View source for NOC-AE-07002210, Request for Exemption from 10 CFR 50.82(a)(8)

{{Adams
| number = ML072750459
| issue date = 09/19/2007
| title = Request for Exemption from 10 CFR 50.82(a)(8)
| author name = Sheppard J
| author affiliation = South Texas Project Nuclear Operating Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000498, 05000499
| license number = 
| contact person = 
| case reference number = NOC-AE-07002210, STI: 32205487
| document type = Exemption from NRC Requirements, Letter type:NOC
| page count = 74
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:Nuclear Operating Company South Texas Promed Electric GeneratingStation 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                                                                             /,Z 0 0/

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         A. H. Gutterman, Esq.
U.S. Nuclear Regulatory Commission        Morgan, Lewis & Bockius LLP 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064                  Mohan C. Thadani U.S. Nuclear Regulatory Commission Mohan C. Thadani                          Thad Hill Senior Project Manager                    Steve Winn U.S. Nuclear Regulatory Commission        Harry Holloway One White Flint North (MS 7 D1)           Eddy Daniels 11555 Rockville Pike                      Marty Ryan Rockville, MD 20852                       NRG South Texas LP Richard A. Ratliff                        J. J. Nesrsta Bureau of Radiation Control               R. K. Temple Texas Department of State Health Services Ed Alarcon 1100 West     4 9 th Street               Kevin Polio Austin, TX 78756-3189                     City Public Service C. M. Canady                              C. Kirksey City of Austin                            City of Austin Electric Utility Department 721 Barton Springs Road                   Jon C. Wood Austin, TX 78704                          Cox, Smith & Matthews Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 289, Mail Code: MN116 Wadsworth, TX 77483

ENCLOSURE 1 EXEMPTION REQUEST STI: 32205487

ENCLOSURE 1 EXEMPTION REQUEST

Enclosure 1 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:

Enclosure 1 NOC-AE-0700221 0 Page 2 of 13 Initially, 3 percent of the generic amount specified in &sect; 50.75 may be used for decommissioning planning. For licensees that have submitted the certifications required under &sect; 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

Enclosure 1 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

Enclosure 1 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

Enclosure 1 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)

Enclosure 1 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 - DecommissioningCosts for Power Reactors, CAF and Associates, April 2007.

Enclosure 1 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.

Enclosure 1 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 4
customers. .
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

Enclosure 1 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.

Enclosure 1 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 iffunds 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

Enclosure 1 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.

Enclosure 1 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

Enclosure 1 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 preparedfor STP Nuclear Operating Company preparedby TLG Services, Inc.
Bridgewater, Connecticut May 2004

South Texas ProjectElectric GeneratingStation           Document S30-1499-002, Rev. 0 DecommissioningCost Update                                               Page ii of vi APPROVALS Project Manager Geoffr'y&#xfd;M. GrifAti~s         Date S--' 2,4.6,ve Project Engineer                                                      Date Benjamin J. Stochmal Technical Manager                                                     Date William A. Cloutier Quality Assurance Manager                                             Date (acting)                                Thomas S. La    ardia, P.E.
TLG Services, Inc.

South Texas ProjectElectric GeneratingStation                                              Document S30-1499-002, Rev. 0 Decommissioning Cost Update                                                                                               Pageiii 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 RC Fees ..................................................................................................             8 1.5   Escalation of Other Costs ......................................................................                        9 1.6   Reactor Vessel Disposition Costs .........................................................                             10 1.7   Project Schedule ....................................................................................                  11 1.8   Co-Owners Cost ....................................................................................                    12 1.9   Other Estimating Assumptions ...........................................................                               12
: 2. RESULTS ................................................................................................................       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 Estim 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 Alternative-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 Alternative-U nit 1 ...........................................................................................            B -4 TLG Services, Inc.

South Texas ProjectElectric GeneratingStation                                       Document 830-1499-002, Rev. 0 DecommissioningCost Update                                                                                         Page iv of vi TABLE OF CONTENTS (continued)
PAGE B-2.b AEP Texas Central Co. - Schedule of Annual Expenditures DECON Alternative-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 ProjectElectric GeneratingStation         Document S30-1499-002, Rev. 0 DecommissioningCost Update                                             Page v of vi REVISION LOG F  N.... J       No.      Dat6      i~oi**i Ie ItemRe!se*I[ *or            Revisi'n 0                    5/26/2004                       Original Issue TLG Services, Inc.

