the exemption request is to permit the funds necessary for that purpose to be withdrawn from the NDTs to fund current disposal activities irrespective of the 10 CFR 50.82(a)(8)(ii) restrictions.

A.

Facility Decommissioning Trust Fund

1.

Status of the Decommissioning Trust Fund The NDTs maintained by the STP Owners are currently very robustly funded and fully meet NRC's decommissioning financial assurance requirements.

As reflected in STPNOC's decommissioning funding status report dated March 27, 2007, and submitted to NRC in accordance with 10 CFR 50.75(f), the minimum decommissioning fund estimate required for the South Texas Project, Units 1 and 2 based on the NRC formula in 10CFR50.75 is approximately $365.5 million per unit. The reported NDT balances as of December 31, 2006 totaled $364.9 million for Unit 1 and $445.8 million for Unit 2, for a total of $810.7 million. Thus, with projected earnings taken into account as permitted by NRC's rules, the NDT balances already substantially exceed NRC minimum requirements and are sufficient to be considered fully "pre-paid" for purposes of compliance with 10 CFR 50.75(e)(1)(i).

Moreover, the STP Owners continue to make periodic contributions to their NDTs, and under Texas law, ongoing ratepayer contributions will be made so that decommissioning funding will NOC-AE-0700221 0 Page 5 of 13 be fully assured. The rates of collection are reviewed by the rate-setting authorities from time-to-time to assure that the rates of collections are adequate and appropriate to provide sufficient funds for decommissioning. These reviews are based on site-specific cost estimates that are maintained by the STP Owners, and regularly updated.

At current rates of collection and contribution, the annual amounts remaining to be collected total $220.2 million for Unit 1 and

$215.8 million for Unit 2, or $436 million.

Notably, the General Accounting Office (GAO) recently analyzed the adequacy of funds for each reactor site to address concerns about the adequacy of the amounts of decommissioning funds that various reactor licensees have and are collecting.

GAO concluded that 33 owners had accumulated fewer funds than needed and 20 owners were not contributing enough for them to meet their decommissioning fund goals. In the case of the South Texas Project, however, GAO found no such problem. STP's fund balances and contributions exceeded the benchmarks used by GAO by 50%.1

2.

Site-Specific Decommissioning Cost Estimate Is Comprehensive The NRC requires in 10CFR50.75(f)(2) that each licensee prepare and submit a Decommissioning Cost Estimate (DCE) at least five years prior to the projected end of operations. As noted above, however, even though operations are projected to continue for at least,20 years, the STP Owners already have a detailed DCE. The most recent DCE update, which was done in 2004, resulted in a total estimated cost, including spent fuel storage and Greenfield costs, of $1.419 billion: $642 million for Unit 1 and $777 million for Unit 2. Of this total cost, $1.026 billion is attributed to license termination with $501 million for Unit 1 and

$525 million for Unit 2. All costs are in 2004 dollars.

The current site-specific estimates reflect the significant industry experience with the conduct of decommissioning as of 2004. By that time, there were several commercial nuclear power plants undergoing decommissioning, including Maine Yankee, Connecticut Yankee, Yankee Rowe, Trojan, and Big Rock Point. These projects were building on the lessons learned from other completed decommissioning projects such as Elk River and Shippingport.

This experience included some generally acknowledged missteps made in the beginning stages of the current projects that led to additional costs beyond what had been projected. By 2004 these problems had been resolved, the projects were proceeding rapidly toward license termination, and the causes of the early-stage problems were well understood.

The STP cost estimates take into account the industry lessons learned. For example, the 2004 update includes an improved Greater than Class C (GTCC) segmentation analysis, reducing the assumed volume of this waste. It also assumes that the reactor vessel and reactor vessel internals would be removed by an outside contractor, which is consistent with current decommissioning practices.

The STP cost estimates take into account site-specific parameters that affect the total cost.

These parameters include site-specific equipment and material inventories, STPNOC staffing costs, projected spent fuel inventories, and site-specific spent fuel storage and shipping schedules. The end result is a site-specific decommissioning cost estimate in which STPNOC has a high degree of confidence.

Nuclear Regulation: NRC Needs More Effective Analysis to Ensure Accumulation of Funds to Decommission Nuclear Power Plants, GAO-04-032, at 34-35 (October 2003)

NOC-AE-0700221 0 Page 6 of 13

3.

The Site-Specific Decommissioning Cost Estimate Is Reliable As discussed above, the DCE contains a thorough and comprehensive analysis of the costs of decommissioning.

The reliability of current industry DCEs is demonstrated by recent decommissioning experience. Data for the three large PWRs that have been fully demolished (Connecticut Yankee, Maine Yankee, and Trojan) show that final decommissioning costs were less than projected in the DCE for two (Maine Yankee and Trojan) and 24% higher for one (Connecticut Yankee). Despite the Connecticut Yankee experience, a table top review of the data indicates that the DCEs are reliable planning tools. 2 Furthermore, the cause of the difference in the case of Connecticut Yankee is now well understood, as explained below.

Both Maine Yankee and Connecticut Yankee started the decommissioning process after an unplanned shutdown. Maine Yankee shut down in December of 1996 and made the decision to decommission in August of 1997. Maine Yankee decided on a Decommissioning Operations Contractor (DOC) approach, with a DOC selected in August of 1998, approximately 20 months after shutdown. Connecticut Yankee shut down in December of 1996 after the decision was made to decommission. Connecticut Yankee also elected to utilize a DOC approach, selecting a DOC in April 1999, more than two years after shutdown.

Connecticut Yankee experienced problems with the selected DOC, and terminated the contract in 2003. These management problems significantly increased the decommissioning costs, resulting in an actual cost some 24 percent higher than the Connecticut Yankee DCE. While management problems also could cause future decommissioning costs to be unnecessarily high, it is likely that such significant problems will be avoided.

The experience of Maine Yankee shows that the cost associated with the type of problems experienced by Connecticut Yankee can be adequately mitigated if they occur in future decommissioning projects.

Maine Yankee also had problems with its selected DOC and decided to terminate its contract. Maine Yankee, however, acted more quickly than Connecticut Yankee.

While Connecticut Yankee terminated its DOC contract four years after DOC selection, Maine Yankee did so after only two years. As a result, Maine Yankee was able to quickly return its decommissioning project to schedule and budget and complete decommissioning within the DCE.

The Maine Yankee experience shows that significant management problems can be overcome if promptly recognized and addressed.

The industry experience with decommissioning plants over the last decade contributes significantly to the reliability of current industry DCEs and provides a knowledge base that will result in more cost-efficient decommissioning in the future. Future decommissioning projects will be able to avoid mistakes and reduce costs through lessons-learned. Since the STP units have longer projected operating lives than most currently operating plants, it is likely to benefit from the decommissioning experiences of dozens of much older plants that will be decommissioned during the remaining operating lives of the STP units. The predictable result will be further lessons learned and opportunities for more efficiency.

4.

Decommissioning Trust Fund Addresses the Removal of the MRCs The existing STP decommissioning cost estimates include not only the radiological cleanup required by the NRC, but also the costs of dismantling the facilities and restoring the site as 2

Table Top Review - Decommissioning Costs for Power Reactors, CAF and Associates, April 2007.

NOC-AE-0700221 0 Page 7 of 13 closely as possible to its natural state.3 The estimate also includes funds intended for ultimate storage and monitoring of spent nuclear fuel remaining on-site following shutdown in the event the U.S. Department of Energy has not fulfilled its obligation to take custody of the spent fuel.

Further, the most recent cost estimate, on which current fund collections are based, specifically includes the cost of disposal of the old steam generators currently stored on-site.

The DCE line item cost to remove, pack, ship and dispose of the old steam generators is

$17.587 million for Unit 1 (2004 Cost Study, Appendix A, page 4 of 19, Table A-i, Line 27.'6) and $17.587 million for Unit 2 (2004 Cost Study, Appendix A, page 13 of 19, Table A-2, Line 27.6), in 2004 dollars. There is also a line item cost of $305,000 to remove the steam generator mausoleum (2004 Cost Study, Appendix A, page 18 of 19, Table A-2, Line 35.15), also in 2004 dollars.

Thus, the total cost for these activities was estimated (in 2004 dollars) to exceed

$35.5 million. In contrast, STPNOC now has the opportunity to complete these activities for less than $31 million (in 2008 dollars).

B.

Withdrawal of Funds Now From the Decommissioning Trust Fund Will Not Jeopardize STPNOC's Ability to Fully Decommission the Facility

1.

There Will Be Sufficient Funds Available To Decommission Facility As noted above, NDT balances for Units 1 and 2 reported for the end of 2006 were approximately $365 and $446 million, respectively.

If these balances were reduced by

$20 million from the NDTs for each Unit in order to fund MRC disposal activities, the remaining Unit 2 balance of $426 million would continue to exceed the NRC minimum "formula" amount of

$365.5 million. The Unit 1 balance of $345 million would exceed the NRC minimum, if earnings were taken into account for just three years assuming a 2 percent real rate of return as specified in 10 CFR 50.75(e)(1)(ii). With just three years worth of earnings, the Unit 1 NDT value would exceed $365.5 million. As such, even after the withdrawal of funds to pay for MRC disposal, the NDT balances are sufficient to be considered fully prepaid for purposes of meeting NRC's requirements to provide financial assurance for decommissioning, in accordance with 10 CFR 50.75(e)(1)(i) (prepayment method).

In addition to fully meeting NRC's requirements when the NDT balances are compared to the NRC "formula" amount for the STP units, the STP Owners continue to make annual contributions to the NDTs. In establishing the amounts of their annual contributions, the STP owners assess the NDT balances against not only the NRC minimum, but also against the site-specific decommissioning cost estimates for STP Units 1 and 2. When necessary, the need for adjustment to the rate of collections is reviewed with the rate-making authorities, such as the Public Utility Commission of Texas (PUCT).

The total 2004 site-specific estimates for Units 1 and 2 are $642.2 million and $777.3 million, respectively, including nearly $17.6 million in each estimate for the disposal of the old steam generators, and $0.3 million in the Unit 2 estimate for demolition of the mausoleum. If credit were taken for earnings assuming a 2 percent real rate of return for all NDT funds for 20 and 21 years respectively, based upon the end of 2006 balances reduced by $20 million each to pay for current disposal ($345 million and $426 million), the "value" of these current balances for Units 1 and 2 would exceed $510 million and $645 million, respectively. Taking into consideration the currently planned future contributions to each unit's funds of $220.2 and $215.8 million, respectively, there is clearly reasonable assurance that the NDTs will be sufficient to fund the Because the relevant orders by the State Commissions do not yet specifically allocate collections among the types of decommissioning costs, the funds for all decommissioning purposes currently are commingled in the trust, including those for NRC-jurisdictional radiological decommissioning.

NOC-AE-0700221 0 Page 8 of 13 decommissioning activities contemplated by the site-specific estimate, after the requested withdrawals of $20 million from each unit's NDTs are made over the next few years.

2.

The Withdrawal Will Not Reduce the Value of the Decommissioning Fund Below an Amount Necessary to Place and Maintain the Reactor in a Safe Storage Condition If Unforeseen Conditions or Expenses Arise The use of NDT funds for the requested purpose will not reduce the value of the NDTs below an amount necessary to place and maintain the reactors in a safe storage condition. As discussed in Section IV.B.1 above, the remaining NDT balances (after withdrawals of up to $20 million per unit were made) would continue to exceed the NRC minimum requirements for financial assurance for decommissioning.

Thus, the NDT balances would remain sufficient to be considered "fully funded" for purposes of compliance with NRC's rules.

Moreover, the STP Owners will continue to make annual contributions to the their NDTs, so that it is projected that the NDTs will be sufficient to fund the entire site-specific decommissioning cost estimate at the end of plant life, when the additional contributions and assumed earnings are taken into account.

Thus, even with the requested withdrawals, the STP Owners not only have sufficient funds to place and maintain the reactor in a safe storage. condition, but the STP Owners also have sufficient funds to complete the NRC-required radiological decommissioning based on its site-specific decommissioning cost estimate, as well as other planned decommissioning activities.

3.

Decommissioning Funding for STP Units 1 and 2 Is Assured Even in the Event of Any Shortfall in Available Funds The current status of NDT funding and program of continued contributions provide reasonable assurance that the NDT funds will continue to be adequate to fund decommissioning after the requested withdrawals are made. Even if this analysis were incorrect, NRC can further rely on the fact that the STP Owners will be able to obtain the funds necessary to complete decommissioning, even if there were a shortfall.

The STP Owners have the ability to collect additional funds from the ratepayers, if the NDT balances became inadequate. CPS and Austin Energy are governmental entities that have the ability to set rates and collect funds for decommissioning from their ratepayers. With respect to the legacy interests in STP Units 1 and 2 originally licensed to Houston Lighting & Power Company (30.8%) and Central Power and Light (25.2%), Texas law provides that CPS and NRG South Texas can seek collection of funds from Texas retail customers for the decommissioning liability for these interests pursuant to "cost of service" ratemaking. Section 39.205 of the Texas Utilities Code provides that, after January 1, 2002, costs associated with nuclear decommissioning obligations for the existing nuclear plants shall continue to be subject to cost-of-service rate regulation and will be included as a non-bypassable charge to retail customers.

4.

On October 6, 2004, the PUCT issued a final order adopting new Substantive Rule section 25.303. The new rule codifies the continuing responsibility of the electric transmission and distribution companies whose predecessors owned nuclear power plants prior to the restructuring of the Texas electricity industry, to collect funds necessary for the decommissioning of those facilities for the benefit of the transferee company.

The rule provides that the annual decommissioning costs must be stated as a separate non-bypassable charge in the individual transmission and distribution company's rates, and provides for the periodic adjustment of the non-bypassable charge based on the most current estimate of the costs of decommissioning the NOC-AE-0700221 0 Page 9 of 13 V.

JUSTIFICATION OF EXEMPTION AND SPECIAL CIRCUMSTANCES 10 CFR 50.12, "Specific Exemptions," states that the NRC may grant exemptions from the requirements of the regulations in 10 CFR Part 50 if three conditions are met.

The three conditions are: (1) the exemption is authorized by law; (2) the exemption will not present an undue risk to the public health and safety; and (3) the exemption is consistent with the common defense and security.

In addition, 10 CFR 50.12 provides that the NRC will not consider granting an exemption unless special circumstances are present.

A.

The Requested Exemption is Authorized by Law The NRC has the authority under the Atomic Energy Act to grant exemptions from its regulations if doing so would not violate the requirements of law. This exemption is authorized by law as is required by 10 CFR 50.12(a)(1). No law exists that precludes the activities covered by this exemption request. The provisions of 10 CFR 50.82 were adopted at the discretion of the Commission consistent with its statutory authority. No statute required the NRC to adopt the specific provisions from which STP seeks an exemption. Rather, the NRC may determine that alternative means are adequate to provide reasonable assurance of safety.

B.

The Requested Exemption Will Not Present an Undue Risk to the Public Health and Safety This exemption will not present an undue risk to the public health and safety. To the contrary, granting this exemption will result in increasing the protection to the public health and safety as multiple source terms will be removed from the site and properly disposed of decades in advance of the time the MRCs would be removed if they were stored on-site until the reactor ceases operation. This will provide for permanent disposal of the MRCs and eliminate any risk of future exposures from these sources at STP. Moreover, ample decommissioning funding assurance will continue to be provided after withdrawals are made to pay for the near-term MRC disposal activity.

C.

The Requested Exemption is Consistent with the Common Defense and Security This exemption is consistent with the common defense and security because the use of NDT funds to dispose of the MRCs will have no effect on the physical security of the site or the protection of special nuclear material from theft.

Moreover, to the extent that residual radioactivity in the MRCs maintained in storage represents any potential threat, near-term permanent disposal enhances security.

D.

Special Circumstances This exemption is justified based on five of the six special circumstances enumerated in 10 CFR 50.12(a)(2):

1.

Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule. (10 CFR 50.12(a)(2)(ii))

The underlying purpose of the rule is to provide assurance that there will be adequate funds for the ultimate decommissioning of the site.

The application of the regulation restricts the nuclear plant in question. Order Adopting New Section 25.303 as Approved at the September 30, 2004 Open Meeting, Project No. 29169 (October 6, 2004).

Thus, the PUCT has issued implementing regulations to provide for the ongoing funding of decommissioning by ratepayers as required under Texas law.

