NOC-AE-11002663, Regarding Financial Assurance for Decommissioning - 2011 Update (Revised)

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Regarding Financial Assurance for Decommissioning - 2011 Update (Revised)
ML11109A006
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 04/13/2011
From: Harrison G
South Texas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-11002663, D57, G25, STI: 32851932
Download: ML11109A006 (15)
v • d • e


Text

Nuclear Operating Company South Texas ProlectElectnc Generatin$Stion PO Box 289 Wadswwrth Texas 77483 -

April 13, 2011 NOC-AE-1 1002663 File No.: D57, G25 10 CFR 50.75 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, STN 50-499 Financial Assurance for Decommissioninq - 2011 Update (Revised)

Reference:

George Harrison, STP Nuclear Operating Company, to NRC Document Control Desk, "Financial Assurance for Decommissioning - 2011 Update," dated March 24, 2011 (NOC-AE-11002656)

Pursuant to 10 CFR 50.75(f)(1), the STP Nuclear Operating Company (STPNOC) submits this revision to the referenced 2011 update regarding funds available, effective December 31, 2010, for decommissioning South Texas Project Units 1 and 2. The revision slightly increases the minimum decommissioning fund estimate for the 28% share of Units 1 and 2 held by City Public Service of San Antonio, and revises footnotes 2 and 3 for the 28% share where indicated in the margins. Footnote 2 for the 12% share incorporates an editorial change to the owner name.

The data are assembled by the individual co-owners of the South Texas Project; each of the co-owners is responsible for its respective contribution to the content of this report:

" NRG South Texas LP;

" City Public Service of San Antonio (referred to as CPS Energy); and

  • City of Austin - Austin Energy.

This letter contains no NRC commitments.

If there are any questions, please contact either Mr. Philip L. Walker at (361) 972-8392 or me at (361) 972-8074.

George Harrison General Manager, Finance and Accounting PLW Attachments:

1. Financial Assurance for Decommissioning - NRG South Texas LP
2. Financial Assurance for Decommissioning - City Public Service of San Antonio
3. Financial Assurance for Decommissioning - City of Austin - Austin Energy Aw (

STI: 32851932 (7

NOC-AE-1 1002663 Page 2 of 2 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV John Ragan U. S. Nuclear Regulatory Commission Catherine Callaway 612 East Lamar Blvd., Suite 400 Jim von Suskil Arlington, Texas 76011-8064 NRG South Texas LP Balwant K. Singal A. H. Gutterman, Esquire Senior Project Manager Morgan, Lewis & Bockius LLP U.S. Nuclear Regulatory Commission One White Flint North (MS 8B1) 11555 Rockville Pike Balwant K. Singal Rockville, MD 20852 U. S. Nuclear Regulatory Commission Senior Resident Inspector Richard Pena U. S. Nuclear Regulatory Commission E. Alarcon P. 0. Box 289, Mail Code: MN1 16 Kevin Polio Wadsworth, TX 77483 City Public Service C. M. Canady C. Mele City of Austin City of Austin Electric Utility Department 721 Barton Springs Road Peter Nemeth Austin, TX 78704 Crain Caton & James, P.C.

Richard A. Ratliff Texas Department of State Health Services Alice Rogers Texas Department of State Health Services

ATTACHMENT I SOUTH TEXAS PROJECT FINANCIAL ASSURANCE FOR DECOMMISSIONING 2011 UPDATE NRG SOUTH TEXAS LP

Attachment 1 NOC-AE-1 1002663 Page 1 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONING NRG South Texas LP 13.2% Ownership of South Texas Project Unit 1 Pursuant to 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning on March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor or share of reactor it owns. The requested information is provided below.

1. Minimum decommissioning fund estimate, Total Required: $61,642,350 pursuant to 10 CFR 50.75(b) and (c)1:
2. Amount accumulated at the end of the calendar Amount Accumulated2 : $37,773,989 year preceding the date of the report for items included in 10 CFR 50.75(b) and (c):
3. Schedule of the annual amounts remaining to be Amount Remaining3 : $20,870,100 collected for items in 10 CFR 50.75(b) and (c):

Number of Years to Collect: 17

4. Assumptions used regarding escalation in Escalation Rate: 2.713%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 5.02% -7.01%

factors used in funding projections:

5. Contracts upon which the licensee is relying The Public Utility Commission of Texas pursuant to 10 CFR 50.75(e)(1)(ii)(c): (PUCT) approved the Decommission Funds Collections Agreement by and between AEP Texas Central Company (TCC) and NRG South Texas LP in which TCC collects the non-bypassable charges and deposits them directly into the trust.
6. Modifications to a licensee's current method None providing financial assurance occurring since the last submitted report:
7. Material changes to trust agreements: None
1. The NRC formulas in section 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service, and reduce residual radioactivity to levels that permit: (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.
2. By Order dated October 10, 2008 in PUCT Docket No. 35772, NRG South Texas LP was granted approval to establish a separate spent fuel management subaccount. By Order dated July 13, 2009 in PUCT Docket No. 36796, NRG South Texas was granted approval to establish a separate subaccount for pre-shutdown disposal of large components. The amounts allocable to the spent fuel management and pre-shutdown disposal subaccounts are not included in the reported amount. The reported amount includes funds accumulated based upon a site-specific study that includes license termination and other costs.
3. Target amounts to be collected were established by the PUCT-approved separate non-bypassable decommissioning charges established in PUCT Tariff Control No. 31271. Actual collections will vary but the charges are intended to produce the targeted annual collection amounts established in PUCT Docket No. 35772. Collections are being deposited on a priority basis in the large component disposal subaccount, which is expected to be fully funded in 2011. Thereafter, collections will be apportioned between the subaccount (-27.5%) and the primary account for 10CFR50.75(c) costs (-72.5%).

Attachment 1 NOC-AE-1 1002663 Page 2 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONING NRG South Texas LP 30.8% Ownership of South Texas Project Unit I Pursuant to 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning on March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor or share of reactor it owns. The requested information is provided below.

1. Minimum decommissioning fund estimate, Total Required: $143,832,150 pursuant to 10 CFR 50.75(b) and (c)1 :
2. Amount accumulated at the end of the calendar Amount Accumulated 2: $94,572,148 year preceding the date of the report for items included in 10 CFR 50.75(b) and (c):
3. Schedule of the annual amounts remaining to be Amount Remaining 3: $33,852,789 collected for items in 10 CFR 50.75(b) and (c):

Number of Years to Collect: 17

4. Assumptions used regarding escalation in Escalation Rate: 2.713%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 5.02% - 7.01%

factors used in funding projections:

5. Contracts upon which the licensee is relying The Public Utility Commission of Texas pursuant to 10 CFR 50.75(e)(1)(ii)(c): (PUCT) approved the Decommission Funds Collections Agreement by and between CenterPoint Energy Houston Electric (CNP) and Texas Genco, LP In which CNP collects the non-bypassable charges and deposits them directly into the trust.
6. Modifications to a licensee's current method None providing financial assurance occurring since the last submitted report:
7. Material changes to trust agreements: None
1. The NRC formulas in section 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service, and reduce residual radioactivity to levels that permit: (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.
2. By Order dated October 10, 2008 in PUCT Docket No. 35772, NRG South Texas LP was granted approval to establish a separate spent fuel management subaccount. By Order dated July 13, 2009 in PUCT Docket No. 36796, NRG South Texas was granted approval to establish a separate subaccount for pre-shutdown disposal of large components. The amounts allocable to the spent fuel management and pre-shutdown disposal subaccounts are not included in the reported amount. The reported amount includes funds accumulated based upon a site-specific study that includes license termination and other costs.
3. Target amounts to be collected were established by the PUCT-approved separate non-bypassable decommissioning charges established in PUCT Tariff Control No. 31271. Actual collections will vary but the charges are intended to produce the targeted annual collection amounts established in PUCT Docket No. 35772. Collections are being deposited on a priority basis in the large component disposal subaccount, which is expected to be fully funded in 2012. Thereafter, collections will be apportioned between the subaccount (-27.5%) and the primary account for 10CFR50.75(c) costs (-72.5%).

Attachment 1 NOC-AE-1 1002663 Page 3 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONING NRG South Texas LP 13.2% Ownership of South Texas Project Unit 2 Pursuant to 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning on March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor or share of reactor it owns. The requested information is provided below.