South Texas ProjectElectricGeneratingStation              Document 830-1499-002,Rev. 0 DecommissioningCost 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 ProjectElectric GeneratingStation              Document S30-1499-002, Rev. 0 DecommissioningCost Update                                                  Page 1 of20
: 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 ProjectElectric GeneratingStation              Document S30-1499-002, Rev. 0 DecommissioningCost Update                                                   Page2 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 ProjectElectric GeneratingStation                 Document 830-1499-002,Rev. 0 DecommissioningCost Update                                                      Page3 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 GeneratingStation                Document 830-1499-002, Rev. 0 DecommissioningCost Update                                                    Page4 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 ProjectElectric GeneratingStation                  Document S30-1499-002,Rev. 0 DecommissioningCost 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 ProjectElectric GeneratingStation                 Document S30-1499-002, Rev. 0 DecommissioningCost 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 ProjectElectric GeneratingStation                   Document S30-1499-002, Rev. 0 DecommissioningCost Update                                                        Page 7 of20 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 ProjectElectricGeneratingStation                           Document S30-1499-002, Rev. 0 Decommissioning Cost Update                                                              Page8 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 ProjectElectric GeneratingStation                     Document S30-1499-002, Rev. 0 DecommissioningCost 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 ProjectElectric GeneratingStation                  Document S30-1499-002, Rev. 0 DecommissioningCost Update                                                    Page 10 of20 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 ProjectElectric GeneratingStation                 Document S30-1499-002, Rev. 0 DecommissioningCost 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 ProjectElectricGeneratingStation              Document S30-1499-002, Rev. 0 DecommissioningCost 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 ProjectElectric GeneratingStation             Document S30-1499-002, Rev. 0 DecommissioningCost 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 ProjectElectric GeneratingStation                         Document S30-1499-002, Rev. 0 DecommissioningCost Update                                                                Page 14 of 20 TABLE 1.0 SPENT FUEL MANAGEMENT SCHEDULE EX-CORE FUEL ASSEMBLIES*
Unit 1                                               Unit 2 On-Site       ISFSI Inventory         DOE            On-Site       ISFSI Inventory        DOE Year     Inventory  (assemblies) (canisters) Acceptance       Inventory  (assemblies) (canisters) Acceptance 2024         1,669            0           0           87           1,660          0             0          0 2025          1,582           0           0           87           1,649          0             0        87 2026          1,571           0           0           87           1,634          0             0         87 2027          1,677           0           0           87           1,547          0             0        87 2028          1,590         240          10           87           1,653          0            0         87 2029          1,503         480          20           87           1,566        240           10         87 2030          1,416         744          31           87           1,479        480           20         87 2031          1,329         984          41           87           1,392        720           30         87 2032          1,242       1,242          52           87           1,305        960           40         87 2033          1,155       1,155          49           87           1,218       1218           51          87 2034          1,068       1,068          45           87           1,131       1131           48         87 2035            981         981          41           87           1,044       1044           44         87 2036            894         894          38           87             957        957           40         87 2037            807         807          34           87             870        870           37         87 2038            720         720          30           87             783        783           33         87 2039            633         633          27           87             696        696           29         87 2040            546         546          23           87             609        609           26         87 2041            459         459          20           87             522        522           22         87 2042            372         372          16           87             435        435           19         87 2043            285         285          12           87             348        348           15         87 2044            198         198           9           87             261        261           11         87 2045            111         111           5           87             174        174            8         87 2046             24          24           1           87              87         87            4         87 2047              0           0           0           24               0          0            0         87 Total                                              2,025                                                2,001
* Inventories are approximate and reflect projected/estimated quantities TLG Services,Inc.

South Texas ProjectElectric GeneratingStation                          Document 830-1499-002, Rev. 0 DecommissioningCost Update                                                            Page 15 of 20 TABLE 2.0 CO-OWNER DECOMMISSIONING COST ALLOCATIONS Base Case Costs (1998 dollars)
Unit 1 (Note 1)                                            515,465,630 Unit 2 (Note 2)                                           616,283,056 Owner Texas Genco,         AEP Texas               CPS         COA LP (formerly         Central Co.
HL&P)             (formerly CP&L)
Percent Ownership                     30.8%                25.2%            28.0%        16.0%
(Note 3)
Decommissioning Cost            152,863,835          125,070,411       126,204,595  72,116,911 (allocated) (1998 dollars) (10%
contingency) - Unit 1 (Note 4)
Decommissioning Cost            184,080,980          150,611,711       151,278,943 86,445,110 (allocated) (1998 dollars) (10%
contingency)- Unit 2 (Note 5)
Average Reduction                      .2966                .2426            .2448       .1399 (Base Case to Allocated Share) -
Unit 1 (Note 6)
Average Reduction                      .2987                .2444            .2455       .1403 (Base Case to Allocated Share) -
Unit 2 (Note 6)
Note 1: Refer to Appendix C-1 of 1998 TLG report Note  2:   Refer to Appendix C-2 of 1998 TLG report Note  3:   Refer to Appendix E of 1998 TLG report Note  4:   Refer to Appendix E, Tables E-1, E-3, E-5 and E-7 of 1998 TLG report Note  5:   Refer to Appendix E, Tables E-2, E-4, E-6 and E-8 of 1998 TLG report Note  6:   Calculated by ratio of Owner's Cost to Base Case Cost TLG Services, Inc.