NOC-AE-0700221 0 Page 10 of 13 expenditure of decommissioning trust funds in this circumstance, which is unnecessary to achieve the underlying purpose of the rule. The purpose of the restrictions on fund withdrawal is to protect the heath and safety of the public by assuring that there will be adequate funds available to complete NRC-required decommissioning activities following termination of the operating license. The above analysis in Section IV of the site-specific decommissioning cost estimate and the status of the NDTs demonstrates that funding will be adequate to complete decommissioning even if funds are withdrawn for early disposal of the MRCs.

This conclusion is further supported by the fact that the NRC regulations recognize that a site-specific decommissioning cost estimate provides a reasonable basis for not restricting licensee expenditure of decommissioning funds. Under 10 CFR 50.82(a)(8)(ii), after a licensee ceases operations, its expenditure of decommissioning funds is restricted until it has submitted a site-specific decommissioning cost estimate. Once this cost estimate is provided to the NRC, a licensee may withdraw unlimited funds without obtaining prior NRC approval.

This interpretation of the regulation was specifically stated in the 1996 Statements of Consideration (61 FR 39285): ("Response. The NRC's intent in the proposed rule was not to use a formal approval mechanism for decommissioning expenditures once the licensee submits its site-specific decommissioning cost estimate. The final rule has been modified as suggested by the commenter."). Since STP's site-specific decommissioning cost estimate is being submitted with this exemption request, NRC has the information equivalent to that required by 10 CFR 50.82(a)(8)(ii).

The NRC's regulatory scheme relies in large part on the ability of licensees to effectively plan for

• and manage the decommissioning activity. The above discussion demonstrates that the STP

.Owners have an adequate basis upon which to make informed decisions regarding the effect and timing of activities and expenditure of funds. Further, it shows that they have a reasonable

,basis for determining that it is prudent from both a safety and economic sense to use NDT funds to dispose of these MRCs in the near-term, when permanent disposal can be accomplished on reasonable financial terms. In these circumstances, it is not necessary for NRC to prevent the licensees from exercising their sound business judgment regarding the timing of decommissioning expenditures.

2.

Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess of those incurred by others similarly situated. (10 CFR 50.12(a)(2)(iii))

Compliance with the restrictions on the use of NDT funds presents an undue hardship on the STP Owners, because they will have to fund the planning, design and construction of an additional RPV head mausoleum, as well as eventual decommissioning of the mausoleum, that could otherwise be avoided.

In addition, the STP Owners could avoid ongoing maintenance costs and other inconveniences from having to maintain storage facilities that would no longer need to exist, if the STP owners could use NDT funds to dispose of the MRCs. These are unnecessary regulatory burdens that were never contemplated when the regulation was adopted, because the rule never fully addressed the possibility of MRCs being removed during the operating life of the plant. For example, as discussed above in Section III, the definition of "major decommissioning activities" assumed to occur after permanent cessation of operations includes removal of MRCs.

STPNOC is planning on RPV head improvements to STP Units 1 and 2 that will result in the removal of the existing RPV head from STP Unit 1 in a planned Fall 2009 outage and removal of the existing RPV head from STP Unit 2 in a planned Spring 2010 outage. If the STP Owners NOC-AE-0700221 0 Page 11 of 13 are unable to use NDT funds to pay approximately $4.5 million for the near-term permanent disposal of these RPV heads, the STP Owners will instead budget from operating funds to plan, design and construct a new storage facility for the RPV heads, at costs which are projected to exceed $1.4 million. This expenditure will not reduce the future cost of permanent disposal, but rather will simply defer the $4.5 million expense until NDT funds can be accessed to pay for it.

In addition to the burden of constructing this new RPV head mausoleum, the STP Owners will be burdened with ongoing annual maintenance costs for this new facility and the existing steam generator mausoleum, the nuisance of having these facilities on-site, and ultimately the need to plan for and fund the future demolition and decommissioning of these storage facilities, which is estimated to exceed $400,000 in 2007 dollars for both mausoleums.

All of the costs associated with the new RPV head mausoleum would be avoided if NDT funds collected for the purpose of funding MRC disposal could be used to dispose the RPV heads in 2009 and 2010.

Moreover, additional costs and inconveniences associated with the steam generator mausoleum could also be avoided if NDT funds could be used for the near-term disposal of these MRCs. As noted above in section IV.B.1, use of NDT funds would not have an adverse impact of the ability to decommission the site to unrestricted use standards. In fact, plans and funding for future decommissioning would be enhanced by reducing future risks and uncertainties. Consequently, application of the rule without granting this exemption results in unnecessary and avoidable costs and burdens to the STP Owners and their ratepayers that were not anticipated when this rule was adopted.

3.

The exemption would result in benefit to the public health and safety that compensates for any decrease in safety that may result from the grant of the exemption. (10 CFR 50.12(a)(2)(iv))

While STPNOC clearly is capable of maintaining protection of the public health and safety if the MRCs are stored on-site, the exemption would result in benefit to the public health and safety, because removal of the MRCs would provide a permanent disposal solution. This eliminates any potential future risk associated with on-site storage, even if such risk is low. Furthermore, there is no associated decrease in safety. Thus, allowing the exemption will result in a net benefit to the public health and safety.

Prompt disposal of these MRCs furthers the objective of maintaining radiation exposures as low as reasonably achievable pursuant to 10 CFR 20.1101(b) by eliminating the potential for any future exposure from storing waste on-site.

In addition, disposing of waste prior to the permanent cessation of operations is consistent with NRC policy to minimize the costs and complexity of decommissioning, which can only improve safety.

4.

There is present any other material circumstance not considered when the regulation was adopted for which it would be in the public interest to grant an exemption. (10 CFR 50.12(a)(2)(vi))

As promulgated, the rule has never required that site-specific decommissioning cost estimates be developed during the operating life of the plant, but instead assumed that such estimates would be developed around the time a plant ceases operation. See 10 CFR 50.75(f)(2). In the absence of site-specific information, there may be an understandable preference for preserving funds in the NDTs, because it would be difficult to make informed decisions regarding the sequencing of decommissioning activities and expenses. However, where detailed information is available, NRC and the licensees have the ability to evaluate the cost and benefits of prompt disposal versus deferring expenditures.

This changed circumstance provides NRC with the ability to determine if there is reasonable assurance that sufficient funds will be available at the time of decommissioning if funds are withdrawn to cover the disposal costs for these MRCs.

NOC-AE-0700221 0 Page 12 of 13 The exemption request also satisfies the special circumstance criterion of 10 CFR 50.12(a)(2)(vi) in that, when this rule was adopted, the NRC did not consider that MRCs would be removed from the Facility long before permanent cessation of operation, and that the MRCs would be stored on-site because NDTs did not include sub-accounts to address disposal of large components.

NRC's rulemaking history makes clear that licensees may maintain sub-accounts in NDTs that might be used for purposes unrestricted by NRC, such as covering the disposal costs for MRCs.

In one example, American Electric Power Company set aside funds that were dedicated for disposal of steam generators from DC Cook. However, some state utility commissions do not favor the use of sub-accounts. In adopting the regulation, NRC anticipated that sub-accounts would be used to separate the funds collected for NRC-jurisdiction decommissioning from other decommissioning uses, and did not contemplate that funds collected for non-NRC decommissioning purposes would be commingled with the NRC-required decommissioning funds (61 FR 39285).

In this case, the funds for NRC-jurisdictional decommissioning and other decommissioning are commingled in the NDTs. NRC did not intend to prevent the use of those funds solely because they are commingled, and to do so would create an unnecessary regulatory burden as it does not have a corresponding safety benefit. This is especially true in the current situation where the adequacy of decommissioning funding can be assessed based upon a site-specific decommissioning cost estimate that sets out the costs for the different elements of decommissioning (including the disposal of MRCs) to determine whether there are adequate funds to fulfill NRC decommissioning requirements.

5.

Application of the regulation in the particular circumstances conflicts with other rules or requirements of the commission.

(10 CFR 50.12(a)(2)(i))

Application of the regulations in 10 CFR 50.82(a) is in conflict with the NRC philosophy favoring the timely disposition of nuclear waste, under circumstances where doing so is practicable. For example, materials licensees of the NRC are subject to the 1994 Decommission Timeliness Rule, 10 CFR 30.36, 40.42, 70.38, and 72.54, which requires those licensees to decontaminate and decommission certain unused portions of operating nuclear materials facilities. Allowing contaminated land, buildings or equipment to remain on-site was seen as a possible public and environmental liability, and the NRC looked for ways to achieve early decommissioning of unused portions of materials facilities. For valid and sound reasons, reactor licensees are not subject to this rule and, in fact, are allowed the SAFSTOR option under 10 CFR 50.82.

Nevertheless, NRC should look favorably upon efforts to pursue near-term permanent disposal of MRCs where justified.

Another example of NRC's preference for minimizing the on-site inventory of waste is reflected in 10 CFR 20.1406 which was added along with modifications to NRC's license termination rule in 1997 (62 FR 39058). This regulation provides:

Applicants for licenses, other than renewals, after August 20, 1997, shall describe in the application how facility design and procedures for operation will minimize, to the extent practicable, contamination of the facility and the environment, facilitate eventual decommissioning, and minimize to the extent practicable, the generation of radioactive waste.

The intent of 10 CFR 20.1406 is to diminish the occurrence and severity of site contamination by taking measures that will control contamination and facilitate eventual decommissioning.

Consistent with this philosophy, early removal of large components is consistent with NOC-AE-0700221 0 Page 13 of 13 10 CFR 20.1406. In contrast, storage of MRCs on-site until permanent cessation of operations will increase the complexity of decommissioning and volume of waste to be disposed at the end of plant life. Moreover, this complexity will be exacerbated by the inventory of MRCs stored on-site at multiple plants. Thus, permitting the phased disposal of large components over time will reduce the inventory of waste material and eliminate this future decommissioning activity, consistent with the philosophy underlying 10 CFR 20.1406.

Though not required to do so, reactor licensees should be permitted to utilize NDT funds to pay for the permanent disposal of MRCs prior to cessation of operations. This is justified where funds are being accumulated in NDTs and are available for this purpose, especially where early removal could take advantage of favorable disposal pricing. Unless the use of NDT funds is permitted, MRCs will likely remain on-site for additional decades, particularly given current trends towards license renewal.

Finally, delaying disposal introduces risks associated with potential changes in future disposal costs and availability of disposal capacity.

VI.

CONCLUSION Granting this exemption will be consistent with the NRC decommissioning regulations as it:

(1) would not foreclose release of the site for possible unrestricted use (in fact, it would enhance STPNOC's ability to achieve unrestricted release); (2) would not result. in significant environmental impacts not previously reviewed by the NRC; and (3) would not. undermine the existing and continuing reasonable assurance that adequate funds will be available for decommissioning.

Disposal of the MRCs would facilitate eventual unrestricted release of the Facility, thus improving environmental conditions.

In addition, authorizing prompt disposal would give STPNOC the ability to take advantage of cost effective disposal alternatives and thereby eliminate the uncertainty associated with the future cost and availability of disposal capacity. Prompt disposal of MRC source terms that otherwise would remain on-site until much later in time is prudent and consistent with the underlying purpose of the Commission's decommissioning regulations.

It is prudent and consistent with the underlying purpose of the Decommission Timeliness Rule to remove large component source terms that otherwise would remain on-site till much later in time.

In sum, it will facilitate the decommissioning process by removing the specified components from the site so that: (1) the inventory of radioactive waste and associated source term at the site will be reduced; (2) the costs and inconveniences associated with maintaining the MRCs on-site will be avoided; (3) the overall cost to decommission the site will be reduced; (4) uncertainty regarding future disposal cost and capacity for these MRCs will be eliminated; and (5) assurance of adequate funds to decommission the reactors at the time the reactors cease operation will be maintained.

Finally, assurance of the adequacy of the availability of funds for Facility decommissioning is supported by a site-specific decommissioning cost estimate and the associated funding program.

ENCLOSURE 2 DECOMMISSIONING COST UPDATE for the SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION May 2004

Document S30-1499-002, Rev. 0 DECOMMISSIONING COST UPDATE for the SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION prepared for STP Nuclear Operating Company prepared by TLG Services, Inc.

Bridgewater, Connecticut May 2004

South Texas Project Electric Generating Station Decommissioning Cost Update APPROVALS Document S30-1499-002, Rev. 0 Page ii of vi Project Manager Project Engineer Technical Manager Quality Assurance Manager (acting)

Geoffr'yýM. GrifAti~s Benjamin J. Stochmal William A. Cloutier Thomas S. La ardia, P.E.

Date S--' 2,4.6,ve Date Date Date TLG Services, Inc.

South Texas Project Electric Generating Station Document S30-1499-002, Rev. 0 Decommissioning Cost Update Page iii of vi TABLE OF CONTENTS PAGE DECOMMISSIONING COST STUDY LIMITED TECHNICAL AND ECONOMIC UPDATE........................................................................................

vi

1.

BASIS OF ESTIMATE UPDATE..................................................................

1 1.1 Spent Fuel Disposition...........................................................................

1 1.2 Utility, Doc and Security Staff................................................................

6 1.3 Waste Processing and Disposal Costs....................................................

7 1.4 N R C Fees..................................................................................................

8 1.5 Escalation of Other Costs......................................................................

9 1.6 Reactor Vessel Disposition Costs.........................................................

10 1.7 Project Schedule....................................................................................

11 1.8 Co-Ow ners Cost....................................................................................

12 1.9 Other Estimating Assumptions...........................................................

12

2.

R ESULTS................................................................................................................

13 TABLES 1.0 Spent Fuel Management Schedule - Ex-Core Fuel Assemblies.................. 14 2.0 Co-Owner Decommissioning Cost Allocations.............................................

15 3.1 Schedule of Annual Expenditures DECON Alternative - Unit 1................ 16 3.2 Schedule of Annual Expenditures DECON Alternative (Certain Spent Fuel-Related Costs) - Unit 1................................................

17 4.1 Schedule of Annual Expenditures DECON Alternative - Unit 2................ 18 4.2 Schedule of Annual Expenditures DECON Alternative (Certain Spent Fuel-Related Costs) - Unit 2................................................

19 A-1 South Texas Project - Unit 1, DECON, Decommissioning Cost E stim ate..................................................................................................

A -2 A-2 South Texas Project - Unit 2, DECON, Decommissioning Cost E stim ate............................................................................................

A -11 B-l.a Texas Genco, LP - Schedule of Annual Expenditures DECON A lternative-U nit 1...........................................................................................

B -2 B-l.b Texas Genco, LP - Schedule of Annual Expenditures DECON Alternative-U nit 2............................................................................

B-3 B-2.a AEP Texas Central Co. - Schedule of Annual Expenditures DECON A lternative-U nit 1...........................................................................................

B -4 TLG Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document 830-1499-002, Rev. 0 Page iv of vi TABLE OF CONTENTS (continued)

PAGE B-2.b AEP Texas Central Co. - Schedule of Annual Expenditures DECON A lternative-U nit 2...........................................................................................

B -5 B-3.a CPS - Schedule of Annual Expenditures DECON Alternative-Unit 1....... B-6 B-3.b CPS - Schedule of Annual Expenditures DECON Alternative-Unit 2......... B-7 B-4.a COA - Schedule of Annual Expenditures DECON Alternative-Unit 1........ B-8 B-4.b COA - Schedule of Annual Expenditures DECON Alternative-Unit 2........ B-9 FIGURES

1.

Tim eline of Events.......................................................................................

20 APPENDICES A.

Decommissioning Cost Estimates DECON Alternative..............................

A-1 B.

Co-Owner Schedule of Annual Expenditures DECON Alternative.......

B-1 TLG Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document S30-1499-002, Rev. 0 Page v of vi REVISION LOG Dat6 Ie F

N.... J No.

ItemRe!se*I[

i~oi**i

• or Revisi'n 0

5/26/2004 Original Issue TLG Services, Inc.

South Texas Project Electric Generating Station Document 830-1499-002, Rev. 0 Decommissioning Cost Update Page vi of vi DECOMMISSIONING COST STUDY LIMITED TECHNICAL AND ECONOMIC UPDATE This technical and economic update to the 1998 cost estimates prepared for decommissioning the South Texas Project Electric Generating Station (STPEGS or STP) incorporates changes in significant cost drivers that will impact the cost to decommission the station.