1. Minimum decommissioning fund estimate, Total Required: $61,642,350 pursuant to 10 CFR 50.75(b) and (c) 1 :
2. Amount accumulated at the end of the calendar Amount Accumulated 2 : $47,217,439 year preceding the date of the report for items included in 10 CFR 50.75(b) and (c):
3. Schedule of the annual amounts remaining to be Amount Remaining 3: $16,840,502 collected for items in 10 CFR 50.75(b) and (c):

Number of Years to Collect: 18

4. Assumptions used regarding escalation in Escalation Rate: 2.727%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 5.02% - 7.01%

factors used in funding projections:

5. Contracts upon which the licensee is relying The Public Utility Commission of Texas pursuant to 10 CFR 50.75 (e)(1)(ii)(c): (PUCT) approved the Decommission Funds Collections Agreement by and between AEP Texas Central Company (TCC) and NRG South Texas LP in which TCC collects the non-bypassable charges and deposits them directly into the trust.
6. Modifications to a licensee's current method None providing financial assurance occurring since the last submitted report:
7. Material changes to trust agreements: None
1. The NRC formulas in section 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service, and reduce residual radioactivity to levels that permit: (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.
2. By Order dated October 10, 2008 in PUCT Docket No. 35772, NRG South Texas LP was granted approval to establish a separate spent fuel management subaccount. By Order dated July 13, 2009 in PUCT Docket No. 36796, NRG South Texas was granted approval to establish a separate subaccount for pre-shutdown disposal of large components. The amounts allocable to the spent fuel management and pre-shutdown disposal subaccounts are not included in the reported amount. The reported amount includes funds accumulated based upon a site-specific study that includes license termination and other costs.
3. Target amounts to be collected were established by the PUCT-approved separate non-bypassable decommissioning charges established in PUCT Tariff Control No. 31271. Actual collections will vary but the charges are intended to produce the targeted annual collection amounts established in PUCT Docket No. 35772. Collections are being deposited on a priority basis in the large component disposal subaccount, which is expected to be fully funded in 2011. Thereafter, collections will be apportioned between the subaccount (-24.3%) and the primary account for 10CFR50.75(c) costs (-75.7%).

Attachment 1 NOC-AE-1 1002663 Page 4 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONING NRG South Texas LP 30.8% Ownership of South Texas Project Unit 2 Pursuant to 10 CFR 50.75(0(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning on March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor or share of reactor it owns. The requested information is provided below.

1. Minimum decommissioning fund estimate, Total Required: $143,832,150 pursuant to 10 CFR 50.75(b) and (c)1 :
2. Amount accumulated at the end of the calendar Amount Accumulated 2: $122,262,239 year preceding the date of the report for items included in 10 CFR 50.75(b) and (c):
3. Schedule of the annual amounts remaining to be Amount Remaining 3: $10,793,353 collected for items in 10 CFR 50.75(b) and (c):

Number of Years to Collect: 18

4. Assumptions used regarding escalation in Escalation Rate: 2.727%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 5.02% - 7.01%

factors used in funding projections:

5. Contracts upon which the licensee is relying The Public Utility Commission of Texas pursuant to 10 CFR 50.75(e)(1)(ii)(c): (PUCT) approved the Decommission Funds Collections Agreement by and between CenterPoint Energy Houston Electric (CNP) and Texas Genco, LP in which CNP collects the non-bypassable charges and deposits them directly into the trust.
6. Modifications to a licensee's current method None providing financial assurance occurring since the last submitted report:
7. Material changes to trust agreements: None
1. The NRC formulas in section 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service, and reduce residual radioactivity to levels that permit: (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.
2. By Order dated October 10, 2008 in PUCT Docket No. 35772, NRG South Texas LP was granted approval to establish a separate spent fuel management subaccount. By Order dated July 13, 2009 in PUCT Docket No. 36796, NRG South Texas was granted approval to establish a separate subaccount for pre-shutdown disposal of large components. The amounts allocable to the spent fuel management and pre-shutdown disposal subaccounts are not included in the reported amount. The reported amount includes funds accumulated based upon a site-specific study that includes license termination and other costs.
3. Target amounts to be collected were established by the PUCT-approved separate non-bypassable decommissioning charges established in PUCT Tariff Control No. 31271. Actual collections will vary but the charges are intended to produce the targeted annual collection amounts established in PUCT Docket No. 35772. Collections are being deposited on a priority basis in the large component disposal subaccount, which is expected to be fully funded in 2012. Thereafter, collections will be apportioned between the subaccount (-24.3%) and the primary account for 10CFR50.75(c) costs (-75.7%).