South Texas ProjectElectric GeneratingStation               Document S30-1499-002, Rev. 0 DecommissioningCost Update                                                  Page 16 of 20 TABLE 3.1 SCHEDULE OF ANNUAL EXPENDITURES DECON Alternative - Unit 1 (2004 Dollars)
Period 3 Period 1          Period 2             Site            Site Year    Planning       Decommissioning      Restoration      Restoration       Total Offset 2027     40,009,022                      0                0              0     40,009,022 2028    113,943,089                      0                0              0    113,943,089 2029     14,993,215            91,265,205                 0              0    106,258,420 2030                0          9.5,153,173                0              0O    95,153,173 2031                0          79,081,192                 0              0     79,081,192 2032                0          76,963,622                 0              0     76,963,622 2033                0          63,503,463                 0              0     63,503,463 2034                0           7,008,629          835,794               0      7,844,424 2035                0                    0       2,674,366               0      2,674,366 2036                0                    0           65,430     21,114,597     21,180,027 2037                0                    0                0     17,799,013     17,799,013 2038                0                    0                0              0               0 2039                0                    0                0              0               0 2040                0                    0                0              0               0 2041                0                    0                0              0               0 2042                0                    0                0              0               0 2043                0                    0                0              0               0 2044                0                    0                0              0               0 2045                0                    0                0              0               0 2046                0                    0                0              0               0 2047                0                    0                0     17,741,317     17,741,317 2048                0                    0                0              0               0 168,945,326           412,975,284        3,575,590      56,654,926    642,151,127 TLG Services, Inc.

South Texas ProjectElectric GeneratingStation                   Document S30-1499-002, Rev. 0 DecommissioningCost Update                                                       Page17 of20 TABLE 3.2 SCHEDULE OF ANNUAL EXPENDITURES DECON Alternative (Certain Spent Fuel-Related Costs') - Unit 1 (2004 Dollars)
Period 3 Period 1           Period 2               Site             Site Year      Planning      Decommissioning         Restoration       RE*storation       Total Offset 2027       13,342,759                                                                13,342,759 2028       33,070,745                                                                33,070,745 2029         4,256,930            16,738,056                                         20,994,986 2030                              13,848,765                                          13,848,765 2031                               5,044,110                                           5,044,110 2032                               4,242,662                                           4,242,662 2033                                 862,290                                             862,290 2034                                 688,345             367,710                       1,056,054 2035                                                   1,176,593                       1,176,593 2036                                                      28,786        1,175,644      1,204,430 2037                                                                      991,035        991,035 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 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 ProjectElectric GeneratingStation              Document 830-1499-002, Rev. 0 DecommissioningCost Update                                                 Page 18 of 20 TABLE 4.1 SCHEDULE OF ANNUAL EXPENDITURES DECON Alternative - Unit 2 (2004 Dollars)
Post Decommissioning ISFSI Operations Period 1      Period 2          Site      Spent Fuel      ISFSI Year    Planning         D&D        Restoration     Transfer       D&D            Total 2028       4,394,183              0              0             0           0       4,394,183 2029      89,685,306              0              0             0           0      89,685,306 2030      38,994,842     71,392,645              0             0           0    110,387,487 2031               0    104,160,906              0             0           0    104,160,906 2032               0     93,625,142              0             0           0      93,625,142 2033               0     90,772,043              0             0           0      90,772,043 2034               0     79,646,821              0             0           0      79,646,821 2035               0     34,031,434              0             0           0      34,031,434 2036               0        424,836     50,568,116             0           0      50,992,952 2037               0              0     42,627,504       755,284           0      43,382,788 2038               0              0              0    4,307,480            0       4,307,480 2039               0              0              0     4,307,480           0       4,307,480 2040               0              0              0     4,319,281           0       4,319,281 2041               0              0              0     4,307,480           0       4,307,480 2042               0              0              0    4,307,480            0       4,307,480 2043               0              0              0     4,307,480           0       4,307,480 2044               0              0              0    4,319,281            0       4,319,281 2045               0              0              0     4,307,480           0       4,307,480 2046               0              0              0    4,307,480            0       4,307,480 2047               0              0              0   20,951,274   10,689,696      31,640,970 2048               0              0              0             0   5,785,991       5,785,991 2049               0              0              0             0           0               0 133,074,330    474,053,828     93,195,620   60,497,481   16,475,687    777,296,946 TLG Services, Inc.