The work is being done in accordance with the requirements of South Texas Project Nuclear Operating Company's (STPNOC) contract B02948 and extrapolates from the conclusions of the 1998 decommissioning cost study prepared for STPEGS (TLG Document H01-1323-002, Rev. 2). [Although that report was issued in 1999, the results were reported in 1998 dollars. That report will be referred to as the 1998 analysis.] The re-visited and updated cost drivers include:

0 Spent Fuel Management and Strategy a

Program Management (includes Utility, Decommissioning Operations Contractor [DOC], and Security) 0 NRC Reactor and Independent Spent Fuel Storage Installation [ISFSI]

Fees Waste Processing and Disposal Reactor Vessel Disposition (includes Greater Than Class C (GTCC) disposal)

Energy General Inflation The basis for the update, as well as the results, are d escribed in the following narrative.

TLG Services, Inc.

South Texas Project Electric Generating Station Document S30-1499-002, Rev. 0 Decommissioning Cost Update Page 1 of 20

1. BASIS OF ESTIMATE UPDATE The cost estimate was developed by updating the economic inputs and spent fuel strategy from the decommissioning cost model used in preparing the 1998 STPEGS decommissioning cost study for the DECON scenario.

Based on the recommendations in that study, and in TLG's current best judgment, DECON remains the preferred funding alternative for planning purposes. This estimate included updating the expected initiation of U.S. Department of Energy (DOE) spent fuel acceptance and acceptance rates, and incorporating industry experience associated with loading and transferring multi-purpose spent fuel canisters. This estimate also incorporated updated utility, security, DOC, and engineering staff costs based on current salary values, and staffing levels consistent with TLG's current estimating model (which incorporates industry experience over the past 5 years). In addition, this estimate updated waste disposal and waste processing costs based on current unit costs, revised U.S. Nuclear Regulatory Commissioning (NRC) fee costs based on published cost recovery schedules, and escalated all other costs (excluding property taxes) based on a general inflation index used in the NRC's 10CFR50.75(c) minimum funding calculation criteria.

The basis and assumptions used for each of the updated cost drivers are identified in sub-sections 1.1 through 1.9.

1.1 SPENT FUEL DISPOSITION The cost to dispose of the spent fuel generated from plant operations is not reflected within the estimates to decommission STPEGS. Ultimate disposition of the spent fuel is under the DOE's Waste Management System, as defined by the NWPA. DOE Spent Fuel disposal is financed by a 1 millfkWhr surcharge paid into the DOE's waste fund during operations. However, the NRC requires licensees to establish a program to manage and provide funding for the management of all irradiated fuel at the reactor until title of the fuel is transferred to the Secretary of Energy. This funding requirement is fulfilled through inclusion of certain high-level waste cost elements within the estimates, as described below.

The spent fuel assemblies stored in the spent fuel pool and in dry storage at the site will be transferred to the DOE, in accordance with the existing contract.Operation of the DOE's yet-to-be constructed geologic repository is contingent upon the review and approval of the facility's license application by the NRC, the successful resolution of pending litigation, and the development of a national transportation system. By comparison, the NRC's review of the 7LG Services, Inc.

South Texas Project Electric Generating Station Document S30-1499-002, Rev. 0 Decommissioning Cost Update Page 2 of 20 application for an interim storage facility submitted by the Private Fuel Storage consortium began in 1997 and is still ongoing. With a more technically complex and politically sensitive application for permanent disposal, it is not unreasonable to expect that NRC approval to construct the repository at Yucca Mountain will require at least as long a review period. Construction would therefore begin sometime around the year 2010, at the earliest. The spent fuel management plan described in this section is predicated upon the DOE beginning pickup of commercial fuel in the year 2015.

This timetable is consistent with the findings of an evaluation recently issued to Congress by the Government Accounting Office in their report "Technical, Schedule, and Cost Uncertainties of the Yucca Mountain Repository Project," GAO-02-191, dated December 2001.

The total inventory of assemblies that will require handling during decommissioning and the timing of their removal is based upon several assumptions. DOE's removal of spent fuel from commercial reactors is projected to begin in 2015 as noted above. The rate at which spent fuel is removed from commercial reactors is based upon an annual capacity at the geologic repository that ramps up to 3,000 metric tonnes of uranium (MTU).

This acceptance rate is consistent with the rate specified in the "Analysis of the Total System Life Cycle Cost of the Civilian Radioactive Waste Management Program" (DOE/RW-0533) issued in May 2001. Any delay in the startup of the repository or decrease in the rate of acceptance will correspondingly prolong the transfer process and result in spent fuel remaining at the site longer.

DOE's contracts with commercial reactors allocates its capacity to accept spent fuel from commercial reactors based upon the date on which spent fuel was last removed from a reactor. The "oldest" fuel provides the utility with the highest priority for spent fuel removal.

Spent fuel acceptance schedules for each unit were developed by applying projected DOE-acceptance against total industry discharges. STPEG's first core discharge was in 1989. The total industry discharge at that time was 19,482 MTU. Therefore, based on the acceptance schedule (described above),

the first spent fuel would be picked up in year 10 of DOE's repository operations in 2024. STPEG's final core discharge is expected in 2029 based on the units' 40-year lifetimes. The total estimated industry discharge at this time is estimated to be approximately 91,000 MTU. This is a mid-case projection that assumes no new reactor startups, no early shutdowns and no life extensions of current operating U.S. plants. Therefore, based on the acceptance schedule, the last spent fuel would be picked up in year 33 of DOE's repository operations in 2047.

TLG Services, Inc.

South Texas Project Electric Generating Station Document 830-1499-002, Rev. 0 Decommissioning Cost Update Page 3 of20 Given the length of time during which STPEG will need to store spent fuel, it is reasonable to assume that the licensee will develop supplemental storage at the site at an ISFSI such that decommissioning can be completed in the shortest time practical.

Table 1 provides the spent fuel management schedule incorporated into the decommissioning estimates. The inventory levels (approximately 2025 and 2001 assemblies for Unites 1 and 2 respectively) represent the total number of fuel assemblies discharged from each unit, based on nominal projections fuel burnup over the units' 40-year lifetimes. ISFSI inventory is based upon fuel pool capacity and the projections for DOE removal of spent fuel noted above. The last core off-loads of spent fuel will be stored in the fuel storage pools for approximately five years after the cessation of plant operations. The five years is based upon the acceptance criterion for standard fuel as defined in the standard contract and the current design of dry storage systems.

Operation and maintenance costs for the ISFSI are included with the estimate. The estimate also addresses the cost for staffing the facility, as well as security, insurance and licensing fees. The estimates include the costs to load and transfer the fuel storage canisters, as well as the cost to construct the ISFSI itself. Costs are also provided for the final disposition of the facility once the transfer is complete. Other spent fuel caretaking costs include the costs for storage pool maintenance, security and associated operating expenses.

With the storage pools emptied, decommissioning operations can be concluded and the operating licenses terminated. Costs are included within the estimates to site, construct, and license an independent spent fuel storage facility, and for continued operation of this facility until the year 2047, when the DOE is expected to complete the transfer and acceptance of STP fuel. Expenditures include licensing, permits, engineering, site alterations, pad construction, cask transfer equipment and the purchase of storage canisters and concrete storage overpacks. Caretaking costs include staffing, insurance, and fees, as well as costs associated with the final disposition of the facility. The decommissioning cost for the ISFSI is identified as a separate line item cost in the cost table.

Canister Desian A multi-purpose storage canister, with a 24-fuel assembly capacity, is used for the storage of fuel at the ISFSI and in the transfer of spent fuel to the DOE.

An average cost of $800,000 is used for the cost of a multi-purpose canister and storage overpack. For fuel transferred directly from the pool to the DOE, the DOE is assumed to provide the canisters at no additional cost to the owners.

TLG Services, Inc.

South Texas Project Electric Generating Station Document 830-1499-002, Rev. 0 Decommissioning Cost Update Page 4 of 20 Canister Loading and Transfer An average cost of $200,000 is used for the labor and materials to load the spent fuel into the DOE transport cask. For estimating purposes, 50% of this cost is used to estimate the cost to transfer the fuel from the ISFSI to the DOE.

Since the costs for managing the ISFSI is assigned to Unit 2, all canister transfer costs incurred after the site restoration period have been allocated to Unit 2.

Operations and Maintenance An annual cost of approximately $997,000 and $70,000 is used for operation and maintenance (O&M) of the spent fuel pools (operating for 5 years after shutdown) and the ISFSI (operating approximately 20 years), respectively.

These O&M costs are exclusive of labor, which is included as a utility staffing or security staffing cost, and exclusive of nuclear liability and property insurance, property taxes, regulatory agency fees, and emergency planning fees, which are separately itemized costs.

Spent fuel pool O&M costs are allocated to each unit. Since the cost for managing the ISFSI is assigned to Unit 2 after the site restoration period, all ISFSI O&M costs have been allocated to Unit 2. However, it is beyond the scope of this update to distinguish precisely between costs resulting from the presence of spent fuel on the site from other costs that the licensee must incur to complete decommissioning.

Spent Fuel Pool Isolation A cost of $8.4 million is used to account for isolation of the spent fuel storage pools and fuel handling systems in Unit 1, such that decommissioning operations can commence on the balance of the plant. This cost is reduced to

$5.6 million for Unit 2, since the engineering, planning, and design work was already completed for Unit 1.

ISFSI Design Considerations A multi-purpose (storage and transport) dry shielded storage canister with a vertical, reinforced concrete storage overpack is used as a basis for the cost analyses. The overpacks are assumed to have some level of neutron-induced activation as a result of the long-term storage of the fuel, i.e., to levels exceeding free-release limits. The cost to dispose of this material, as well as the demolition of the ISFSI facility, is included in the estimate.

TLG Services, Inc.

South Texas Project Electric Generating Station Document S30-1499-002, Rev. 0 Decommissioning Cost Update Page 5 of 20 Nuclear Property and Liability Insurance Nuclear Property and Liability Insurance coverage requirements and premiums will be affected by the presence of spent nuclear fuel. This includes higher coverage for the first 18 months after unit shutdown, due to the potential risk of a zircaloy fire, as well as coverage while the ISFSI is in operation, after the physical decommissioning work has been completed. The insurance premiums (or allocated share of the premiums) associated with these periods have been assigned as a spent fuel cost. These costs are assigned to each of the units until site restoration is complete. Thereafter, consistent with the cost study allocations, these costs are assigned to Unit 2.

Security Staffing Security will be required due to both the presence of spent fuel, as well as the presence of large quantities-of radioactive materials. Security staff assigned to the decommissioning project is assumed to be absorbed by the license termination workforce, while there is substantial physical decommissioning work in progress.

The security staff after this period is assumed to be principally dedicated to ISFSI security, with the majority of the cost allocated as a spent fuel cost. However, it is beyond the scope of this update to distinguish precisely between costs resulting from the presence of spent fuel on the site from other costs that the licensee must incur to complete decommissioning. Consistent with the cost study allocations, spent fuel security costs are assigned to Unit 2.

Utility Staffin The utility staff will be required due to both the presence of spent fuel as well as to oversee and support the decommissioning work. While there is substantial physical decommissioning work in progress utility staff assigned to operate the spent fuel pools and ISFSI is assumed to be absorbed by the license termination workforce.

A fraction of utility staff after this time period is assumed to be dedicated to ISFSI operations, and is allocated as a spent fuel cost. However, it is beyond the scope of this update to distinguish precisely between costs resulting from the presence of spent fuel on the site from other costs that the licensee must incur to complete decommissioning. Consistent with cost study allocations, spent fuel utility staff costs are assigned to Unit 2.

TLG Services, Inc.

South Texas Project Electric Generating Station Document S30-1499-002, Rev. 0 Decommissioning Cost Update Page 6 of20 NRC and NRC ISFSI Fees The NRC requires an annual fee to be paid by reactor licensees in a decommissioning status.

This fee is applicable to a reactor in a decommissioning status with spent fuel on-site. This fee (identified as "NRC Fee" in the cost table) has been allocated as a license termination cost, until the reactor license has been terminated.

Thereafter, this cost has been allocated as a spent fuel cost (identified as "NRC ISFSI Fee" in the cost table).

These costs are assigned to each of the units until site restoration is complete.

Thereafter, consistent with the cost study allocations, these costs are assigned to Unit 2.

Property Taxes Throughout the decommissioning project, an annual property tax cost has been included. There is an annual property tax associated with the ISFSI, after all decommissioning and site restoration activities have been completed.

This annual tax has been allocated as a spent fuel cost in all years in which the ISFSI is in operation. The remaining property taxes are allocated to license termination or site restoration costs. These costs are assigned to each of the units until site restoration is complete. Thereafter, consistent with the cost study allocations, these costs are assigned to Unit 2.

Emergency Planning Fees Whenever spent fuel is present on site, an annual Emergency Planning fee has been included, and designated as a spent fuel cost. These costs are assigned to each of the units until site restoration is complete. Thereafter, consistent with the cost study allocations, these costs are assigned to Unit 2.

1.2 UTILITY, DOC AND SECURITY STAFF The staff required to support and manage a decommissioning project represents a significant project cost. In order to reflect changes from 1998 to 2004, both labor costs as well as numbers of individuals assigned to the project were updated. Labor costs based on STPEGS representative salary levels were incorporated into the model.

In addition, staffing levels were adjusted to reflect experience from ongoing U.S. power reactor decommissioning projects.

Based on information obtained from STPNOC, overhead rates remained constant (average rate is 50% of salary).

The following table reflects the results of the cost estimate update:

TLG Services, Inc.

South Texas Project Electric Generating Station Document S30-1499-002, Rev. 0 Decommissioning Cost Update Page 7 of 20 CHANGE IN UTILITY, DOC, CONSULTING ENGINEERING, AND SECURITY OFFICER SALARIES AND MAN-HOURS Change 1998 2004

(%)

Average Annual "Utility" Salary (including all A&G and overheads)

(dollars) 87,000 116,000 33.3 Average Annual "DOC" Salary (including all overheads and profit) (dollars) 99,000 130,000 31.3 Average Annual "Consulting Engineering" Salary (including all 208,000 189,000

<9.1>

overheads, per diemns and profit)

(dollars)

Average Annual Security Officer Salary*

31,000 50,000 61.3 (including all overheads and profit)

(dollars)

Total Utility Staff (Man-Hours) 3,805,000 4,129,000 8.5 Total DOC Staff (Man-Hours) 1,387,000 1,806,000 30.2 Total Consulting Engineering Staff (Man-158,546 158,546 0.0 Hours)

Total Security Staff (Man-Hours) 966,000 1,006,000 4.1 The average security salary in the 1998 study did not include a 40% overhead, therefore the cost differential is unusually high.

The staffing levels were generally not affected by the project schedule, since the license termination and completion of spent fuel pickup did not change between the 1998 and 2004 cost estimates.

1.3 WASTE PROCESSING AND DISPOSAL COSTS Decommissioning a nuclear power station generates a substantial amount of radioactive waste, which results in a substantial decommissioning cost. The quantity of waste generated from the decommissioning project was assumed to be unchanged since the 1998 study, however, the cost of waste processing and disposal was updated to incorporate the latest rate schedules. Based on STPNOC provided waste schedules, the following is a summary of the TLG Services, Inc.

South Texas Project Electric Generating Station Document S30-1499-002, Rev. 0 Decommissioning Cost Update Page 8 of 20 changes in the waste processing and disposal costs between the 1998 and 2004 study.

CHANGE IN WASTE PROCESSING AND DISPOSAL COSTS Change 1998 2004

(%)

Direct Disposal of Low-Level Radioactive Waste ($'s/Ilb) 4.40 5.10 15.9 Processing of Contaminated Metallic Waste ($'s/ lb) 1.40 2.00 42.9 Disposal of Dry Active Waste (DAW) (paper, cloth and similar consurnables)*($'s/ lb) 4.40 3.25

<26.1>

Disposal of Bulk Debris (such as contaminated 4.40 0.45

<89.8>

concrete)* ($'s/ Ib)

Disposal of Greater-Than-17,800 22,100 24.2 Class-C Waste ** ($'sI ft3)

Direct disposal of low-level waste was used for disposal of DAW and bulk debris in the 1998 study.

• • The contingency value assigned to GTCC waste was reduced from 50% to 15% in this update.

This reflects TLG's current practice of classifying this cost as a "Government Service" rather than as a highly activated component disposal cost. With adjustments for contingency the change is <5.1%>.