ATTACHMENT 2 SOUTH TEXAS PROJECT FINANCIAL ASSURANCE FOR DECOMMISSIONING 2011 UPDATE CITY PUBLIC SERVICE OF SAN ANTONIO

Attachment 2 NOC-AE-1 1002663 Page 1 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONING City Public Service of San Antonio 12% Ownership of South Texas Project Unit I Pursuant to 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning on March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor or share of reactor it owns. The requested information is provided below.

1. Minimum decommissioning fund estimate, Total Required: $56,038,172 pursuant to 10 CFR 50.75(b) and (c)1 :
2. Amount accumulated at the end of the calendar Amount Accumulated 2 : $33,882,358 year preceding the date of the report for items included in 10 CFR 50.75(b) and (c):
3. Schedule of the annual amounts remaining to be Amount Remaining 3 : $0 collected for items in 10 CFR 50.75(b) and (c):

Number of Years to Collect: 17

4. Assumptions used regarding escalation in Escalation Rate: 2.72%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 7.3%

factors used in funding projections:

5. Contracts upon which the licensee is relying None pursuant to 10 CFR 50.75(e)(1)(ii)(c):
6. Modifications to a licensee's current method None providing financial assurance occurring since the last submitted report:
7. Material changes to trust agreements: The Master Trust Agreement was revised effective January 1, 2011, in accordance with a Public Utility Commission of Texas (PUCT) order authorizing transfer of funds from Unit 1 to a spent fuel subaccount to be used only for fuel-related costs incurred after shutdown commences. Additionally, the Master Trust Agreement was revised to allow for creation of a pre-shutdown decommissioning cost subaccount to fund large component replacement and disposal costs.
1. The NRC formulas in 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service, and reduce residual radioactivity to levels that permit: (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. The cost of dismantling or demolishing non-radiological systems and structures is not included in NRC decommissioning cost estimates. The costs of managing and storing spent fuel on site until transfer to the Department of Energy are not included in the cost formulas.
2. By Order dated November 20, 2008 in PUCT Docket No. 35786, CPS Energy was granted approval to establish separate spent fuel management and pre-shutdown activities subaccounts. The amounts allocable to these subaccounts are not included in the reported amount. The reported amount includes funds accumulated based upon a site-specific study that includes license termination and other costs.
3. CPS Energy estimates that the Trust is currently fully funded, based on the 2008 decommissioning cost study and updated escalation rates. Additional contributions ended December 31, 2008. If future estimates indicate that further funding may be required, CPS Energy would be able to exercise its rate setting apply to the PUCT to seek further funding for NRC license termination costs through cost-of-service recovery authorized by Texas law.

Attachment 2 NOC-AE-1 1002663 Page 2 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONING City Public Service of San Antonio 28% Ownership of South Texas Project Unit I Pursuant to 10 CFR 50.75(0(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning on March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor or share of reactor it owns. The requested information is provided below.

1. Minimum decommissioning fund estimate, Total Required: $130,758,676 I pursuant to 10 CFR 50.75(b) and (c)1 :
2. Amount accumulated at the end of the calendar Amount Accumulated2 : $94,429,860 year preceding the date of the report for items included in 10 CFR 50.75(b) and (c):
3. Schedule of the annual amounts remaining to be Amount Remaining 3: $0 collected for items in 10 CFR 50.75(b) and (c):

Number of Years to Collect: 17

4. Assumptions used regarding escalation in Escalation Rate: 2.72%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 7.3%

factors used in funding projections:

5. Contracts upon which the licensee is relying None pursuant to 10 CFR 50.75(e)(1)(ii)(c):
6. Modifications to a licensee's current method None providing financial assurance occurring since the last submitted report:
7. Material changes to trust agreements: The Master Trust Agreement was revised effective January 1, 2011, in accordance with a Public Utility Commission of Texas (PUCT) order authorizing transfer of funds from Unit I to a spent fuel subaccount to be used only for fuel-related costs incurred after shutdown commences. Additionally, the Master Trust Agreement was revised to allow for creation of a pre-shutdown decommissioning cost subaccount to fund large component replacement and disposal costs.
1. The NRC formulas in 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service, and reduce residual radioactivity to levels that permit: (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. The cost of dismantling or demolishing non-radiological systems and structures is not included in NRC decommissioning cost estimates. The costs of managing and storing spent fuel on site until transfer to the Department of Energy are not included in the cost formulas.
2. Consistent with the approach taken for its 12% interest in the Order dated November 20, 2008, in PUCT Docket No.