South Texas ProjectElectricGeneratingStation                      Document S30-1499-002, Rev. 0 Decommissioning Cost Update                                                        Page 19 of 20 TABLE 4.2 SCHEDULE OF ANNUAL EXPENDITURES DECON Alternative (Certain Spent Fuel-Related Costs') - Unit 2 (2004 Dollars)
Post Decommissioning ISFSI Operations Period 1         Period 2           Site        Spent Fuel        ISFSI Year     Planning           D&D         Restoration        Transfer        D&D            Total 2028        1,466,299                                                                      1,466,299 2029      23,361,411                                                                      23,361,411 2030        7,550,303       23,801,499                                                    31,351,802 2031                        16,800,152                                                    16,800,152 2032                         7,406,180                                                     7,406,180 2033                         5,120,152                                                     5,120,152 2034                         2,697,964                                                     2,697,964 2035                         2,894,415                                                     2,894,415 2036                            75,852       3,207,957                                     3,283,810 2037                                         2,704,218          755,284                    3,459,502 2038                                                         4,307,480                     4,307,480 2039                                                         4,307,480                     4,307,480 2040                                                         4,319,281                     4,319,281 2041                                                         4,307,480                     4,307,480 2042                                                         4,307,480                     4,307,480 2043                                                         4,307,480                     4,307,480 2044                                                         4,319,281                     4,319,281 2045                                                         4,307,480                     4,307,480 2046                                                          4,307,480                    4,307,480 2047                                                          3,209,958   10,689,696      13,899,653 2048                                                                       5,785,991       5,785,991 2049 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 ProjectElectric GeneratingStation                           Document S30-1499-002, Rev. 0 Decommissioning Cost Update                                                             Page 20 of 20 FIGURE 1 TIMELINE OF EVENTS Unit 1 (Shutdown August 20, 2027)
Period 1                                           Period 3 Transition and               Period 2 Site Preparations           Decommissioning              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 I
Unit 2 (Shutdown December 15, 2028)
Period 1                                        Period 3 Transition and                Period 2               Site                ISFSI            ISFSI Preparations           Decommissioning        I RP..Qtnrqinn          Operations 12/2028                   06/2030                  01/2036          10/2037                 09/2047 03/2048 Storage Pool Empty 02/2034 TLG Services, Inc.

South Texas ProjectElectric GeneratingStation                                       Document S30-1499-002, Rev. 0 DecommissioningCost Update                                                                    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 ProjectElectricGeneratingStation                                                                                                                            DocumentS30-1499-002, Rev. 0 DecommissioningCost Update                                                                                                                                                   Appendix A, Page2 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                                              118       17.7            135       135 2 Notification of Cessation of Operations                                                                 Note 1 3 Remove fuel & source material                                                                           Note 2 4 Notification of Permanent Defueling                                                                     Note I 5 Deactivate plant systems & process waste                                                                Note 1 6 Prepare and submit PSDAR                                                              181      27.2             208       208 7 Review plant dwgs & specs.                                                            417      62.5             479       479 8 Perform detailed red survey                                                                             Note 1 9 Estimate by-product Inventory                                                          91       13.6            104       104 10 End product description                                                                91       13.6            104       104 11 Detailed by-product inventory                                                         118       17.7            135       135 12 Define major work sequence                                                            680      102.0            782       782 13 Perform SER and EA                                                                    281      42.1             323       323 14 Perform Site-Specific Cost Study                                                      453      68.0             521       521 15 Prepare/submit Ucense Termination Plan                                                371      55.7             427       427 16 Receive NRC approval of termination plan                                                                Note 1 Activity Specifications 17.1 Plant & temporary facilities                                                           446      66.9             513       462                51 17.2 Plant systems                                                                          378      56.6             434       391                43 17.3 NSSS Decontamination Flush                                                              45       6.8              62        52 17.4 Reactor Internals                                                                      643      96.5             740       740 17.5 Reactor vessel                                                                         589    " 88.4             677       677 17.6 Biological shield                                                                       45       6.8              52        52 17.7 Steam generators                                                                       283      42.4             325       325 17.8 Reinforced concrete                                                                    145      21.8             167        83                83 17.9 Turbine & condenser                                                                     73       10.9             83                          83 17.10 Plant structures & buildings                                                           283      42.4             325       163              163 17.11 Waste management                                                                       417      62.5             479       479 17.12 Facility & site ctoseout                                                                82       12.2             94        47                47 17 Total                                                                               3,428      514.3          3.943     3,472              471 Planning & Site Preparations 18 Prepare dismantling sequence                                                          218      32.6             250       250 19 Plant prep. & temp. svces                                                           2308       346.2          2,654     2,654 20 Design water clean-up system                                                          127       19.0            146       146 21 Rigging/CCEs/tooling/stc.                                                           1,954      293.1         2.247      2,247 22 Procure casksliners & containers                                                      111       16.7            128       128 TLA Services, Inc.