1.4 NRC FEES The NRC recovers a large fraction of its operating budget through a cost recovery program. The fees for cost recovery are published in the Code of Federal Regulations, and are updated on a regular basis. The number of NRC staff man-hours charged to the project was assumed to be unchanged since the 1998 study, however, the hourly cost and annual fees were updated to incorporate the latest rate schedules. Based on schedules extracted from the Code of Federal regulations, the following is a summary of the changes in NRC hourly rates and annual fees.

TLG Services, Inc.

South Texas Project Electric Generating Station Document S30-1499-002, Rev. 0 Decommissioning Cost Update Page 9 of 20 CHANGE IN NRC FEES Change 1998 2004

(%)

NRC Annual Fee (Power Reactor with Fuel On-Site in Decommissioning Status) (per unit) ($'s/yr) 150,000 319,000 212.7 NRC Annual ISFSI Fee* (per site)

($'s/yr) 283,000 319,000 12.7 Average Cost Per Professional Staff Hour ($'slhr) 131 156 19.1 The current study, consistent with current NRC regulations, only includes the Annual ISFSI Fee after the reactor license has been terminated. In the 1998 study the ISFSI Fee was applied for the entire duration of the project.

1.5 ESCALATION OF OTHER COSTS In order to account for escalation of costs between 1998 and 2004, costs that were not updated based on specific 2004 cost values, were escalated using Bureau of Labor Statistics (BLS) indices, produced by the U.S. Department of Labor.

The index chosen (for all items not updated based on specific 2004 values, excluding energy), is "Employment Cost Index, Total Compensation, Private Industry, South Region" (ecul3202i). This was selected since it is used in NRC's minimum funding formula for escalating labor, equipment and materials as described in NRC's NUREG/CR-1307, Volume 10 - "Report on Waste Burial Charges".

Since the BLS does not forecast inflation, the 2004 index has not been published. Therefore TLG determined the average annual increase between 1997 and 2003, and applied this increase to represent the change between 1998 and 2004.

The average annual rate of change was calculated at 3.34%, resulting in an increase of 21.8% over the 6 year period.

The index chosen for energy is "Producer Price Index, Fuels and Related Products and Power, Industrial Electric Power" (wpu0543). This was selected since it is used in NRC's minimum funding formula for escalating energy as described in NUREG/CR-1307, Volume 10. Similar to what was done with the employment cost index, TLG determined the average annual increase between 1997 and 2003 and applied this increase to represent the change between 1998 TLG Services, Inc.

South Texas Project Electric Generating Station Document S30-1499-002, Rev. 0 Decommissioning Cost Update Page 10 of 20 and 2004.

The average annual rate of change was calculated at 1.86%,

resulting in an increase of 11.7% over the 6 year period.

It should be noted that property taxes were not escalated in this cost update (at the direction of STPNOC).

1.6 REACTOR VESSEL DISPOSITION COSTS The reactor vessel and internals disposition calculations were revised to incorporate current TLG methods used for estimating reactor vessel disposition costs and updated Andrews County, Texas waste facility disposal costs.

Revisions to TLG methods include the following significant elements:

" Incorporated the current lifetime operations history (megawatt-hours to date), and assumed there is an increased capacity factor over the remainder of plant life (90% v. 80% in the previous study). These changes affect the neutron activation levels, which affects the curie content at time of shutdown, and affects the cost of GTCC disposal (estimated cost of GTCC disposal is tied to the cost of disposal of spent fuel).

" A revised approach to calculating the packaged volume of GTCC material.

The updated approach reduces the total packaged volume of GTCC material.

" A revised contingency is applied to the disposal of GTCC material (15% v.

50% in the previous study). This is intended to reflect that the waste will be transferred to the DOE, and therefore the cost is related to a government service.

" The cost for disposal of GTCC material has been assigned to the last year of the spent fuel pickup (2047). This does not affect cost in current year dollars, but will affect present value cost calculations.

" A revised approach to the packaging of lightly-activated material (current approach is to assume that much of the lightly-activated material is now packaged in B-25 boxes, rather than cask liners).

• The segmentation and packaging crew's cost structure was changed to reflect the use of outside contractors to do the reactor vessel segmentation and packaging, rather than the on-site work force (this is the current U.S.

industry practice)

" Material costs were updated with new vendor information, or escalated from the last study.

TLG Services, Inc.

South Texas Project Electric Generating Station Document S30-1499-002, Rev. 0 Decommissioning Cost Update Page 11 of 20 1.7 PROJECT SCHEDULE Despite a later estimated start date of DOE.spent fuel acceptance, increases in the estimated rate at which spent fuel is accepted by the DOE resulted in the project schedule remaining essentially unchanged from the 1998 study (spent fuel is estimated to be picked up by the end of third quarter in 2047 in this study, versus the middle of 2048 in the 1998 study. A timeline of events is provided in Figure 1.

Significant milestone dates in the decommissioning estimate are noted in the following table.

SIGNIFICANT MILESTONES MILESTONE EVENT DATE DOE initiates spent fuel pickup (commercial reactors) 2015 Unit 1 - DOE initiates spent fuel pickup 2024 Unit 2 - DOE initiates spent fuel pickup 2025 Unit 1 - Permanent Cessation of Operations 2027 Unit 2 - Permanent Cessation of Operations 2028 Unit 1 - Initiate Spent Fuel Transfer to ISFSI 2028 Unit 2 - Initiate Spent Fuel Transfer to ISFSI 2029 Unit 1 - Spent Fuel Pool Empty (5 years - 2 months after 2032 shutdown)

Unit 2 - Spent Fuel Pool Empty (5 years - 2 months after 2034 shutdown)

ISFSI - Initiate Fuel Transfer from ISFSI to DOE 2033 Unit 1 - Reactor License Terminated 2034 Unit 2 - Reactor License Terminated 2036 Unit 1 - Site Restoration Complete 2037 Unit 2 - Site Restoration Complete 2037 ISFSI - Transfer GTCC stored in ISFSI to DOE 2047 ISFSI - Complete Fuel Transfer from ISFSI to DOE 2047 TLG Services, Inc.

South Texas Project Electric Generating Station Document S30-1499-002, Rev. 0 Decommissioning Cost Update Page 12 of 20 1.8 CO-OWNERS COST An objective of this update was to estimate the co-owners Schedule of Annual expenditures, considering ownership allocations, contingency values at 10%,

and tax exemption considerations. The "average reduction" between the base case estimate, and each owner's cost developed in the 1998 analysis was calculated and applied to the updated cost estimate (2004 dollars).

For clarification, these values, and the corresponding reductions, are as shown in Table 2. The new base case schedule of annual expenditures was developed by reducing the base case by these average reduction values.

1.9 OTHER ESTIMATING ASSUMPTIONS With the exceptions of the items described above, the estimate relied on the assumptions developed for the 1998 decommissioning cost study (TLG document H01-1323-002, Rev. 2, dated December 1998).

This includes elements such as, plant equipment and structures inventories, scope of work (what is included as a decommissioning activity), contamination levels, energy consumption, unit cost factors (worker productivity), and project contingencies.

A complete definition of assumptions is contained in sections 1 through 5 of the 1998 study.

TLG Services, Inc.

South Texas Project Electric Generating Station Document S30-1499-002, Rev. 0 Decommissioning Cost Update Page 13 of20

2. RESULTS The costs based on this technical and economic update are provided in Appendix A, Tables A-1 and A-2. These tables provide the same types of information that were provided in Tables C-1 and C-2 of the 1998 study. The total cost to decommission the station with the updated assumptions is

$1,419,448,073; or an increase/decrease of 287,699,387 (25.4%).

The estimated annual schedules of expenditure based on this estimate are provided in Tables 3.1 and 4.1. These tables provide the same information that was provided in Table 3.3 and 3.4 of the 1998 study. In addition estimated annual schedules of expenditures related to managing spent fuel are provided in Tables 3.2 and 4.2. The basis for spent fuel management costs are explained in Section 1, and are itemized in Tables A-1 and A-2 (refer to the column labeled "Spent Fuel Mgmt.")

In order to establish owner-specific disbursements, based on ownership allocations, previously specified contingency values, and tax exemption considerations, a schedule of annual expenditures has been developed for each owner, by unit. These schedules are provided in Appendix B, Tables B-1 through B-4. Consistent with the 1998 study these tables represent the following:

" Expenditure schedules for Texas Genco, LP and AEP Texas Central Company include state sales tax and property tax allocations, as applicable, the schedules for CPS and COA, the two municipal owners, do not.

" Expenditure schedules are based on a flat contingency rate of 10%.

• The ownership share remains unchanged from the 1998 study (refer to Table 2).

TLG Services, Inc.

South Texas Project Electric Generating Station Document Decommissioning Cost Update TABLE 1.0 SPENT FUEL MANAGEMENT SCHEDULE EX-CORE FUEL ASSEMBLIES*

Unit 1 S30-1499-002, Rev. 0 Page 14 of 20 Unit 2 On-Site Year Inventory ISFSI Inventory (assemblies) (canisters)

DOE Acceptance On-Site ISFSI Inventory DOE Acceptance Inventory (assemblies) (canisters) 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 1,669 1,582 1,571 1,677 1,590 1,503 1,416 1,329 1,242 1,155 1,068 981 894 807 720 633 546 459 372 285 198 111 24 0

0 0

0 0

240 480 744 984 1,242 1,155 1,068 981 894 807 720 633 546 459 372 285 198 111 24 0

0 0

0 0

10 20 31 41 52 49 45 41 38 34 30 27 23 20 16 12 9

5 1

0 87 87 87 87 87 87 87 87 87 87 87 87 87 87 87 87 87 87 87 87 87 87 87 24 1,660 1,649 1,634 1,547 1,653 1,566 1,479 1,392 1,305 1,218 1,131 1,044 957 870 783 696 609 522 435 348 261 174 87 0

0 0

0 0

0 240 480 720 960 1218 1131 1044 957 870 783 696 609 522 435 348 261 174 87 0

0 0

0 0

0 10 20 30 40 51 48 44 40 37 33 29 26 22 19 15 11 8

4 0

0 87 87 87 87 87 87 87 87 87 87 87 87 87 87 87 87 87 87 87 87 87 87 87 Total 2,025 2,001

• Inventories are approximate and reflect projected/estimated quantities TLG Services, Inc.

South Texas Project Electric Generating Station Document 830-1499-002, Rev. 0 Decommissioning Cost Update Page 15 of 20 TABLE 2.0 CO-OWNER DECOMMISSIONING COST ALLOCATIONS Unit 1 (Note 1)

Unit 2 (Note 2)

Base Case Costs (1998 dollars) 515,465,630 616,283,056 Texas Genco, LP (formerly HL&P)

Owner AEP Texas Central Co.

(formerly CP&L)

CPS COA Percent Ownership (Note 3)

Decommissioning Cost (allocated) (1998 dollars) (10%

contingency) - Unit 1 (Note 4)

Decommissioning Cost (allocated) (1998 dollars) (10%

contingency)- Unit 2 (Note 5)

Average Reduction (Base Case to Allocated Share) -

Unit 1 (Note 6)

Average Reduction (Base Case to Allocated Share) -

Unit 2 (Note 6) 30.8%

152,863,835 184,080,980 25.2%

125,070,411 150,611,711 28.0%

126,204,595 151,278,943

.2448

.2455 16.0%

72,116,911 86,445,110

.1399

.1403

.2966

.2987

.2426

.2444 Note 1:

Note 2:

Note 3:

Note 4:

Note 5:

Note 6:

Refer to Appendix C-1 of 1998 TLG report Refer to Appendix C-2 of 1998 TLG report Refer to Appendix E of 1998 TLG report Refer to Appendix E, Tables E-1, E-3, E-5 and E-7 of 1998 TLG report Refer to Appendix E, Tables E-2, E-4, E-6 and E-8 of 1998 TLG report Calculated by ratio of Owner's Cost to Base Case Cost TLG Services, Inc.

South Texas Project Electric Generating Station Document S30-1499-002, Rev. 0 Decommissioning Cost Update Page 16 of 20 TABLE 3.1 SCHEDULE OF ANNUAL EXPENDITURES DECON Alternative - Unit 1 (2004 Dollars)

Period 3 Period 1 Year Planning Period 2 Decommissioning Site Restoration Offset Site Restoration Total 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 40,009,022 113,943,089 14,993,215 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

91,265,205 9.5,153,173 79,081,192 76,963,622 63,503,463 7,008,629 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

835,794 2,674,366 65,430 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0O 0

0 0

0 0

21,114,597 17,799,013 0

0 0

0 0

0 0

0 0

17,741,317 0

40,009,022 113,943,089 106,258,420 95,153,173 79,081,192 76,963,622 63,503,463 7,844,424 2,674,366 21,180,027 17,799,013 0

0 0

0 0

0 0

0 0

17,741,317 0

168,945,326 412,975,284 3,575,590 56,654,926 642,151,127 TLG Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document S30-1499-002, Rev. 0 Page 17 of20 TABLE 3.2 SCHEDULE OF ANNUAL EXPENDITURES DECON Alternative (Certain Spent Fuel-Related Costs') - Unit 1 (2004 Dollars)

Period 1 Period 2 Year Planning Decommissioning Period 3 Site Restoration RE Offset Site

• storation Total 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 13,342,759 33,070,745 4,256,930 16,738,056 13,848,765 5,044,110 4,242,662 862,290 688,345 13,342,759 33,070,745 20,994,986 13,848,765 5,044,110 4,242,662 862,290 1,056,054 1,176,593 1,204,430 991,035 367,710 1,176,593 28,786 1,175,644 991,035 50,670,434 41,424,227 1,573,089 2,166,679 95,834,429 Note 1: Although some spent fuel management costs are reflected here, it is beyond the scope of this study to distinguish precisely between costs resulting from the presence of spent fuel on the site and other costs that the licensee must incur to complete decommissioning.

TLG Services, Inc.

South Texas Project Electric Generating Station Document 830-1499-002, Rev. 0 Decommissioning Cost Update Page 18 of 20 TABLE 4.1 SCHEDULE OF ANNUAL EXPENDITURES DECON Alternative - Unit 2 (2004 Dollars)

Post Decommissioning Period 1 Year Planning Period 2 D&D Site Restoration ISFSI Operations Spent Fuel ISFSI Transfer D&D Total 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 4,394,183 89,685,306 38,994,842 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

71,392,645 104,160,906 93,625,142 90,772,043 79,646,821 34,031,434 424,836 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

50,568,116 42,627,504 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

755,284 4,307,480 4,307,480 4,319,281 4,307,480 4,307,480 4,307,480 4,319,281 4,307,480 4,307,480 20,951,274 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

10,689,696 5,785,991 0

4,394,183 89,685,306 110,387,487 104,160,906 93,625,142 90,772,043 79,646,821 34,031,434 50,992,952 43,382,788 4,307,480 4,307,480 4,319,281 4,307,480 4,307,480 4,307,480 4,319,281 4,307,480 4,307,480 31,640,970 5,785,991 0

133,074,330 474,053,828 93,195,620 60,497,481 16,475,687 777,296,946 TLG Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document S30-1499-002, Rev. 0 Page 19 of 20 TABLE 4.2 SCHEDULE OF ANNUAL EXPENDITURES DECON Alternative (Certain Spent Fuel-Related Costs') - Unit 2 (2004 Dollars)

Post Decommissioning Period 1 Year Planning Period 2 D&D Site Restoration ISFSI Operations Spent Fuel ISFSI Transfer D&D Total 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 1,466,299 23,361,411 7,550,303 23,801,499 16,800,152 7,406,180 5,120,152 2,697,964 2,894,415 75,852 3,207,957 2,704,218 755,284 4,307,480 4,307,480 4,319,281 4,307,480 4,307,480 4,307,480 4,319,281 4,307,480 4,307,480 3,209,958 1,466,299 23,361,411 31,351,802 16,800,152 7,406,180 5,120,152 2,697,964 2,894,415 3,283,810 3,459,502 4,307,480 4,307,480 4,319,281 4,307,480 4,307,480 4,307,480 4,319,281 4,307,480 4,307,480 13,899,653 5,785,991 10,689,696 5,785,991 32,378,014 58,796,214 5,912,175 42,756,164 16,475,687 156,318,253 Note 1: Although some spent fuel management costs are reflected here, it is beyond the scope of this study to distinguish precisely between costs resulting from the presence of spent fuel on the site and other costs that the licensee must incur to complete decommissioning.