35786, CPS Energy has established separate spent fuel management and pre-shutdown activity subaccounts. The amounts allocable to these subaccounts are not included in the reported amount. The reported amount includes funds accumulated based upon a site-specific study that includes license termination and other costs.

3. CPS Energy estimates that the Trust is currently fully funded, based on the 2008 decommissioning cost study and updated escalation rates. Additional contributions ended January 31, 2008. If future estimates indicate that further funding may be required, CPS Energy would be able to exercise its rate setting authority to collect and accumulate further funds for NRC license termination costs.

Attachment 2 NOC-AE-1 1002663 Page 3 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONING City Public Service of San Antonio 12% Ownership of South Texas Project Unit 2 Pursuant to 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning on March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor or share of reactor it owns. The requested information is provided below.

1. Minimum decommissioning fund estimate, Total Required: $56,038,172 pursuant to 10 CFR 50.75(b) and (c)1 :
2. Amount accumulated at the end of the calendar Amount Accumulated 2: $35,021,913 year preceding the date of the report for items included in 10 CFR 50.75(b) and (c):
3. Schedule of the annual amounts remaining to be Amount Remaining 3 : $0 collected for items in 10 CFR 50.75(b) and (c):

Number of Years to Collect: 18

4. Assumptions used regarding escalation in Escalation Rate: 2.72%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 7.3%

factors used in funding projections:

5. Contracts upon which the licensee is relying None pursuant to 10 CFR 50.75(e)(1)(ii)(c):
6. Modifications to a licensee's current method None providing financial assurance occurring since the last submitted report:
7. Material changes to trust agreements: The Master Trust Agreement was revised effective January 1, 2011, in accordance with a Public Utility Commission of Texas (PUCT) order authorizing transfer of funds from Unit 2 to a spent fuel subaccount to be used only for fuel-related costs incurred after shutdown commences. Additionally, the Master Trust Agreement was revised to allow for creation of a pre-shutdown decommissioning cost subaccount to fund large component replacement and disposal costs.
1. The NRC formulas in 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service, and reduce residual radioactivity to levels that permit: (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. The cost of dismantling or demolishing non-radiological systems and structures is not included in NRC decommissioning cost estimates. The costs of managing and storing spent fuel on site until transfer to the Department of Energy are not included in the cost formulas.
2. By Order dated November 20, 2008 in PUCT Docket No. 35786, CPS Energy was granted approval to establish separate spent fuel management and pre-shutdown activities subaccounts. The amounts allocable to these subaccounts are not included in the reported amount. The reported amount includes funds accumulated based upon a site-specific study that includes license termination and other costs.
3. CPS Energy estimates that the Trust is currently fully funded, based on the 2008 decommissioning cost study and updated escalation rates. Additional contributions ended December 31, 2008. If future estimates indicate that further funding may be required, CPS Energy would be able to apply to the PUCT to seek further funding for NRC license termination costs through cost-of-service recovery authorized by Texas law.

Attachment 2 NOC-AE-1 1002663 Page 4 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONING City Public Service of San Antonio 28% Ownership of South Texas Project Unit 2 Pursuant to 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning on March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor or share of reactor it owns. The requested information is provided below.

1. Minimum decommissioning fund estimate, Total Required: $130,758,676 pursuant to 10 CFR 50.75(b) and (c)1 :
2. Amount accumulated at the end of the calendar Amount Accumulated 2 : $114,617,695 year preceding the date of the report for items included in 10 CFR 50.75(b) and (c):
3. Schedule of the annual amounts remaining to be Amount Remaining 3: $0 collected for items in 10 CFR 50.75(b) and (c):

Number of Years to Collect: 18

4. Assumptions used regarding escalation in Escalation Rate: 2.72%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 7.3%

factors used in funding projections:

5. Contracts upon which the licensee is relying None pursuant to 10 CFR 50.75(e)(1)(ii)(c):
6. Modifications to a licensee's current method None providing financial assurance occurring since the last submitted report:
7. . Material changes to trust agreements: The Master Trust Agreement was revised effective January 1, 2011, in accordance with a Public Utility Commission of Texas (PUCT) order authorizing transfer of funds from Unit 2 to a spent fuel subaccount to be used only for fuel-related costs Incurred after shutdown commences. Additionally, the Master Trust Agreement was revised to allow for creation of a pre-shutdown decommissioning cost subaccount to fund large component replacement and disposal costs.
1. The NRC formulas in 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service, and reduce residual radioactivity to levels that permit: (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. The cost of dismantling or demolishing non-radiological systems and structures is not included in NRC decommissioning cost estimates. The costs of managing and storing spent fuel on site until transfer to the Department of Energy are not included in the cost formulas.
2. Consistent with the approach taken for its 12% interest in the Order dated November 20, 2008, in PUCT Docket No.

