NOC-AE-19003635, Financial Assurance for Decommissioning 2019 Update

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Financial Assurance for Decommissioning 2019 Update
ML19116A049
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 03/26/2019
From: Harrison G
South Texas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-19003635
Download: ML19116A049 (15)
v • d • e


Text

South Texas Project £/ec/r/c Ge11eral/11g Stat/011 P.Q 80)( 28f) H'.!dsworth, Texas 7748)

U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Units 1 and *2 Docket Nos. STN 50-498, STN 50-499 Financial Assurance for Decommissioning - 2019 Update Pursuant to 10 CFR 50.75(f)(1), STP Nuclear Operating Company (STPNOC) submits the attached status reports regarding funds available, effective December 31, 2018, for decommissioning South Texas Project Units 1 and 2. The data are assembled by the individual co-owners of the South Texas Project:

  • City Public Service Board of San Antonio; and
  • City of Austin - Austin Energy.

The attached reports provide the following information for each co-owner:

  • Estimated amount of decommissioning funds required;
  • Amount accumulated by December 31, 2018;
  • A schedule of the annual amounts remaining to be collected;
  • Assumptions for rates of escalation in decommissioning cost, and for rates used in funding projections;
  • Modifications to method of providing financial fund assurance; and
  • Material changes to trust agreements.

This letter contains no NRC commitments.

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If there are any questions, please contact either Tim Hammons at (361) 972-7347 or me at (361) 972-8074.

George Harrison Executive Vice President and Chief Financial Officer tjh Attachments:

1. South Texas Project Financial Assurance for Decommissioning 2019 Update - NRG South Texas LP
2. South Texas Project Financial Assurance for Decommissioning 2019 Update - City Public Service Board of San Antonio
3. South Texas Project Financial Assurance for Decommissioning 2019 Update- City of Austin

- Austin Energy STI: 34817833

NOC-AE-19003635 Page 2 of 2 cc:

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 E. Lamar Boulevard Arlir)gton, TX 76011-4511 Lisa M. Regner Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North (09E01) 11555 Rockville Pike Rockville, MD 20852 Glen 'Ed' Miller Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North (09E01) 11555 Rockville Pike Rockville, MD 20852 NRC Resident Inspector U.S. Nuclear Regulatory Commission P. 0. Box 289, Mail Code: MN116 Wadsworth, TX 77483

ATTACHMENT 1 SOUTH TEXAS PROJECT FINANCIAL ASSURANCE FOR DECOMMISSIONING 2019 UPDATE NRG SOUTH TEXAS LP

Attachment 1 N OC-AE-19003635 Page 1 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONIN G 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: $53,750,130 pursuant to 10 CFR 50.75(b) and (c) 1:

2 $65,116,672

2. Amount accumulated at the end of the calendar Amount Accumulated :

year preceding the date of the report for items included in 10 CFR 50.75(b) and (c):

3. Schedule of the annual amo.unts remaining to be Amount Remaining 3 : $0 collected for items in 10 CFR 50.75(b) and (c):

Number of Years to Collect: 28.65

4. Assumptions used regarding escalation in Escalation Rate: 2.540%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 2.85% - 6.35%

factors used in funding projections:

5. Contracts u*pon which the licensee is relying None pursuant to 10 CFR 50.75(e)(1)(v):
6. Modifications to a licensee's current method of 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 was granted approval to establish a separate spent nuclear fuel management (SNF) subaccount. By Order dated July 13, 2009 in PUCT Docket No.

36796, NRG South Texas was granted approval to establish a separate subaccount for the pre-shutdown disposal of large components. By Order dated October 7, 2013, NRG South Texas was granted approval to establish a separate subaccount for amounts recovered pursuant to a litigation settlement agreement with the United States government for certain onsite spent fuel storage and management expenses it has incurred and will incur as a result of the failure of the Department of Energy to provide for the offsite disposal of spent nuclear fuel. The amounts allocable to the 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. 41970. Actual collections will vary but the charges are intended to*

produce the targeted annual collection amounts established in PUCT Docket No. 41580. All current collections are being deposited in the large component disposal subaccount.

Attachment 1 NOC-AE-19003635 Page 2 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONING NRG South Texas LP 30.8% 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: $125,416,970 pursuant to 10 CFR 50.75(b) and (c)1:

2 $160,978,956

2. Amount accumulated at the end of the calendar Amount Accumulated :

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: 28.65

4. Assumptions used regarding escalation in Escalation Rate: 2.540%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 2.85% - 6.35%

factors used in funding projections:

5. Contracts upon which the licensee is relying None pursuant to 10 CFR 50.75(e)(1)(v):
6. Modifications to a licensee's current method of 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 Optober 10, 2008 in PUCT Docket No. 35772, NRG South Texas was granted approval to establish a separate spent nuclear fuel management (SNF) subaccount. By Order dated July 13, 2009 in PUCT Docket No.