TLG Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update FIGURE 1 TIMELINE OF EVENTS Document S30-1499-002, Rev. 0 Page 20 of 20 Unit 1 (Shutdown August 20, 2027)

Period 1 Transition and Preparations Period 2 Decommissioning Period 3 Site Restoration 08/2027 02/2029 09/2034 10/2037 Storage Pool Empty 10/2032 02/2028 09/2047 L

~Spent Fuel in Dry Fuel StorageJ Unit 2 (Shutdown December 15, 2028)

I Period 1 Period 3 Transition and Period 2 Site ISFSI Preparations Decommissioning I RP..Qtnrqinn Operations ISFSI 12/2028 06/2030 01/2036 10/2037 09/2047 03/2048 Storage Pool Empty 02/2034 TLG Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document S30-1499-002, Rev. 0 Appendix A, Page I of 19 APPENDIX A DECOMMISSIONING COST ESTIMATES DECON Alternative Page South Texas Project, U nit 1........................................................................................

A-2 South Texas Project, Unit 2...............................................................................

A-11 TLG Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document S30-1499-002, Rev. 0 Appendix A, Page 2 of 19 TABLE A-1 SOUTH TEXAS PROJECT - UNIT I DECON, DECOMMISSIONING COST ESTIMATE (Thousands of 2004 Dollars)

Columns may not add due to rounding

• )

NRC Spent Site LLW site GTCC Craft Laborl"

Nwnbe, Activity Description Decon Remove Pack Ship Burial Other Contingency Total LicTerm Fuel Mt. Restore A CF B CF C CF CF Hours PERIOD I I Prepare preliminary decommissioning cost 2 Notification of Cessation of Operations 3 Remove fuel & source material 4 Notification of Permanent Defueling 5 Deactivate plant systems & process waste 6 Prepare and submit PSDAR 7 Review plant dwgs & specs.

8 Perform detailed red survey 9 Estimate by-product Inventory 10 End product description 11 Detailed by-product inventory 12 Define major work sequence 13 Perform SER and EA 14 Perform Site-Specific Cost Study 15 Prepare/submit Ucense Termination Plan 16 Receive NRC approval of termination plan Activity Specifications 17.1 Plant & temporary facilities 17.2 Plant systems 17.3 NSSS Decontamination Flush 17.4 Reactor Internals 17.5 Reactor vessel 17.6 Biological shield 17.7 Steam generators 17.8 Reinforced concrete 17.9 Turbine & condenser 17.10 Plant structures & buildings 17.11 Waste management 17.12 Facility & site ctoseout 17 Total Planning & Site Preparations 18 Prepare dismantling sequence 19 Plant prep. & temp. svces 20 Design water clean-up system 21 Rigging/CCEs/tooling/stc.

22 Procure casksliners & containers 118 17.7 181 27.2 417 62.5 91 13.6 91 13.6 118 17.7 680 102.0 281 42.1 453 68.0 371 55.7 135 135 Note 1 Note 2 Note I Note 1 208 208 479 479 Note 1 104 104 104 104 135 135 782 782 323 323 521 521 427 427 Note 1 446 66.9 378 56.6 45 6.8 643 96.5 589

" 88.4 45 6.8 283 42.4 145 21.8 73 10.9 283 42.4 417 62.5 82 12.2 3,428 514.3 218 32.6 2308 346.2 127 19.0 1,954 293.1 111 16.7 513 434 62 740 677 52 325 167 83 325 479 94 3.943 462 391 52 740 677 52 325 83 163 479 47 3,472 51 43 83 83 163 47 471 250 250 2,654 2,654 146 146 2.247 2,247 128 128 TLA Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Docutent S3-1499-002, Rev. 0 Appendix A, Page 3 of 19 TABLE A-1 SOUTH TEXAS PROJECT - UNIT 1 DECON, DECOMMISSIONING COST ESTIMATE (Thousands of 2004 Dollars)

Columns may not add due to rounding ID NRC Spent Site LLW site GTCC Craft Laborl Numbeu Activity Description Decon Remove Pack Ship Burial Other -

Contingency Total LicTerm Fuel Mit.

Restore A CF B CF C CF CF Hours Detailed Work Procedures 23.1 Plant systems 23.2 NSSS Decontamination Flush 23.3 Vessel head 23.4 Reactor Internals 23.5 Remaining buildings 23.6 CRD cooling assembly 23.7 CRD housings & ICI tubes 23.8 Incore instrumentation 23.9 Reactor vessel 23.10 Facility closeout 23.11 Missile shields 23.12 Biological shield 23.13 Steam generators 23.14 Reinforced concrete 23.15 Turbine & condensers 23.16 Auxiliary building 23.17 Reactor building 23 Total 24 Devon primary loop Period I Additional Costs 25 Site Characterization Survey 26 Severance Plan Subtotal Period 1 Activity Costs Period I Undlitrlbuted Costs 1 Decon equipment 2 Deson supplies 3 DOC staff relocation expenses 4 Process liquid waste 5 Insurance 6 Property taxes 7 Health physics supplies 8 Heavy equipment rental 9 Small tool allowance 10 Disposal of DAW generated 11 Plant energy budget 12 ISFSI Cask Purchase 429 64.3 493 444 49 91 13.6 104 104 227 34.0 261 261 227 34.0 261 261 122 18.4 141 35 106 91 13.6 104 104 91 13.6 104 104 91 13.6 104 104 329 49.3 378 378 109 16.3 125 63 63 41 6.1 47 47 109 16.3 125 125 417 62.5 479 479 91 13.6 104 52 52 283 42.4 325 325 247 37.1 285 256 28 247 37.1 285 256 28 3.239 486 3,725 3,074 652 493.6 1480.8 1480.8 987 987 656 40 149 1,692 21,404 508 2,200 2,200 3.211 24,615 24,615 800 800 37,282 6.340 44,609 43,486 1,123 1,192 249 274 0

543 330 545 12 3,030 1,114 1,715 6,206 3.395 23,200 98 754 754 10 49 49 179 1,371 1,371 968 5,235 5,235 171 1,886 681 6,206 5.628 62 311 311 41 316 316 0

0 0

313 1,769 1,769 509 3,904 3,904 3,480 26,680 1,305 578 26,680 4,031 6,990 313 10,965 TLG Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document S30-1499-002, Rev. 0 Appendix A, Page 4 of 19 TABLE A-i SOUTH TEXAS PROJECT - UNIT 1 DECON, DECOMMISSIONING COST ESTIMATE (Thousands of 2004 Dollars)

Columns may not add due to rounding iD NRC Spent Site LLW site GTCC Craft Labor Numbe Activity Description Deeon Remove Pack Ship Burial Other Contingency Total LicTerm Fuel Mgt.

Restore A CF B CF C CF CF Hours Period I Undlstributed Costs (continued) 13 ISFSI Site alterations 14 ISFSI transfer equipment 15 ISFSI licensing and permits 16 NRC Fees.

17 Emergency Planning Fees 18 Site Security Cost 19 Spent Fuel Pool O&M 20 Spent Fuel Pool Isolation 21 Spent Fuel Transfer Costs Subtotal Undiasuibuted Costs Period 1 Staff Costs DOC Staff Cost Utilty Staff Cost TOTAL PERIOD I COST PERIOD 2 Nuclear Steam Supply System Removal 27.1 Reactor Coolant Piping 27.2 Pressurizer Relief Tank 27.3 Reactor Coolant Pumps & Motors 27.4 Pressurizer 27.6 Steam Generators 27.6 Old Steam Generator Lower Shell Units 27.7 CRDMs/ICIs/Service Structure Removal 27.8 Reactor Vessel Internals 27.9 Reactor Vessel 27 Totals 28 Remove spent fuel racks Removal of Major Equipment 29 Main Turbine/Generator 30 Main Condensers 844 1.716 874 557 4,144 4,124 609 1,218 572 92 2,119 1,496 8,358 3.384 56,487 8.163 35,908 137,840 819 4,742 4,742 91 700 700 122 1,339 1,339 57 629 629 9

101 101 318 2,437 2,437 224 1,720 1.720 1.254 9.612 9,612 508 3,892 3,892 9,034 73.655 22,985 50,670 4,031 6.990 1,831 1,716 115 16 53 17 223 76 66 51 617 335 221 90 44 24 3,157 30 53 2.047 3,706 9,372 30 874 557 4,144 14 18 683 6

6 298 35 29 2.426 4

8 889 2.058 947 9.115 1,709 824 8,892 74 16 1.605 5.503 494 4,785 1,475 372 8,830 10,877 2,711 37,524 14 3

1.654 1,224 9,387 9,387 5,386 41,294 41,294 21,984 168,945 117,152 50,670 1,123 4,031 6,990 11,278 12,078 12.733 4,129 4.114 1,685 24,566 14,878 4,717 16,207 31.297 114,325 14,170 287 1,338 1.338 107 522 522 652 3,237 3,237 238 1.179 1,179 3,422 4.041 22,964 22,964 3,137 2.996 17,587 17.587 462 2,287 2,287 5,460 18.356 18,356 7,681 22,115 22.115 6,559 21,924 89.585 89,585 3,816 1,163 7.016 7.016 1,575 6688 5,596 2,050 21.027 20,512 3,703 2,003 788 459 7,178 2,629 64,333 3,417 459 3,816 73 384 11 84 84 3,298 58 441 441 16,323 TLG Services; Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document 830-1499-002, Rev. 0 Appendix A, Page 5 of'19 TABLE A-1 SOUTH TEXAS PROJECT - UNIT 1 DECON, DECOMMISSIONING COST ESTIMATE (Thousands of 2004 Dolars)

Columnns may not add due to rounding lNfumbei Activity Descrintion NRC Spent Site LLW site GTCC Craft Laborl Other Contineencv Total LicTer.

Fuel Met.

Restore A CF B CF C CF CF a-ou-s Decon Renmove Pack Shin Burial Disposal of Plant Systems 31.1 Auxiliary Feedwater (AF) 31.2 Auxiliary Feedwater (AF) RCA 31.3 Auxiliary Steam & Boilers (AS) 31.4 Auxiliary Steam & Boilers (AS) RCA 31.5 BOP Chemical Feed (CF) 31.6 BOP Diesel Generator (DB) 31.7 Bornn Recycle (BR) 31.8 Breathing Air (BA) RCA 31.9 Chemical & Volume Control (CV) 31.10 Chilled Water HVAC (CH) 31.11 Chilled Water HVAC (CH) RCA 31.12 Circulating Water (CW) 31.13 Circulating Water Screen Wash (SC) 31.14 Closed Loop Auxillary Cooling Water (AC) 31.15 Component Cooling Water (CC) RCA 31.16 Condensate (CD) 31.17 Condensate Polisher (CP) 31.18 Condensate Storage (CT) 31.19 Condenser Air Removal (CR) 31.20 Containment Building (XC) 31.21 Containment Building HVAC (HC) 31.22 Containment Combustible Gas Control (CG 31.23 Containment Hydrogen Monitoring (CM) 31.24 Containment Spray (CS) 31.25 Control Room HVAC (HB) Clean 31.26 Dernineralizer Water (DW) 31.27 Demlneralizer Water (DW) RCA 31.28 Diesel Generator Building (XG) 31.29 ECW & ECW Screen Wash (EW) 31.30 ECW & ECW Screen Wash (EW) RCA 31.31 Electrical Auxiliary Building (XE) 31.32 Electrical Auxiliary Building HVAC (HE) 31.33 Electrical Clean Non RCA 31.34 Electrical Clean RCA 31.35 Electrical Contaminated 31.36 Electlro-Hydraulic Controls (EH) 31.37 Extracton Steam (ES) 31.38 Feedwater (FW) 31.39 Feedwater (FW) RCA 31.40 Fire Protection (FP) 31.41 Fire Protection (FP) RCA 46 2

5 37 7

14 15 16 306 28 58 742 716 77 109 258 198 29 52 422 884 336 135 29 28 85 2,036 24 124 49 38 87 24 30 63 5

305 99 167 47 179 479 248 901 391 20 84 178 7

13 56 36 73 13 7.

21 12 0

0 11 6

0 0

1

.1 619 1,078 2

520 2

50 254 124 129 15 1,914 13 39 144 7

53 2

9 9

.5 42 5

26 26 2

17 2

18 252 1,320 1.320 23 108 108 843 3,541 3.541 12 88 93 460 460 30 227 4

34 8

59 344 1,650 1.00w 50 385 20 155 4

33 4

32 24 126 126 928 5,415 5,415 8

47 47 50 264 264 30 116 74 13 100 4

28 25 117 117 1

6 46 351 75 341 341 7

05 27 206 72 551 259 1,409 1,409 184 981 981 3

23 13 97 27 205 5

25 25 8

64 29 139 139 53 42 17 18 1,428 2,486 88 227 34 59 386 155 33 32 5

1,2005 116 44 100 28 6

351 55 206 551 586 23 97 205 64 0

2,145 310 1,754 899 687 734 11,635 3.291 54.061 3,589 15,455 9,450 1,361 2,456 51.670 15.922 6.304 1,316 1,321 3,236 68,174 915 4,737 3,676 3,945 1.156 3,705 235 14,693 10.664 2,038 8,079 22,327 44.307 15,215 918 4,067 8,503 782 2,695 4.372 TLG Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document S30-1499-002, Rev. 0 Appendix A, Page 6 of 19 TABLE A-i SOUTH TEXAS PROJECT - UNIT I DECON, DECOMMISSIONING COST ESTIMATE (Thousands of 2004 Dollars)

Columns may not add due to rounding ID NRC Spent Site LLW site GTCC Craft Laborl Mumbeo Activity Description Decon Remove Pack Ship Burial Other Contingency Total LicTer-Fuel Mgt.

Restore A CF B CF C CF CF Hours Disposal of Plant Systems (continued) 31.42 Fuel Handling Building (XF) 31.A3 Fuel Handling Building HVAC (HF) 31.44 Gas Storage C02 & H2 (CO/HY) 31.45 Gaseous Waste Processing (WG) 31.46 Generator C02 & H2 (GG) 31.47 Generator Hydrogen Seal Oil (SO) 31.48 Heater Drip & Vent (HD/HV) 31.49 Hot Shop & Decontamination Facility (XN) 31.50 Instrument Air (IA) 31.51 Integrated Leak Rate Test (IL) 31.52 Isolation Valve Cubicle Building (XV) 31.53 Liquid Waste Processing (WL) 1.131 31.54 Low Pressure Nitrogen (NL) 31.55 Lube Oil Purification Strg & Trnsfr (LO) 31.56 MAB Plant Vent Header (VE) 31.57 Main Generator (GE/GM/NN) 31.58 Main Steam (MS) 31.59 Main Steam (MS) RCA 11 31.60 Main Turbine & Lube Oil (LT/TM) 31.61 Mechanical Audfiary Bldg HVAC (HM) RCA 4,472 31.62 Mechanical Aurdliary Butding (XM).