South Texas ProjectElectric GeneratingStation                                                                                                                                           DocutentS3-1499-002, Rev. 0 Decommissioning Cost Update                                                                                                                                                                  Appendix A, Page3 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                                                                               429      64.3              493        444                    49 23.2 NSSS Decontamination Flush                                                                    91      13.6              104       104 23.3 Vessel head                                                                                 227      34.0              261        261 23.4 Reactor Internals                                                                           227      34.0              261        261                  -
23.5 Remaining buildings                                                                         122       18.4              141          35                106 23.6 CRD cooling assembly                                                                          91      13.6              104       104                  -
23.7 CRD housings & ICItubes                                                                       91      13.6              104       104 23.8 Incore instrumentation                                                                        91      13.6             104        104 23.9 Reactor vessel                                                                              329      49.3              378        378 23.10 Facility closeout                                                                            109       16.3             125           63                  63 23.11 Missile shields                                                                                41      6.1                47          47 23.12 Biological shield                                                                            109       16.3             125        125 23.13 Steam generators                                                                             417      62.5              479        479                  -
23.14 Reinforced concrete                                                                            91      13.6              104          52                  52 23.15 Turbine & condensers                                                                         283      42.4              325         -                  325 23.16 Auxiliary building                                                                           247      37.1              285        256                    28 23.17 Reactor building                                                                             247      37.1              285        256                    28 23 Total                                                                                    3.239              486      3,725      3,074                 652 24 Devon primary loop                       987                                                -        493.6        1480.8     1480.8                    -                                           800 Period I Additional Costs 25 Site Characterization Survey                                                              1,692             508      2,200      2,200 26 Severance Plan                                                                          21,404            3.211     24,615     24,615 Subtotal Period 1 Activity Costs                   987                                            37,282            6.340     44,609     43,486               1,123                                          800 Period I Undlitrlbuted Costs                      656 1 Decon equipment                                                                                               98      754        754 2 Deson supplies                           40                                                                   10        49         49 3 DOC staff relocation expenses                  1,192                                                       179      1,371      1,371 4 Process liquid waste                    149               543    545      3,030                            968      5,235      5,235                                   6,990                      313 5 Insurance                                                                                1,715             171      1,886        681       1,305 6 Property taxes                                                                          6,206               -       6,206      5.628         578 7 Health physics supplies                          249                                                          62      311        311 8 Heavy equipment rental                           274                                                          41      316        316 9 Small tool allowance                               0                                                           0         0           0 10 Disposal of DAWgenerated                                  330      12     1,114                            313      1,769      1,769                        4,031                              10,965 11 Plant energy budget                                                                     3.395              509      3,904      3,904 12 ISFSI Cask Purchase                                                                    23,200            3,480     26,680                26,680 TLG Services, Inc.