36796, NRG South Texas was granted approval to establish a separate subaccount for the pre shutdown disposal of large components. By Order dated October 7, 2013, NRG South Texas was granted approval to establish a separate subaccount for amounts recovered pursuant to a litigation settlement agreement with the United States government for certain onsite spent fuel storage and management expenses it has incurred and will incur as a result of the failure of the Department of Energy to provide for the offsite disposal of spent nuclear fuel. The amounts allocable to the 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. 41941. Actual collections will vary. but the charges are intended to produce the targeted annual collection amounts established in PUCT Docket No. 41580. All current collections are being deposited in the large component disposal subaccount.

Attachment 1 NOC-AE-19003635 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 NRG 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: $53,750,130 pursuant to 10 CFR 50.75(b) and (c)1:
2. Amount accumulated at the end of the calendar Amount Accumulated 2 : $78,688,143 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: 29.98

4. Assumptions used regarding escalation in Escalation Rate: 2.530%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 2.85% - 6.35%

factors used in funding projections:

5. Contracts upon which the licensee is relying None pursuant to 10 CFR 50.75(e)(1)(v):
6. Modifications to a licensee's current method of None providing financial assurance occurring since the last submitted report:
7. Material changes to trust agreements: None
1. The NRG 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 was granted approval to establish a separate spent nuclear fuel management (SNF) subaccount. By Order dated July 13, 2009 in PUCT Docket No.

36796, NRG South Texas was granted approval to establish a separate subaccount for the pre-shutdown disposal of large components. By Order dated October 7, 2013, NRG South Texas was granted approval to establish a separate subaccount for amounts recovered pursuant to a litigation settlement agreement with the United States government for certain onsite spent fuel storage and management expenses it has incurred and will incur as a result of the failure of the Department of Energy to provide for the offsite disposal of spent nuclear fuel. The amounts allocable to the 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. 41970. Actual collections will vary but the charges are intended to produce the targeted annual collection amounts established in PUCT Docket No. 41580. All current collections are being deposited in the large component disposal subaccount.

Attachment 1 NOC-AE-19003635 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(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: $125,416,970 pursuant to 10 CFR 50.75(b) and (c) 1:
2. Amount accumulated at the end of the calendar Amount Accumulated 2 : $203,262,434 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: 29.98

4. Assumptions used regarding escalation in Escalation Rate: 2.530%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 2.85% ~ 6.35%

factors used in funding projections:

5. Contracts upon which the licensee is relying None pursuant to 10 CFR 50.75(e)(1)(v):

6.* Modifications to a licensee's current method of None providing financial assurance occurring since the last submitted report:

7. Material changes to trust agreements: None
1. The NRG 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 umestricted 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 was granted approval to establish a separate spent nuclear fuel management (SNF) subaccount. By Order dated July 13, 2009 in PUCT Docket No.

36796, NRG South Texas was granted approval to establish a separate subaccount for the pre-shutdown disposal of large components. By Order dated October 7, 2013, NRG South Texas was granted approval to establish a separate subaccount for amounts recovered pursuant to a litigation settlement agreement with the United States government for certain onsite spent fuel storage and management expenses it has incurred and will incur as a result of the failure of the Department of Energy to provide for the offsite disposal of spent nuclear fuel. The amounts allocable to the 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. 41941. Actual collections will vary but the charges are intended to produce the targeted annual collection amounts established in PUCT Docket No. 41580. All current collections are being deposited in the large component disposal subaccount.

ATTACHMENT 2 SOUTH TEXAS PROJECT FINANCIAL ASSURANCE FOR DECOMMISSIONING 2019 UPDATE CITY PUBLIC SERVICE BOARD OF SAN ANTONIO

Attachment 2 NOC-AE-19003635 Page 1 of 4

. FINANCIAL ASSURANCE FOR DECOMMISSIONING City Public Service Board of San Antonio 12% 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: $48,944,839 pursuant to 10 CFR 50.75(b) and (c)1:
2. Amount accumulated at the end of the calendar Amount Accumulated 2 : $45,237,913 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: 29

4. Assumptions used regarding escalation in Escalation Rate: 2.540%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 5.14%

factors used in funding projections:

5. Contracts upon which the licensee is relying None pursuant to 10 CFR 50.75(e)(1)(v):
6. Modifications to a licensee's current method of None providing financial assurance occurring since the last submitted report:
7. Material changes to trust agreements: No changes since 2017 report was submitted.
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 2018 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 th.rough cost-of-service recovery authorized by Texas law.