31.63 Miscellaneous Drains (MD) 31.64 Miscellaneous HVAC (HZ) 31.65 Miscellaneous HVAC (HZ) RCA 230 31.66 Miscellaneous Reactor Coolant (RC) 31.67 Miscallaneous Yard Areas & Bidgs (XY) 31.68 Nonradioactive Chemical Waste (NC) 31.69 Nonradioactive Dms & Srnps (DR) 31.70 Nonradioactive Dms & Smps (DR) RCA 56 31.71 Oily Waste (OW) 31.72 Open Loop Ausiliary Cooling (OC) 31.73 Plant Fuel Oil Storage & Transfer (FO) 31.74 Post Accident Monitor/Sample (AM/AP) 31.75 Potable Water (PW) 31.76 Potable Water (PW) RCA 13 31.77 Primary Process Sampling (PS) 31.78 Radiation Monitoring (RA) 7 31.79 Radioactive Vents & Drains (ED) 760 31.80 Reactor Coolant Pump Oil Change-Out (P0 31.81 Reactor Head Degassing (RD) 31.82 Reactor Makeup Water (RM) 51 9401 116 7

7 143 32 119 149 2

1,058 16 24 8

12 246 20 46 1,075 200 2

92 sO 730 75 2

61 126 99 236 0

265 6

30 41 43 716 13 54 266 0

0 13 6

3 1

119 773 1

1 65 56 0

0 4

13 0

0 16 40 18 10 896 875 0

0 6

24 0

0 4

36 31 16 1.414 167 0

0 13 85 0

0 12 12 14 7

651 116 0

0 5

26 1

1 64 30 2

1 90 234 17 87 87 381 2,216 2,216 0

1 54 292 292 1

8 1

8 21 164 11 61 61 18 137 47 252 252 0

3 1,189 5.177 5,177 2

18 4

26 7

46 46 2

14 37 287 9

40 40 7

52 2,397 7,944 7.944 56 297 297 0

2 14 106 122 402 402 567 2.924 2,924 11 86 0

2 9

70 47 229 229 15 114 35 271 0

0 82 446 446 1

7 11 54 54 15 80 80 10 60 10 741 3,005 3,005 8

53 63 34 184 184 124 717 717 30 275 149 8

8 164 10 137 36 3

2,067 18 28 14 14 287 52 10 2

106 3.262 862 70 114 271 0

31 27 27 50 1,501 12 147 208 1,951 32,316 36 4,332 336 321 6,841 1,237 5,593 5,774 96 79,318 739 1,114 320 547 11,924 1,251 2.119 212.684 7.612 72 4,224 10,730 28,443 3.635 85 2,954 7,713 4,782 11,422 14 10,282 316 1,787 1,564 2.234 53,749 50 2.066 10,263 TL. Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document 830-1499-002, Rev. 0 AppendixA, Page 7 of19 TABLE A-1 SOUTH TEXAS PROJECT - UNIT 1 DECON, DECOMMISSIONING COST ESTIMATE (Thousands of 2004 Dollars)

Columns may not add due to rounding ID NRC Spent Site LLW site GTCC Craft Laborl Numbes Activity Description Decon Remove Pack Ship Burial Other Contingency Total LieTerm Fuel Me~t Restore A CF B CF C CF CF Hours Disposal of Plant Systems (continued) 31.83 Residual Heat Removal (RH) 31.84 SG Sludge Lancing & Chem Cleaning (SL) 31.85 Safety Injection (SI) 31.86 Secondary Process Sampling (SS) 31.87 Service Air (SA) 31.88 Service Water (T'W) 31.89 Sewage Treatment (ST) 31.90 Sodium Hypochiorlte (SH) 31.91 Solid Waste Processing (WS) 31.92 Spent Fuel Pool Cooling & Cleanup (FC) 31.93 Standby DG Fuel Oil Strg & Tmsfr (DO) 31.94 Standby Diesel Gen Starting Air (SD) 31.95 Standby Diesel Generator (DG) 31.96 Standby Diesel Generator Bldg HVAC (HG) 31.97 Standby Diesel Generator Lube Oil (LU) 31.98 Standby Diesel Jacket Water (JW) 31.99 Stator Cooling Water (GC) 31.100 Steam Generator Blowdown (SB) 31.101 Steam Generator slowdown (SB) RCA 31.102 Turbine Generator Building (XI) 31.103 Turbine Generator Building HVAC (HT) 31.104 Turbine Gland Seal (GS) 31 Totals Decontamlnation of Site Buildings 32.1 Reactor 32.2 Fuel Handling 32.3 Mechanical & Electrical Auxiliary 32 Totals 33 Terminate license 41 22 8,522 3571 931 29 61 11 23 10 39 328 26 12 89 56 5

4 8

68 41 18 208 16 18.141 32 18 62 35 1

1 21 12 238 133 1,586 3,068 60 1,028 11,639 3.314 1,104 1,048 5,466 167 1,044 25 2,3 6,364 517 2,678 0

1 1,168 6,309 4

34 9

71 2

12 3

26 1

11 49 216 381 2Z028 4

30 2

14 13 103 8

65 1

6 1

4 1

9 10 78 17 80 3

21 31 239 2

19 11.888 59.926 2,6781 6,309 216 2.028 80 51.882 3,659 7,078 34 71 12 26 11 140 2,371 30 14 103 65 6

4

-9 78 21 239 19

,5044 26.850 13,936 36 36,194 1,365 2.890 509 1,101 438 2,994 12,786 1.193 553 4.186 2,545 236 172 370 3.137 2.434 785 9.382 749 1,044,086 795 466 463 411 847 103 2,105 981 111

.42 67 220 64 22 39 125 632 1.458 6.840 364 673 3,079 291 767 3.163 1.287 2.898 13.082 Note 1 6.840 3.079 3,163 13,082 11,820 3,778 7,345 22,943 46,051 32,978 33,545 112,574 Period 2 Additional Costs 34 License Termination Survey 7,807 1.923 9,730 9,730 120,798 Subtotal Period 2 Activity Costs 11,579 28.980 11,350 2,973 56,284 25,833 39.865 176,864 171,295 5,569 117,942 3,417 459 1,425,575 TLG Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document S30.1499-002, Rev. 0 Appendix A, Page 8 of 19 TABLE A-i SOUTH TEXAS PROJECT - UNIT 1 DECON, DECOMMISSIONING COST ESTIMATE (Thousands of 2004 Dollars)

Columns may not add due to rounding iD NRC Spent Site LLW site GTCC Craft Laborl Number Activity Description Decons Remove Pack Ship Burial Other Contingency Total LieTerm Fuel Mat. Restore A CF B CF C CF CF Hours Period 2 Undlstributed Costs 1 Decon equipment 2 Decon supplies 3 DOC staff relocation expenses 4 Process liquid waste 5 Insurance 6 Property taxes 7 Health physics supplies 8 Heavy equipment rental 9 Small lool allowance 10 Pipe cutting equipment 11 Deown rig 12 Disposal of DAW generated 13 Decommissioning Equipment Disposition 14 Plant energy budget 15 NRC Fees 16 Emergency Planning Fees 17 Site Security Cost 18 LLRW Processing Equipment 19 ISFSI Cask Purchases 20 Spent Fuel Pool O&M 2`1 Spent Fuel Transfer Subtotal Undistributed Costs Period 2 Staff Costs DOC Staff Cost Utility Staff Cost TOTAL PERIOD 2 PERIOD 3 Demolition of Remaining Site Buildings 35.1 Reactor 36.2 Diesel Generator 35.3 Fuel Handling 35.4 isul Valve Cubicle & Aux Fdwtr Stug Tnk 35.5 Mechanical & Electrical Auxiliary 35.6 Tank Pads & Foundations 35.7 Transformer Pads 656 1,197 1,192 867

- 5,352 11,211 488 913 1,186-3,906 19,156 15,485 48,136 465 1.224 5

718 2,818 50 4,765 3

248 1,678 15,199 346 13,747 2,466 342 5,074 975 18,400 3,665 11.670 98 754 754 299 1,497 1,497 179 1,371 1.371 1.292 6,159 6,159 6,500 168 1,845 1.734 11 16.199 11,537 2.142 1,520 1,338 6,690 6,90 1.682 12.892 11,603 1,289 73 561 505 56 137 1,050 1,050 178 1,364 1,364 1,321 7.360 7,360 17,249 116 717 717 572 2,062 15,809 14,229 1,581 247 2,712 2.712 34 376 376 761 5.835 5,835 146 1.121 1.121 2,760 21,160 21.160 550 4,214 4,214 1,751 13,421 13,421 992 40.613 778 42,383 1.694 772 7.831 73,560 15,190 122,108 76,238 41,424 4,446 17,821 6,500 36,610 5,491 42,101 42,101

-- 62,523 9,378 71,902 71,902 13,044 3,744 64,114 198,527 69,925 412,975 361,536 41,424 10,015 135,763 9,917 459 1,467,957 4,652 634 2.062 535 4,943 234 251 698 5.350 95 730 309 2,372 80 616 741 5,685 35 269 38 288 803 237 568 4,548 730 2,134 616 5,116 269 288 99,608 10.947 38,456 11,338 92.031 6,163 6.370 T7l Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document S30.1499-002, Rev. 0 Appendix A, Page 9 of 19 TABLE A-I SOUTH TEXAS PROJECT - UNIT 1 DECON, DECOMMISSIONING COST ESTIMATE (Thousands of 2004 Dollars)

Columns may not add due to rounding Columns may not add due to rounding IlNumbei Activitv Description NRC Spent Site LLW site GTCC Craft Labor Decon Remove Pack Shin Burial Other Continmenev Total LieTerm Fuel Mgt.

Restor-A CF I CF V

CF CFW V

n.rs Demolition of Remaining Site Buildings (continued) 35.8 Turbine Generator 35.9 Turbine Generator Pedestal 35 Totals Site Closeout Acilvties 36 Grade & landscape site 37 Final report to NRC 38 GTCC Disposal Subtotal Period 3 Activity Costa Period 3 Undtstrlbuted Costs 1 Insurance 2 Property taxes 3 Heavy equipment rental 4 Smal tool allowance 5 Plant energy budget 6 NRC ISFSI Fees 7 Emergency Planning Fees 8 Site Security Cost 9 Spent Fuel Transfer Subtotal Undistributed Costs Period 3 Staff Costs DOC Staff Cost Utility Staff Cost TOTAL PERIOD 3 2,302 611 16,226 1,720

-345 2,647 2,647

-92 703

-703 2.434 18,659 1,608 17.051 67,161 10.798 342,872 17.945 3,331 121 3,452 21,398 141 15.427 15,569 465 3.166 402 500 193 1,412 1.092 7,230 258 1.978 1,978 21 163 163 2,314 17.741 17,741 679 8,697 5,027 38,541 19.512 19,029 679 351,569 46 511 511 3,166 1,210 1,956 500 3.831 3,831 18 140 140 60 462 462 50 551 551 19

.212 212 212 1,624 1,624 164 1,256 1,.256 1,070 11.752 3,740 8,012 882 6,763 6,763 414 3,174 2,857 317 5

0881

-2,760 31,440 7,393 60,231 22,369 3,740 34,122 679 351,569 TLG Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document S30-1499-002, Rev. 0 Appendix A, Page 10 of 19 TABLE A-1 SOUTH TEXAS PROJECT - UNIT 1 DECON, DECOMMISSIONING COST ESTIMATE (Thousands of 2004 Dollars)

Columnns may not add due to rounding INtumebe Activity Description Decon TOTAL COST TO DECOMMISSION 17,316 Total cost to decommission with 18.29% o Total NRC license termination cost Is 78.03%

Non-nuclear demolition cost Is 7.05%

Spent Fuel Management 14.92%

Total LLW site radwaste volume buried Total I0CFR61 greater than class C waste buried Total scrap metal released from South Texas Project Unit 1 Total craft labor requirements Remove Pack 71,249 13,918 ontingency'. $

642,151,127 or 501,057,150 or 45,259,548 or 95,834,429 Ship Burial 4,301 68,258 NEC Spent Site LLW site GTCC Craft Labori Other Contingency Total LibTerm Fuel Met.

Restore A CF B CF C CF CF Hours 367,806 99,302 642,151 501,057 95,834 45A260 139,794 16,907 459 679 1,831,604 157,160 cubic feet 679 cubic feet 33.033 tons 1,831,604 person hours Note: V" Indicates costs less than $500 Note 1: This activity Is performed by the decommissioning staff following plant shutdown; the costs for this are Included In this period's staff cost.

Note 2: This activity, while performed after final plant shutdown, is considered part of operations and therefore no decommissioning costs are Included for this activity.

TLG Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document S30-1499-002, Rev. 0 Appendix A, Page 11 of 19 TABLE A-2 SOUTH TEXAS PROJECT - UNIT 2 DECON, DECOMMISSIONING COST ESTIMATE (Thousands of 2004 Dollars)

Columns may not add due to rounding iD NRC Spent Site LLW site GTCC Craft Labor Number Activity Description Decon Remove Pack Ship Burial Other Contingency Total LAcTerm Fuel Mgt Restore A CF B CF C CF CF Hours PERIOD I 1 Prepare preliminary decommissioning cost 2 Notification of Cessation of Operations 3 Remove fuel & source material 4 Notification of Permanent Defueling 5 Deactivate plant systems & process waste 6 Prepare and submit PSDAR 7 Review plant dwgs & specs.

8 Perform detailed red survey 9 Estimate by-product Inventory 10 End product description 11 Detailed by-product Inventory 12 Define major work sequence 13 Perform SER and EA 14 Perform Site-Specific Cost Study 15 Prepare/submit License Termination Plan 16 Receive NRC approval of termination plan Acivity Specifications 17.1 Plant & temporary facilities 17.2 Plant systems 17.3 NSSS Decontamination Flush 17.4 Reactor Internals 17.5 Reactor vessel 17.6 Biological shield 17.7 Steam generators 17.8 Reinforced concrete 17.9 Turbine & condenser 17.10 Plant structures & buildings 17.11 Waste management 17.12 Facility & site closeout 17 Total Planning & Site Preparations 18 Prepare dismantling sequence 19 Plant prep. & temp. svces 20 Design water clean-up system 21 Rlgglng/CCEsltooting/etc.

22 Procure casks/liners & containers 50 8

68 58 Note 1 Note 2 Note I Note 1 78 12 89 89 178 27 205 205 Note 1 39 6

45 45 39 6

45 45 50 8

• 58 58 291 44 334 334 120 18 138 138 194 29 223 223 159 24 183 183 Note I 191 161 19 275 252 19 121 62 31 121 178 35 1.466 93 2,308 54 1,954 48 29 24 3

41 38 3

18 9

5 18 27 5

220 14 346 a

293 7

219 197 186 167 22 22 316 316 290 290 22 22 139 139 71 36 36 139 70 205 205 40 20 1,686 1,484 107 107 2,654 2,654 62 62 2,247 2,247 55 55 22 19 36 36 70 20 201 TLG Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document 830-1499-002, Rev. 0 Appendix A, Page 12 off19 TABLE A-2 SOUTH TEXAS PROJECT - UNIT 2 DECON, DECOMMISSIONING COST ESTIMATE (Thousands of 2004 Dollars)

Columns may not add due to rounding ID NRC Spent Site LLW site GTCC Craft Laborl Number Activity Description Decon Remove Pack Ship Burial Other Contingencc Total LIcTerm Fuel Mgt Restore A CF B CF C CF CF Hour.

Detailed Work Procedures 23.1 Plant systems 23.2 NSSS Decontaminatlon Flush 23.3 Vessel head 23.4 Reactor internals 23.5 Remaining buildings 23.6 CRD cooling assembly 23.7 CRD housings & ICI tubes 23.8 Incore instrumentation 23.9 Reactor vessel 23.10 Facility doseout 23.11 Missile shields 23.12 Biological shield 23.13 Steam generators 23.14 Reinforced concrete 23.15 Turbine & condensers 23.16 Auxiliary building 23.17 Reactor building 23 Total 24 Decon primary loop Period I Additional Costs 25 Site Characterization Survey 26 Severance Plan Subtotal Period 1 Activity Costs Period I Undsrbilbuted Costs 1 Deaon equipment 2 Decon supplies 3 DOC staff relocation expenses 4 Process liquid waste 5 Insurance 6 Property taxes 7 Health physics supplies 8 Heavy equipment rental 9 Small tool allowance 10 Disposal of PAW generated 11 Plant energy budget 12 ISFSI Cask Purchase 13 ISFSI site alterations 183 28 211 190 39 6

45 45 97 15 111 ItI 97 15 111 111 52 8

60 15 39 6

45 45 39 6

45 45 39 6

45 45 141 21 162 162 47 7

53 27 17 3

20 20 47 7

53 53 178 27 205 205 39 6

45 22 121 18 139 106 16 122 110 106 16 122 110 1,385 208 1,593 1,314 494 1,481 1,481 21 45 27 22 139 12 12 279 987 987 656 40 149 1,692 508 2-200 2,200 21,404 3,211 24,615 24,615 31,602 5,488 38,076 37,596 480 800 800 1,192 249 274 0

543 330 545 12 3,183 1,114 1,715 6,139 4,944 10,400 4,124 98 10 179 1,006 171 62 41 0

313 742 1,560 619 754 754 49 49 1,371 1,371 5,426 5,426 1,886 581 1,305 6,139 5,561 578 311 311 316 316 0

0 1,769 1,769 5,686 5.686 11,960 11,960 4,742 4.742 4,031 6,990 313 10,965 TLG Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document 830-1499-002, Rev. 0 Appendix A, Page 13 of19 TABLE A-2 SOUTH TEXAS PROJECT - UNIT 2 DECON, DECOMMISSIONING COST ESTIMATE (Thousands of 2004 Dollars)

Colunis may not add due to rounding ID NRC Spent Site LLW site GTCC Craft Labor Number Activity Description Decon Remove Pack Ship Burial Other Contingency Total LicTerm uel H, Restore A CF B CF C CF CF Hours Period I Undlstributed Costs (continued) 14 ISFSI transfer equipment 15 ISFSI licensing and permits 16 ISFSI O&M 17 NRC Fees 18 Emergency Planning Fees 19 Site Security Cost 20 Spent Fuel Pool O&M 21 Spent Fuel Pool Isolation 22 Spent Fuel Transfer Subtotal Undistributed Costs Period 1 Staff Costs DOC Staff Cost Ubtlity Staff Cost

!TOTAL PERIOD I COST PERIOD 2 Nuclear Steam Supply System Removal 27.1 Reactor Coolant Piping 27.2 Pressurizer Relief Tank 27.3 Reactor Coolant Pumps & Motors 27.4 Pressurizer 27.5 Steam Generators 27.6 Old Steam Generator Lower Sheo Units 27.7 CRDMs/CIa/ServIce Structure Removal 27.8 Reactor Vessel Internals 27.9 Reactor Vessel 27 Totals 28 Remove spent fuel racks Removal of Major Equipment 29 Main Turbine/Generator 30 Main Condensers 609 1,218 70 572 92 975 1,496 5,572 2,997 91 700 122 1,339 7

77.