35786, CPS Energy has established separate spent fuel management and pre-shutdown activity subaccounts. The amounts allocable to these subaccounts are not included in the reported amount. The reported amount includes funds accumulated based upon a site-specific study that includes license termination and other costs.

3. CPS Energy estimates that the Trust is currently fully funded, based on the 2008 decommissioning cost study and updated escalation rates. Additional contributions ended January 31, 2008. If future estimates indicate that further funding may be required, CPS Energy would be able to exercise its rate setting authority to collect and accumulate further funds for NRC license termination costs.

ATTACHMENT 3 SOUTH TEXAS PROJECT FINANCIAL ASSURANCE FOR DECOMMISSIONING 2011 UPDATE CITY OF AUSTIN - AUSTIN ENERGY

Attachment 3 NOC-AE-1 1002663 Page 1 of 2 FINANCIAL ASSURANCE FOR DECOMMISSIONING City of Austin - Austin Energy 16% Ownership of South Texas Project Unit I Pursuant to 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning on March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor or share of reactor it owns. The requested information is provided below.

1. Minimum decommissioning fund estimate, Total Required: $74,653,135 pursuant to 10 CFR 50.75(b) and (c)':
2. Amount accumulated at the end of the calendar Amount Accumulated: $49,778,721 year preceding the date of the report for items included in 10 CFR 50.75(b) and (c) 2:
3. Schedule of the annual amounts remaining to be Amount Remaining: $24,874,414 collected for items in 10 CFR 50.75(b) and (c):

Number of Years to Collect: 17

4. Assumptions used regarding escalation in Escalation Rate: 3.964%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 5.073%

factors used in funding projections:

5. Contracts upon which the licensee is relying None pursuant to 10 CFR 50.75(e)(1)(ii)(c)?
6. Modifications to a licensee's current method None providing financial assurance occurring since the last submitted report:
7. Material changes to trust agreements: None
1. The NRC formulas in 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service, and reduce residual radioactivity to levels that permit: (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. The cost of dismantling or demolishing non-radiological systems and structures is not included in NRC decommissioning cost estimates. The costs of managing and storing spent fuel on site until transfer to Department of Energy are not included in the cost formulas.
2. On October 1, 2008, an accounting division of the Decommissioning Trust balance was recorded to reflect the division of costs as referenced in footnote 1.

Attachment 3 NOC-AE-1 1002663 Page 2 of 2 FINANCIAL ASSURANCE FOR DECOMMISSIONING City of Austin - Austin Energy 16% Ownership of South Texas Project Unit 2 Pursuant to 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning on March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor or share of reactor it owns. The requested information is provided below.

1. Minimum decommissioning fund estimate, Total Required: $74,653,135 pursuant to 10 CFR 50.75(b) and (c)1 :
2. Amount accumulated at the end of the calendar Amount Accumulated: $59,107,377 year preceding the date of the report for items included in 10 CFR 50.75(b) and (c) 2:
3. Schedule of the annual amounts remaining to be Amount Remaining: $15,545,758 collected for items in 10 CFR 50.75(b) and (c):

Number of Years to Collect: 18

4. Assumptions used regarding escalation in Escalation Rate: 3.964%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 5.073%

factors used in funding projections:

5. Contracts upon which the licensee is relying None pursuant to 10 CFR 50.75(e)(1)(ii)(c):
6. Modifications to a licensee's current method None providing financial assurance occurring since the last submitted report:
7. Material changes to trust agreements: None
1. The NRC formulas in 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service, and reduce residual radioactivity to levels that permit: (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. The cost of dismantling or demolishing non-radiological systems and structures is not included in NRC decommissioning cost estimates. The costs of managing and storing spent fuel on site until transfer to the Department of Energy are not included in the cost formulas.
2. On October 1, 2008, an accounting division of the Decommissioning Trust balance was recorded to reflect the division of costs as referenced in footnote 1.
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