Attachment 2 NOC-AE-19003635 Page 2 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONING City Public Service Board of San Antonio 28% 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: $114,204,623 pursuant to 10 CFR 50.75(b) and (c) 1:

2 $120,790,437

2. Amount accumulated at the end of the calendar Amount Accumulated :

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: 29

4. Assumptions used regarding escalation in Escalation Rate: 2.540%

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

factors used in funding projections: 5.14%

5. Contracts upon which the licensee is relying None pursuant to 10 CFR 50.75(e)(1)(v):
6. Modifications to a licensee's current method of None providing financial assurance occurring since the last submitted report:
7. Material changes to trust agreements: No changes since 2017 report was submitted.
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 2018 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 through the City of San Antonio, its rate setting authority, would be able to set rates to collect and accumulate further funds for NRC license termination costs.

Attachment 2 NOC-AE-19003635 Page 3 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONING City Public Service Board 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: $48,944,839 pursuant to 10 CFR 50.75(b) and (c) 1:
2. Amount accumulated at the end of the calendar Amount Accumulated 2 : $60,271,834 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: 30

4. Assumptions used regarding escalation in Escalation Rate: 2.530%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 5.14%

factors used in funding projections:

5. Contracts upon which the licensee is relying None pursuant to 10 CFR 50.75(e)(1)(v):
6. Modifications to a licensee's current method of None providing financial assurance occurring since the last submitted report:
7. Material changes to trust agreements: No changes since 2017 report was submitted.
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 ma.naging 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 2018 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-19003635 Page 4 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONING City Public Service Board 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: $114,204,623 pursuant to 10 CFR 50.75(b) and (c)1:

2 $143,305,943

2. Amount accumulated at the end of the calendar Amount Accumulated :

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: 30

4. Assumptions used regarding escalation in Escalation Rate: 2.530%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 5.14%

factors used in funding projections:

. 5. Contracts upon which the licensee is relying None pursuant to 10 CFR 50.75(e)(1)(v):

6. Modifications to a licensee's current method of None providing financial assurance occurring since the last submitted report:
7. Material changes to trust agreements: No changes since 2017 report was submitted.
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 NRG 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 2018 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 through the City of San Antonio, its rate setting authority, would be able to set rates to collect and accumulate further funds for NRC license termination costs.

ATTACHMENT 3 SOUTH TEXAS PROJECT FINANCIAL ASSURANCE FOR DECOMMISSIONI NG 2019 UPDATE CITY OF AUSTIN - AUSTIN ENERGY

Attachment 3 NOC-AE-19003635 Page 1 of2 FINANCIAL ASSURANCE FOR DECOMMISSIONING City of Austin - Austin Energy 16% Ownership of South Texas Project Unit 1 Pursuant to 1o CFR 50. 75(f)(1 ), each power reactor licensee is required to report to the NRG 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: $65,259,785 pursuant to 10 CFR 50.75(b) and (c)1:
2. Amount accumulated at the end of the calendar Amount Accumulated: $67,161,609 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: $61,016,050 collected for items in 10 CFR 50.75(b) and (c):

Number of Years to Collect: 29

4. Assumptions used regarding escalation in Escalation Rate: 2.517%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 2.5%

factors used in funding projections:

5. Contracts upon which the licensee is relying None pursuant to 10 CFR 50.75(e)(1)(v):
6. Modifications to a licensee's current method of 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.

Attachment 3 NOC-AE-19003635 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: $65,259,785 pursuant to 10 CFR 50.75(b) and (c) 1:
2. Amount accumulated at the end of the calendar Amount Accumulated: $73,927,861 year preceding the date of the report for items included ir:, 10 CFR 50. 75(b) and (c):
3. Schedule of the annual amounts remaining to be Amount Remaining: $51,360,570 collected for items in 10 CFR 50.75(b) and (c):

Number of Years to Collect: 30

4. Assumptions used regarding escalation in Escalation Rate: 2.527%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 2.5%

factors used in funding projections:

5. Contracts upon which the licensee is relying None pursuant to 10 CFR 50.75(e)(1)(v):
6. Modifications to a licensee's current method of None providing financial assurance occurring since the last submitted report:
7. Material changes to trust agreements: None
1. The NRG 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 NRG 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.
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