57 629 029 9

101 146 1,121 1,121 224 1,720 83 6,408 449 3,446 700 1.339 77 101 1,720 6,408 3,446 4,031 6,990 844 1,716 1,831 1,716 98 190 16 90 53 44 17 24 223 3,157 30 76 53 66 2.047 51 3,706 601 9,341 335 30 73 384 874 557 4,297 40,923 6,744 55,954 23,576 32,378 5.807 871 6,678 6,678 28,144 4,222 32.365 32.365 874 857 4,297 106,475 17.324 133,074 100,216 32,378 12 16 590 248 1,153 1.153 6

6 298 107 622 522 35 29 2,426 652 3,237 3,237 4

8 889 238 1,179 1,179 2,058 947 9,115 3,422 4.041 22,964 22,964 1,709 824 8,892 3,137 2.996 17,587 17,587 74 16 1,605 462 2,287 2,287 5.503 494 4,771 5,453 18,335 18,335 1.475 372 8,736 7.634 21,973 21.973 10.875 2,709 37,323 6,559 21,830 89.238 89,238 14 3

1,654 3,815 1,163 7,016 7,016 11,278 480 4,031 8,990 12,078 1,361 688 5,596 2,050 21,027 20,512 3,703 2,003 7,178 64,119 3,816 10,880 4,129 4,115 1,684 24,566 14.878 4,717 788 459 29,692 2Z629 29,692 3,417 459 124,353 14,170 11 84 58 441 84 441 3,298 16,323 7L Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document S30-1499-002, Rev. 0 Appendix A, Page 14 of 19 TABLE A-2 SOUTH TEXAS PROJECT - UNIT 2 DECON, DECOMMISSIONING COST ESTIMATE (Thousands of 2004 Dollars)

Columns may not add due to rounding ID NRC Spent Site LLW site GTCC Craft Labor Number Activity Description Decon Remove Pack Ship Burial Other Contingency Total LicTerm Fuel Mgt Restore A CF B CF C CF CF Hours Disposal of Plant Systems 31.1 Auxiliary Feedwater (AF) 31.2 Auxiliary Feedwater (AF) RCA 31.3 Auxiliary Steam & Boilers (AS) 31.4 Auxiliary Steam & Boilers (AS) RCA 31.5 BOP Chemdcal Feed (CF/AD/CA) 31.6 SOP Dlesal Generator (DB) 31.7 Bonn Recycle (BR) 31.8 Breathing Air (BA) 31.9 Breathing Air (BA) RCA 31.10 Chemical & Volume Control (CV) 31.11 Chilled Water HVAC (CH) 31.12 Chilled Water HVAC (CH) RCA 31.13 Circulating Water (CW) 31.14 Circulating Water Screen Wash (SC) 31.15 Closed Loop Auxiliary Cooling Water (AC) 31.16 Component Cooling Water (CC) RCA 31.17 Condensate (CD) 31.18 Condensate Polisher (CP) 31.19 Condensate Storage (CT) 31.20 Condenser Air Removal (CR) 31.21 Containment Building (XC) 31.22 Containment Building HVAC (HC) 31.23 Containment Combustible Gas Control (CG) 31.24 Containment Hydrogen Monitoring (CM) 31.25 Containment Spray (CS) 31.26 Control Room HIAC (HB) Clean 31.27 Demineralizer Building HVAC (HW) 31.28 Demineralizer Water (DW) 31.29 Demlneralizer Water (DW) RCA 31.30 Diesel Generator Building (XG) 31.31 ECW & ECW Screen Wash (EW) 31.32 ECW & ECW Screen Wash (EW) RCA 31.33 Electrical Auxiliary Building (XE) 31.34 Electrical Auxiliary Building HVAC (HE) 31.35 Electrical Clean Non RCA 31.36 Electrical Clean RCA 31.37 Electrical Contaminated 31.38 Electro-Hydraulic Controls (EH) 31.39 Essential Cooling Pond Makeup (EP) 31.40 Essential Cooling Pond Makeup (EP) RCA 31.41 Extraction Steam (ES) 61 5

9 84 3

5 27 18 312 18 3

6 614 638 82 132 258 385 59 53 279 293 290 131 31 31 725.

1,732 24 124 50 39 81 9

208 4

9 8

298 84 143 85 189 715 320 1,331 668 15 23 23 41 84 12 7

575 19 11 988 2

1 75 12 6

556 0

0 2

1 1

50 8

4 357 125 128 441 1.689 13 37 193 9

70 4

17 17 13 97 2

9 9

4 31 3

21 243 1,273 1,273 3

21 2

11 11 736 3.134 3,134 12 94 105 495 495 58 443 9

68 8

61 184 756 756 44 334 17 20 150 5

36 5

35 266 1,510 1,510 827 4,822 4,822 8

47 47 49 262 262 31 119 74 12 93 1

10 31 239 3

17 17 1

10 45 342 63 290 290 13 98 28 217 107 822 360 2,012 2,012 287 1,517 1,517 2

17 3

26 17 81 81 13 96 70 97 31 21 21 94 443 68 61 317 150 36 35 45 93 10 239 10 342 98 217 822 17 26 96 1,326 2,278 174 1,281 4

115 824 2.852 523 3,985 286 1,285 852 11,843 840 356 46.284 3,815 15,433 18,541 2,764 2,541 24,485 13,742 6,112 1,429 1,456 25,371 58,382 933 4,727 3,712 3.671 408 9.631 525 375 14,248 9,058 3,789 8,538 33,307 63,735 25,967 697 1,075 2,479 4,027 TLG Services, Inc.

South Texas Project Electric Generating Station Decomnissioning Cost Update Document S30-1499-002, Rev. 0 Appendix A, Page 16 of 19 TABLE A-2 SOUTH TEXAS PROJECT - UNIT 2 DECON, DECOMMISSIONING COST ESTIMATE (Thousands of 2004 Dollars)

Columns may not add due to rounding ID NRC Spent Site LLW site GTCC Craft Labor Number Activity Description Decon Remove Pack Ship Burial Other Contingency Total LicTerm Fuel Mg Restore A CF B CF C CF CF Hours Disposal of Plant Systems (continued) 31.42 Feedwater(FW) 31.43 Feodwater (FW) RCA 31.44 Fire Protection (FP) 31.45 Fire Protection (FP) RCA 31.46 Fresh Water Supply (SW) 31.47 Fuel Handling Building (XF) 31.48 Fuel Handling Building HVAC (HF) 31.49 Gas H2 Storage (HY) 31.50 Gas N2 High Pressure Supply (NH) 31.51 Gaseous Waste Processing (NG) 31.52 Generator CO2 & H2 (GG) 31.53 Generator Hydrogen Seat Oil (SO) 31.54 Heater Drip & Vent (HD/HV) 31.55 Hot Shop & Decontamination Fadcily (XN) 31.56 Instrument Air (IA) 31.57 Integrated Leak Rate Test (IL) 31.58 IsolaSton Valve Cubicle Building (XV) 31.59 Lighting Diesel Generator (DL) 31.60 Liquid Waste Processing (WL) 31.61 Low Pressure Nitrogan (NL) 31.62 Lube Oil Purification Strg & Tmsfr (LO) 31.53 MAB Plant Vent Header (VE) 31.64 Main Generator (GE/GM/NN) 31.65 Main Steam (MS) 31.66 Main Steam (MS) RCA 31.67 Main Turbine & Lube Oil (LT/TM) 31.68 Mechanical Auxiliary Bldg HVAC (HM) RCA 31.69 Mechanical Auxiliary Building (XM) 31.70 Miscellaneous Drains (MD) 31.71 Miscellaneous HVAC (HZ) 31.72 Miscellaneous HVAC (HZ) RCA 31.73 Miscellaneous Reactor Coolant (RC) 31.74 Miscellaneous Yard Areas & Bldgs (XY) 31.75 Nonradioactive Chemical Waste (NC) 31.75 Norvadloactlve Dms & Smps (DR) RCA 31.77 Nonradloactive Plumbing Dms & Smps (DR) 31.78 Oily Waste (OW) 31.79 Open Loop Auxiliary Cooling (OC) 31.80 Plant Fuel Oil Storage & Transfer (FO) 31.81 Post Accident Monitor/Sample (AM/AP) 31.82 Potable Water (PW) 195 7

12 173 21 40 37 21 1,027 1

0 122 10 18 177 37 134 151 4

5 1,110 1,019 41 36 322 13 191 9

15 63 4,134 986 235 30 113 78 17 699 1,518 79 75 138 66 140 125 41 374 51 0

0 3

3 1

129 1

1 65 0

0 10 0

0 24 17 10 830 2

1 86 0

0 9

31 16 1,430 0

0 17 3

836 57 19 47 852 281 60 168 112 29 225 5

24 24 26 198 16 77 77 6

43 7

34 34 415 2.411 2,411 0

1 0

0 55 300 300 2

12 3

20 27 203 14 80 80 20 155 51 274 274 1

5 1

6 1,148 4,985 4,985 6

47 6

41 144 836 836 2

15 29 220 7

30 30 9

72 2,215 7,335 7.335 70 375 375 5

35 17 131 41 136 136 563 2.907 2.907 228 1.746 12 91 58 272 272 10 76 22 170 19 143 6

47 115 619 619 8

59 225 198 43 0

12 20 203 155 5

6 47 41 15 220 72 35 131 1,746 91 76 170 143 47 59 7

297 149 22 56 1,916 198 22 3.298 40 9,288 755 8,155 2,416 1.751 80O 35,438 34 17 4,637 469 819 8,456 1,405 6,353 5,843 183 233 77.196 1,967 1,674 10.791 583 9.155 949 2908 196,311 8,852 1,428 5.175 3,633 27,237 70.842 3,734 8,460 3,175 7,114 5,960 1,921 14,480 2,452 TLG Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document S30-1499-002, Rev. 0 Appendix A, Page 16 of 19 TABLE A-2 SOUTH TEXAS PROJECT - UNIT 2 DECON, DECOMMISSIONING COST ESTIMATE (Thousands of 2004 Dollars)

Columns may not add due to rounding

' D NRC Spent Site LLW site GTCC Craft Labor Pack Ship Burial Other Contingency Total LicTerm Fuel Mgt Restore A CF B CF C CF CF Hoursl I*

1RAmn*A Number Activit Desert tion Decan Remove Disposal of Plant Systems (continued) 31.83 Potable Water (PW) RCA 31.84 Primary Process Sampling (PS) 31.85 Radiation Monitoring (RA) 31.86 Radioactive Vents & Drains (ED) 31.87 Reactor Coolant Pump Oil Change-Out (PO) 31.88 Reactor Head Degassing (RO) 31.89 Reactor Makeup Water (RM) 31.90 Residual Heat Removal (RH) 31.91 SO Sludge Lancing & Chem Cleaning (SL) 31.92 Safety Injection (SI) 31.03 Secondary Process Sampling (SS) 31.94 Service Air (SA) 31.95 Service Water (TW) 31.96 Sewage Treatment (ST) 31.97 Sodium Hypochlorite (SH) 31.98 Solid Waste Processing (WS) 31.99 Spent Fuel Pool Cooling & Cleanup (FC) 31.100 Standby DG Fuel Oil Strg & Tmsfr (DO) 31.101 Standby Diesel Gen Starting Air (SD) 31.102 Standby Diesel Generator (DG) 31.103 Standby Diesel Generator Bldg HWAC (HG) 31.104 Standby Diesel Generator Lube Oil (LU) 31.105 Standby Diesel Jacket Water (JW) 31.106 Stator Cooling Water (GC) 31.107 Steam Generator Blowdown (SB) 31.108 Steam Generator Blowdown (SB) RCA 31.109 Turbine Generator Building (XT) 31.110 Turbine Generator Building HVAC (HT) 31.111 Turbine Gland Seal (GS) 31.112 Well Water Supply (WW) 31 Totals Decontamination of Site Buildings 32.1 Reactor 32.2 Fuel Handling 32.3 Mechanical & Electrical Auxiliary 32 Totals 33 Terminate license 12 25 40 8

56 772 718 13 63 290 345 0

1,198 26 82 45 50 81 41 38 311 26 12 82 57 3

3 4

40 23 43 77 217 20 188 7,805 21,974 795 466 463 411 847 103 1.729 805 0

0 10 14 7

648 0

0 5

1 1

67 2

1 88 31 17 1,527 65 36 3.153 1

1 60 20 11 952 241 134 11,718 12 111 26 31 252 166 1,086 25 235 7,005 10 46 46 14 77 77 12 77 12 747 3,019 3,019 8

63 53 37 201 201 132 765 765 499 2,585 2,585 0

0 1,262 6,798 6.798 4

30 12 94 7

52 7

57 12 93 49 215 215 355 1,883 1,883 4

30 2

13 12 94 9

66 0

3 0

4 1

4 6

46 18 84 84 12 89 33 249 3

22 28 216 12,347 61,225 62,776 1.458 6,840 6.840 673 3,079 3,079 767 3.163 3,163 2,898 13,082 13,082 Note 1 23 65 1,496 12 156 202 3,523 0

7,274 30 94 52 57 93 139 2,197 30 13 94 66 3

4 4

46 89 249 22 216 8,449 27.031 11,820 3,778 7,345 22,943 1.496 1,531 2,885 54,381 500 2,395 11.207 13,478 8

46,584 1,212 3.902 2,145 2.412 3,787 2,978 12,108 1,166 534 3,831 2,595 124 146 175 1,907 2,618 3,516 9.786 903 8,883 1,186.227 46,051 32,978 33,545 112,574 111 64 3.314 632 42 22 1.104 364 67 39 1,048 291 181 103 8.581 901 TW Services, Ine.

South Texas Project Electric Generating Station Decommissioning Cost Update Document 830-1499-002, Rev. 0 Appendix A, Page 17 of19 TABLE A-2 SOUTH TEXAS PROJECT - UNIT 2 DECON, DECOMMISSIONING COST ESTIMATE (Thousands of 2004 Dollars)

Columns may not add due to rounding iD NRC Spent Site LLW site GTCC Craft Labor Number Activity Description Decon Remove Pack Ship Burial Other Contingency Total LieTerm Fuel Mgt Restore A CF B CF C CF CF Hours Period 2 Additional Costs 34 Ucense Termination Survey Subtotal Period 2 Activity Costs Period 2 Undistributed Costs 1 Decon equipment 2 Decon supplies 3 DOC staff retocaton expenses 4 Process liquid waste 5 Insramnce 6 Property taxes 7 Health physics supplies 8 Heavy equipment rental 9 Small tool allowance 10 Pipe cutting equipment 11 Decon rig 12 Disposal of DAW generated 13 Decommissioning Equipment Disposition 14 Plant energy budget 15 ISFSI O&M 16 NRC Fees 17 Emergency Planning Fees 18 Site Security Cost 19 LLRW Processing Equipment 20 ISFSI Cask Purchase 21 Spent Fuel Pool O&M 22 Spent Fuel Transfer Subtotal Undtabibuted Costs Period 2 Staff Costs DOC Staff Cost Utility Staff Cost TOTAL PERIOD 2 10.470 32,607 656 1,198 1,192 861 5,801 11,238 533 913 1,186 3.901 19,878 14,371 52,284 7,875 2.362 10,237 10,237 11.312 2,949 59,278 26,155 40.670 181,323 172,349 98 754 754 299 1,497 1,497 179 1,371 1,371 458 710 2,776 1,277 6,082 6.082 1,681 168 1,849 1,738 13,808 13,808 10,280 1,450 7,251 7,251 1,686 12.923 11,631 80 613 552 137 1,050 1.050 178.