South Texas ProjectElectricGeneratingStation                                                                                                                                          Document S30-1499-002, Rev. 0 Decommissioning Cost Update                                                                                                                                                                 Appendix A, Page4 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                                                                      4,124              819    4,742               4,742 14  ISFSI transfer equipment                                                                       609               91     700                 700 15  ISFSI licensing and permits                                                                  1,218              122   1,339               1,339 16  NRC Fees.                                                                                      572               57     629       629 17  Emergency Planning Fees                                                                          92               9     101                 101 18  Site Security Cost                                                                          2,119              318    2,437     2,437        -
19  Spent Fuel Pool O&M                                                                          1,496             224    1,720               1.720 20  Spent Fuel Pool Isolation                                                                   8,358            1.254    9.612               9,612 21  Spent Fuel Transfer Costs                                                                    3.384             508    3,892               3,892 Subtotal Undiasuibuted Costs Period 1              844     1.716        874     557     4,144        56,487            9,034   73.655    22,985    50,670            4,031      6.990                    11,278 Staff Costs DOC Staff Cost                                                                              8.163            1,224    9,387     9,387 Utilty Staff Cost                                                                          35,908            5,386   41,294    41,294 TOTAL PERIOD I COST                              1,831     1,716        874     557     4,144       137,840           21,984  168,945   117,152    50,670   1,123    4,031      6,990                    12,078 PERIOD 2 Nuclear Steam Supply System Removal 27.1 Reactor Coolant Piping                    115       221         14       18      683                            287    1,338     1.338                      1,575                               12.733 27.2 Pressurizer Relief Tank                     16       90           6       6      298                            107      522       522                        6688                               4,129 27.3 Reactor Coolant Pumps & Motors             53        44         35      29     2.426                            652    3,237     3,237                      5,596                                4.114 27.4 Pressurizer                                 17       24           4       8      889                            238    1.179     1,179                      2,050                                1,685 27.6 Steam Generators                          223     3,157      2.058     947     9.115         3,422            4.041   22,964    22,964                     21.027                               24,566 27.6 Old Steam Generator Lower Shell Units                30      1,709     824     8,892         3,137            2.996   17,587    17.587                     20,512                               14,878 27.7 CRDMs/ICIs/Service Structure Removal       76        53         74      16     1.605            -               462    2,287     2,287                      3,703                                4,717 27.8 Reactor Vessel Internals                   66     2.047      5.503     494     4,785                          5,460   18.356    18,356                      2,003        788    459             16,207 27.9 Reactor Vessel                              51    3,706      1,475     372     8,830            -             7,681   22,115    22.115                      7,178      2,629    -               31.297 27 Totals                                    617     9,372    10,877    2,711    37,524         6,559           21,924   89.585    89,585                     64,333      3,417    459            114,325 28 Remove spent fuel racks                   335        30          14       3    1.654         3,816            1,163    7.016     7.016                      3,816         --                    14,170 Removal of Major Equipment 29 Main Turbine/Generator                               73                                                           11      84                           84                                        3,298 30 Main Condensers                                     384                                                           58     441                         441                                        16,323 TLG Services; Inc.

South Texas ProjectElectricGenerating Station                                                                                                                                             Document 830-1499-002, Rev. 0 DecommissioningCost Update                                                                                                                                                                     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 NRC        Spent     Site              LLW site        GTCC Craft Laborl lNfumbei             Activity Descrintion         Decon     Renmove    Pack     Shin     Burial       Other       Contineencv  Total    LicTer. Fuel Met. Restore    A CF      B CF    C CF   CF      a-ou-s Disposal of Plant Systems 31.1 Auxiliary Feedwater (AF)                     -           46                                                        7       53                               53                                      2,145 31.2 Auxiliary Feedwater (AF) RCA                    2          5                                                       2        9           9                                                              310 31.3 Auxiliary Steam & Boilers (AS)                            37                                                      .5       42                               42                                      1,754 31.4 Auxiliary Steam & Boilers (AS) RCA              7         14                                                       5       26          26                                                              899 31.5 BOP Chemical Feed (CF)                                    15                                                       2       17                               17                                         687 31.6 BOP Diesel Generator (DB)                                 16                                                       2       18                               18                                         734 31.7 Bornn Recycle (BR)                           -          306       13        7.      619            124          252    1,320      1.320                          1,428                             11,635 31.8 Breathing Air (BA) RCA                         28         58                                                      23      108       108                                                             3.291 31.9 Chemical & Volume Control (CV)              742         716       21       12     1,078            129          843    3,541      3.541                          2,486                             54.061 31.10 Chilled Water HVAC (CH)                                   77                                                       12       88        -                      88     -                                3,589 31.11 Chilled Water HVAC (CH) RCA                  109         258                                                       93     460        460                                                            15,455 31.12 Circulating Water (CW)                                   198                                                       30     227                             227                                        9,450 31.13 Circulating Water Screen Wash (SC)                        29                                                        4       34                               34                                      1,361 31.14 Closed Loop Auxillary Cooling Water (AC)                  52                                                        8       59        -                      59                                      2,456 31.15 Component Cooling Water (CC) RCA             422         884                                                     344    1,650      1.00w                                                            51.670 31.16 Condensate (CD)                              -           336                                                      50      385                             386                                       15.922 31.17 Condensate Polisher (CP)                                 135                                                      20       155                            155                                        6.304 31.18 Condensate Storage (CT)                                   29                                                        4       33                               33                                      1,316 31.19 Condenser Air Removal (CR)                                28                                                        4       32                               32                                      1,321 31.20 Containment Building (XC)                                 85        0        0          2             15          24       126       126                              5                              3,236 31.21 Containment Building HVAC (HC)                         2,036       11        6       520          1,914          928    5,415      5,415                          1,200                            68,174 31.22 Containment Combustible Gas Control (CG                   24        0        0          2             13            8       47          47                            5                                915 31.23 Containment Hydrogen Monitoring (CM)                     124         1      .1        50             39           50      264        264                   -        116                              4,737 31.24 Containment Spray (CS)                         49         38                                                      30      116           74                   44                                      3,676 31.25 Control Room HVAC (HB) Clean                  -            87                                                      13      100        -                   100                                        3,945 31.26 Dernineralizer Water (DW)                                 24                                                        4       28        -                      28                                      1.156 31.27 Demlneralizer Water (DW) RCA                   30         63                                                     25       117       117                                                             3,705 31.28 Diesel Generator Building (XG)                              5                                                       1        6                                6                                        235 31.29 ECW & ECW Screen Wash (EW)                              305                                                      46      351         -                   351                                       14,693 31.30 ECW & ECW Screen Wash (EW) RCA                 99       167                                                      75      341        341                                                            10.664 31.31 Electrical Auxiliary Building (XE)                       47                                                        7       05        -                      55                                      2,038 31.32 Electrical Auxiliary Building HVAC (HE)                 179                                                      27      206                             206                                        8,079 31.33 Electrical Clean Non RCA                                479                                                      72      551                             551 22,327 31.34 Electrical Clean RCA                        248         901                                                     259    1,409      1,409                                                           44.307 31.35 Electrical Contaminated                      -          391                         254            144          184      981        981                  -         586        -    -              15,215 31.36 Electlro-Hydraulic Controls (EH)                         20                                                        3       23                               23                                        918 31.37 Extracton Steam (ES)                                     84                                                       13       97                               97                                      4,067 31.38 Feedwater (FW)                                          178                                                       27     205                             205                                        8,503 31.39 Feedwater (FW) RCA                              7         13                                                       5       25          25                                                             782 31.40 Fire Protection (FP)                                      56                                                       8       64        -                      64                                      2,695 31.41 Fire Protection (FP) RCA                       36         73                                                      29      139       139                      0                                      4.372 TLG Services, Inc.