1,364 1.364 1,227 51 4,836 1,339 7,462 7,452 5

3 248 405 124 786 786 19.206 2,881 22,087 19,878 392 39 431 2.472 247 2.719 2,719 342 34 377 7.878 1,182 9,059 8,606 927 139 1,060 1,066 30.400 4.560 34,960 3.662 549 4,211 11.714 1,757 13,471 1,690 764 7,860 92,886 18,404 146,180 84,076 46.653 6,998 53,651 53,651 81,652 12,248 93,900 91,265 13,002 3,712 67,136 247,346 78,319 474,054 401,340 121.892 3.417 459 1,578,837 111 2,147 431 377 453 34,960 4,211 13,471 56,161 2.635 58,796 8,974 117,909 1,381 1,292 611 17.505 572 2.209 4,943 18.077 13,917 135,986 6,405 6,405 9,822 459 984 40,711 778 42,473 1,621.310 TLG Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document S30-1499-002, Rev. 0 Appendix A, Page 18 of 19 TABLE A-2 SOUTH TEXAS PROJECT - UNIT 2 DECON, DECOMMISSIONING COST ESTIMATE (Thousands of 2004 Dollars)

Columns may not add due to rounding ID NRC Spent Site LLW site GTCC Craft Laborl Number Activity Description Decon Remove Pack Ship Burial Other Contingenc5 Total LieTerm Fuel M Restore A CF B CF C CF CIF Hours PERIOD 3 Demolition of Remaining Site Buildings 35.1 Reactor 35.2 Basins 35.3 Circulating Water Intake & Discharge 35.4 Diesel Generator 35.5 Essential Cooling Pond/Intake/Discharge 35.6 Fuel Handling 35.7 Isol Valve Cubicle & Aux Fdwtr Strg Tnk 35.8 Maintenance Operations Facility 35.9 Mechanical & Electrical Auxiliary 35.10 Miscellaneous Slabs, Foundations & Pads 35.11 Miscellaneous Yard Buildings 35.12 Nuclear Support Center 35.13 Nuclear Training Facility& Annex 35.14 Sewage Treatment Plant 35.15 Steam Generator Mausoleum 35.16 Tank Pads & Foundations 35.17 Transformer Pads 35.18 Trenches & Culverts 35.19 Turbine Generator 35.20 Turbine Generator Pedestal 35.21 Warehouses 3522 Yard Piping 35 Totals Site Closeout Activities 36 Remove Rubble 37 Grade & landscape site 38 Final report to NRC Period 3 Additional Costs 39 ISFSI License Termination 40 ISFSI Demolition and Site Restoration 41 Firing Range Restoration 42 Reservoir Restoration 43 GTCC Disposal Subtotal Period 3 Activity Costa 4,652 85 3,985 634 639 2,062 535 376 4.943 913 1,995 486 282 56 266 235 263 1,122 2.302 611 2.316 91 28,852 698 5.350 13 98 598 4,583 95 730 96 735 309 2,372 80 616 56 432 741 5,685 137 1,050 299 2,295 73 558 42 324 8

65 40 305 35 270 40 303 168 1.290 345 2,647 92 703 347 2,664 14 105 4,328 33,180 803 237 568 1,608 4,548 98 4.583 730 735 2.134 616 432 5.116 1,050 2,295 558 324 65 305 270 303 1.290 2.647 703 2.664 105 31.572 99,608 1.021 53.943 10.947 10,712 38,456 11,338 8,479 92,031 19,844 44,016 11,701 7.203 671 4,131 6,183 6,678 25.578 67,161 10,798 45.588 1,279 577.366 1,184 2,497 178 1,361 1,361 375 2,872 2,872 60 9

70 70 2.326 12,627 2.449 1,503 8

36,493 161 70 17 5,385 49 15,427 2,607 2,376 13,049 270 416 2,190 16 90 22,162 3,324 25,486 2,314 17,741 17,741 13,049 2,190 90 26,486 12,422 12,422 679 63,467 6.701 161 87 20,861 25,100 13,336 96,039 19,419 15.239 61,381 679 662,488 T7W Services, Inc.

C South Texas Project Electric Generating Station Decommissioning Cbst Update Document S30-1499-002, Rev. 0 Appendix A, Page 19 of 19 TABLE A-2 SOUTH TEXAS PROJECT - UNIT 2 DECON, DECOMMISSIONING COST ESTIMATE (Thousands of 2004 Dollars)

Columns may not add due to rounding ID NRC Spent Site LLW site GTCC Craft Laborl Number Activity Description Decon Remove Pack Ship Burial Other Contingency Total LieTerm Fuel Mgt Restore A CF B CF C CF CF Hours Period 3 Undistributed Costs 1 Insurance 2 Property taxes 3 Heavy equipment rental 4 Small tool allowance 5 Plant energy budget 6 ISFSI O&M 7 NRC ISFSI Fees 8 Emergency Planning Fees 9 Site Security Cost 10 Spent Fuel Transfer Subtotal Undistributed Costs Period 3 Staff Costs DOC Staff Cost Utility Staff Cost TOTAL PERIOD 3 TOTAL COST TO DECOMMISSION Total cost to decommission with Total NRC license termination cost is Non-nuclear demolition cost is Spent Fuel Management Total LLW site radwasta volume buried Total I0CFR61 greater than class C waste buried Total scrap metal released from South Texas Prole Total craft labor requirements 3,331 202 3.533 1,671 167 1,838 1,838 9,341 9,341 8,800 741 500 3,831 3,831 30 232 232 1,025 154 1,179 1,179 825 124 948 948 3,558 356 3,914 3,914 1,331 133 1.464 1,464 6,735 1,010 7.746 7,228 518 7.843 1,176 9.019 9,019 32.329 3,650 39,512 33,011 6,501 9,985 1,498 11,482 11,482 20,118 3.018 23.135 3,928 16,894 2,314 40,026 161 87 20,861 87,531 21 501 170,169 23,347 65,144 81,678 12,422 6-79 662,488 16,202 94,026 14,037 4,356 92,294 441,352 117,145 777,297 524,904 156,318 96,075 152,439 16,812 459 679 2,295,875 17.75% contingency $

777,296,8946 67.53%

or 524,903,585 12.36%

or 96,075,107 20.11%

156,318,253 169,710 cubic feet 679 cubic feet ct Unit 2 40,869 tons 2,295,875 person hours Note: "0" indicates costs less than $500 Note 1: This activity Is performed by the decommissioning staff following plant shutdown; the costs for this are Included in this period's staff cost.

Note 2: This activity, while performed after final plant shutdown, is considered part of operations and therefore no decommissioning costs ere included for this activity.

TLG Services, Inc.

South Texas Project Electric Generating Station Document S30-1499-002, Rev. 0 Decommissioning Cost Update Appendix B, Page 1 of 9 APPENDIX B CO-OWNER SCHEDULE OF ANNUAL EXPENDITURES DECON Alternative Page Texas Genco, LP - Unit 1.............................................................................................

B-2 Texas Genco, LP - Unit 2..............................................................................................

B-3 AEP Texas Central Co. - Unit 1..................................................................................

B-4 AEP Texas Central Co. - Unit 2..............................................................................

B-5 CPS - Unit 1..................................................................................................................

B-6 CPS - Unit 2..................................................................................................................

B-7 COA - Unit l...........................................................................................................

B-8 COA - Unit 2..................................................................................................................

B-9 TLG Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document S30-1499.002, Rev. 0 Appendix B, Page 2 of 9 TABLE B-l.a TEXAS GENCO, LP - SCHEDULE OF ANNUAL EXPENDITURES DECON Alternative - Unit 1 (2004 Dollars, 10% Contingency)

Period 3 Period 1 Year Planning Period 2 Decommissioning Site Restoration Offset Site Restoration Total 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 11,866,676 33,795,520 4,446,988 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

27,069,260 28,222,431 23,455,482 22,827,410 18,835,127 2,078,759 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

247,897 793,217 19,407 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

6,262,589 5,279,187 0

0 0

0 0

0 0

0 0

5,262,074 0

11,866,676 33,795,520 31,516,247 28,222,431 23,455,482 22,827,410 18,835,127 2,326,656 793,217 6,281,996 5,279,187 0

0 0

0 0

0 0

0 0

5,262,074 0

50,109,184 122,488,469 1,060,520 16,803,851 190,462,024 TLG Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document S30-1499-002, Rev. 0 Appendix B, Page 3 of 9 TABLE B-l.b TEXAS GENCO, LP - SCHEDULE OF ANNUAL EXPENDITURES DECON Alternative - Unit 2 (2004 Dollars, 10% Contingency)

Post Decommissioning Period 1 Year Planning Period 2 D&D Site Restoration ISFSI Operations Spent Fuel ISFSI Transfer

'D&D Total 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 1,303,315 26,600,662 11,565,870 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

21,175,059 30,894,125 27,769,217 26,922,988 23,623,247 10,093,723 126,006 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

14,998,503 12,643,318 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

224,017 1,277,599 1,277,599 1,281,099 1,277,599 1,277,599 1,277,599 1,281,099 1,277,599 1,277,599 6,214,148 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

3,170,564 1,716,125 0

1,303,315 26,600,662 32,740,929 30,894,125 27,769,217 26,922,988 23,623,247 10,093,723 15,124,510 12,867,335 1,277,599 1,277,599 1,281,099 1,277,599 1,277,599 1,277,599 1,281,099 1,277,599 1,277,599 9,384,712 1,716,125 0

39,469,846 140,604,365 27,641,821 17,943,553 4,886,689 230,546,274 TLG Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document 830-1499-002, Rev. 0 Appendix B, Page 4 of 9 TABLE B-2.a AEP TEXAS CENTRAL CO. - SCHEDULE OF ANNUAL EXPENDITURES DECON Alternative - Unit 1 (2004 Dollars, 10% Contingency)

Period 3 Period 1 Year Planning Period 2 Decommissioning Site Restoration Offset Site Restoration Total 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 9,706,189 27,642,593 3,637,354 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

22,140,939 23,084,160 19,185,097 18,671,375 15,405,940 1,700,293 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

202,764 648,801 15,873 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

5,122,401 4,318,041 0

0 0

0 0

0 0

0 0

4,304,043 0

9,706,189 27,642,593 25,778,293 23,084,160 19,185,097 18,671,375 15,405,940 1,903,057 648,801 5,138,275 4,318,041 0

0 0

0 0

0 0

0 0

4,304,043 0

40,986,136 100,187,804 867,438 13,744,485 155,785,863 TLG Services, Inc.

South Texas Project Electric Generating Station Decommissioning Cost Update Document S30-1499-002, Rev. 0 Appendix B, Page 5 of 9 TABLE B-2.b AEP TEXAS CENTRAL CO. - SCHEDULE OF ANNUAL EXPENDITURES DECON Alternative - Unit 2 (2004 Dollars, 10% Contingency)

Post Decommissioning Period 1 Year Planning Period 2 D&D Site Restoration ISFSI Operations Spent Fuel ISFSI Transfer D&D Total 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 1,066,029 21,757,655 9,460,149 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

17,319,856 25,269,436 22,713,460 22,021,298 19,322,319 8,256,026 103,065 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

12,267,825 10,341,433 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

183,232 1,044,995 1,044,995 1,047,858 1,044,995 1,044,995 1,044,995 1,047,858 1,044,995 1,044,995 5,082,779 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

2,593,320 1,403,681 0

1,066,029 21,757,655 26,780,004 25,269,436 22,713,460 22,021,298 19,322,319 8,256,026 12,370,890 10,524,664 1,044,995 1,044,995 1,047,858 1,044,995 1,044,995 1,044,995 1,047,858 1,044,995 1,044,995 7,676,099 1,403,681 0

32,283,833 115,005,459 22,609,257 14,676,689 3,997,002 188,572,239 MG Services, Inc.

South Texas Project Electric Generating Station Document S30-1499-002, Rev. 0 Decommissioning Cost Update Appendix B, Page 6 of 9 TABLE B-3.a CPS - SCHEDULE OF ANNUAL EXPENDITURES DECON Alternative - Unit 1 (2004 Dollars, 10% Contingency)

Period 3 Period 1 Year Planning Period 2 Decommissioning Site Restoration Offset Site Restoration Total 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 9,794,209 27,893,268 3,670,339 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

22,341,722 23,293,497 19,359,076 18,840,695 15,545,648 1,715,712 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

204,602 654,685 16,017 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

5,168,853 4,357,198 0

0 0

0 0

0 0

0 0

4,343,074 0

9,794,209 27,893,268 26,012,061 23,293,497 19,359,076 18,840,695 15,545,648 1,920,315 654,685 5,184,871 4,357,198 0

0 0

0 0

0 0

0 0

4,343,074 0

41,357,816 101,096,350 875,305 13,869,126 157,198,596 TLG Services, Inc.

South Texas Project Electric Generating Station Document S30-1499-002, Rev. 0 Decommissioning Cost Update Appendix B, Page 7 of 9 TABLE B-3.b CPS - SCHEDULE OF ANNUAL EXPENDITURES DECON Alternative - Unit 2 (2004 Dollars, 10% Contingency)

Post Decommissioning Period 1 Year Planning Period 2 D&D Site Restoration ISFSI Operations Spent Fuel ISFSI Transfer D&D Total 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 1,075,696 21,954,963 9,545,937 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

17,476,920 25,498,590 22,919,435 22,220,996 19,497,542 8,330,895 104,000 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

12,379,075 10,435,213 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

184,894 1,054,471 1,054,471 1,057,360 1,054,471 1,054,471 1,054,471 1,057,360 1,054,471 1,054,471 5,128,872 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

2,616,837 1,416,411 0

1,075,696 21,954,963 27,022,857 25,498,590 22,919,435 22,220,996 19,497,542 8,330,895 12,483,075 10,620,107 1,054,471 1,054,471 1,057,360 1,054,471 1,054,471 1,054,471 1,057,360 1,054,471 1,054,471 7,745,709 1,416,411 0

32,576,596 116,048,377 22,814,288 14,809,783 4,033,248 190,282,292 TLG Services, Inc.

South Texas Project Electric Generating Station Document S30-1499-002, Rev. 0 Decommissioning Cost Update Appendix B, Page 8 of 9 TABLE B-4.a COA - SCHEDULE OF ANNUAL EXPENDITURES DECON Alternative - Unit 1 (2004 Dollars, 10% Contingency)

Period 3 Period 1 Year Planning Period 2 Decommissioning Site Restoration Offset Site Restoration Total 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 5,597,262 15,940,638 2,097,551 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

12,768,002 13,311,929 11,063,459 10,767,211 8,884,135 980,507 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

116,928 374,144 9,154 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

2,953,932 2,490,082 0

0 0

0 0

0 0

0 0

2,482,010 0

5,597,262 15,940,638 14,865,553 13,311,929 11,063,459 10,767,211 8,884,135 1,097,435 374,144 2,963,086 2,490,082 0

0 0

0 0

0 0

0 0

2,482,010 0

23,635,451 57,775,242 500,225 7,926,024 89,836,943.

TLG Services, Inc.

South Texas Project Electric Generating Station Document S30-1499-002, Rev. 0 Decommissioning Cost Update Appendix B, Page 9 of 9 TABLE B-4.b COA - SCHEDULE OF ANNUAL EXPENDITURES DECON Alternative - Unit 2 (2004 Dollars, 10% Contingency)

Post Deconmmissioning Period 1 Year Planning Period 2 D&D Site Restoration ISFSI Operations Spent Fuel ISFSI Transfer D&D Total 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 614,746 12,546,974 5,455,378 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

9,987,831 14,572,111 13,098,157 12,699,009 11,142,590 4,760,998 59,435 0O 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 7,074,479 5,963,588 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

105,664 602,616 602,616 604,267 602,616 602,616 602,616 604,267 602,616 602,616 2,931,083 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

1,495,488 809,460 0

614,746 12,546,974 15,443,209 14,572,111 13,098,157 12,699,009 11,142,590 4,760,998 7,133,914 6,069,252 602,616 602,616 604,267 602,616 602,616 602,616 604,267 602,616 602,616 4,426,572 809,460

.0 18,617,099 66,320,131 13,038,067 8,463,598 2,304,949 108,743,843 TLG Services, Inc.