South Texas ProjectElectricGeneratingStation                                                                                                                                                 Document S30-1499-002, Rev. 0 Decommissioning Cost Update                                                                                                                                                                       Appendix A, Page6 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)                             51        0       0        13              6             17        87           87                              30                              1,951 31.A3 Fuel Handling Building HVAC (HF)                       940        3       1       119            773            381    2,216       2,216                               275                            32,316 31.44 Gas Storage C02 & H2 (CO/HY)                              1                                                        0         1        -                                                                    36 31.45 Gaseous Waste Processing (WG)                          116        1       1        65             56             54       292        292                               149                             4,332 31.46 Generator C02 & H2 (GG)                                   7                                                        1         8                                8                                           336 31.47 Generator Hydrogen Seal Oil (SO)                          7                                                        1        8                                 8                                           321 31.48 Heater Drip&Vent (HD/HV)                               143                                                       21       164                            164                                           6,841 31.49 Hot Shop & Decontamination Facility (XN)                32        0       0         4             13             11        61           61                -             10                              1,237 31.50 Instrument Air (IA)                                    119                                                       18       137         -                  137                                           5,593 31.51 Integrated Leak Rate Test (IL)                         149        0       0        16             40             47      252         252                  -             36                             5,774 31.52 Isolation Valve Cubicle Building (XV)                     2                                                        0        3         -                      3                                             96 31.53 Liquid Waste Processing (WL)               1.131     1,058       18      10       896            875          1,189    5.177       5,177                            2,067                             79,318 31.54 Low Pressure Nitrogen (NL)                              16                                                        2        18         -                     18                                            739 31.55 Lube Oil Purification Strg & Trnsfr (LO)                24                                                        4        26         -                     28                                          1,114 31.56 MAB Plant Vent Header (VE)                                8       0       0         6             24              7        46           46                              14                                320 31.57 Main Generator (GE/GM/NN)                               12                                                         2       14         -                     14                                            547 31.58 Main Steam (MS)                                        246                                                       37      287          -                  287                                          11,924 31.59 Main Steam (MS) RCA                            11       20                                                        9        40           40                                                             1,251 31.60 Main Turbine & Lube Oil (LT/TM)                         46                                                        7        52         -                     52                                         2.119 31.61 Mechanical Audfiary Bldg HVAC (HM) RCA     4,472     1,075                                                    2,397    7,944      7.944                                                              212.684 31.62 Mechanical Aurdliary Butding (XM).           -         200        0       0         4             36             56      297         297                  -             10                             7.612 31.63 Miscellaneous Drains (MD)                                 2                                                       0         2                                2                                             72 31.64 Miscellaneous HVAC (HZ)                                 92                                                       14      106                             106                                           4,224 31.65 Miscellaneous HVAC (HZ) RCA                  230        sO                                                      122      402        402                                                               10,730 31.66 Miscellaneous Reactor Coolant (RC)                     730       31      16     1.414            167            567    2.924      2,924                             3.262                             28,443 31.67 Miscallaneous Yard Areas & Bidgs (XY)                   75                                                       11        86        -                      86                                         3.635 31.68 Nonradioactive Chemical Waste (NC)                        2                                                       0         2                                2                                             85 31.69 Nonradioactive Dms & Srnps (DR)                         61                                                        9        70                               70                                         2,954 31.70 Nonradioactive Dms & Smps (DR) RCA             56      126                                                       47      229        229                                                                7,713 31.71 Oily Waste (OW)                                         99                                                       15      114         -                   114                                           4,782 31.72 Open Loop Ausiliary Cooling (OC)                       236                                                       35      271                             271                                          11,422 31.73 Plant Fuel Oil Storage & Transfer (FO)                    0                                                       0         0                                0                                             14 31.74 Post Accident Monitor/Sample (AM/AP)                   265        0       0        13             85             82      446        446                  -              31                            10,282 31.75 Potable Water (PW)                                        6                                                       1         7                                                                            316 31.76 Potable Water (PW) RCA                         13       30                                                       11        54           54                              27                             1,787 31.77 Primary Process Sampling (PS)                           41        0       0        12             12             15        80          80                       -      27        -     -               1,564 31.78 Radiation Monitoring (RA)                       7       43                                                       10        60           10                  50                                         2.234 31.79 Radioactive Vents & Drains (ED)              760       716       14       7       651            116            741    3,005      3,005                             1,501                             53,749 31.80 Reactor Coolant Pump OilChange-Out (P0       -           13       0       0         5             26              8        53          63                               12                               50 31.81 Reactor Head Degassing (RD)                             54        1       1        64             30             34      184         184                              147                              2.066 31.82 Reactor Makeup Water (RM)                              266        2       1        90            234            124      717         717                              208                             10,263 TL. Services, Inc.

South Texas ProjectElectricGeneratingStation                                                                                                                                                 Document 830-1499-002, Rev. 0 DecommissioningCost Update                                                                                                                                                                        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)                            357        32       18     1,586           167             517      2,678      2,678                         3,659                              13,936 31.84 SG Sludge Lancing & Chem Cleaning (SL)                  1                                                          0           1          1                                                                36 31.85 Safety Injection (SI)                                 931        62       35     3,068         1,044           1,168      6,309      6,309                         7,078                              36,194 31.86 Secondary Process Sampling (SS)                        29                                                          4          34                              34     -                                 1,365 31.87 Service Air (SA)                                       61                                                          9          71                              71                                       2.890 31.88 Service Water (T'W)                                    11                                                          2          12                              12                                         509 31.89 Sewage Treatment (ST)                                  23                                                          3          26                              26                                       1,101 31.90 Sodium Hypochiorlte (SH)                               10                                                          1          11                              11                                         438 31.91 Solid Waste Processing (WS)                  41        39          1       1        60            25              49        216         216                          140                               2,994 31.92 Spent Fuel Pool Cooling & Cleanup (FC)                328        21       12     1,028          2,3              381      2Z028      2.028                         2,371                              12,786 31.93 Standby DG Fuel Oil Strg & Tmsfr (DO)                  26                                                          4          30                              30                                       1.193 31.94 Standby Diesel Gen Starting Air (SD)                   12                                                          2          14                              14                                         553 31.95 Standby Diesel Generator (DG)                          89                                                         13        103                             103                                        4.186 31.96 Standby Diesel Generator Bldg HVAC (HG)                56                                                          8          65                              65                                       2,545 31.97 Standby Diesel Generator Lube Oil (LU)                  5                                                          1           6                               6                                         236 31.98 Standby Diesel Jacket Water (JW)                        4                                                          1           4                               4                                          172
                                                                                                                                                               -9             -
31.99 Stator Cooling Water (GC)                               8                                                          1           9                                                                         370 31.100 Steam Generator Blowdown (SB)                          68                                                         10          78                              78                                       3.137 31.101 Steam Generator slowdown (SB) RCA            22        41                                                         17          80         80                                                            2.434 31.102 Turbine Generator Building (XI)                        18                                                          3          21                              21                                         785 31.103 Turbine Generator Building HVAC (HT)                  208                                                         31        239                             239                                        9.382 31.104 Turbine Gland Seal (GS)                                16                                                          2          19                              19                                         749 31 Totals                                    8,522    18.141       238      133    11,639        6,364           11.888     59.926     51 .882                ,5044  26.850                           1,044,086 Decontamlnation of Site Buildings 32.1 Reactor                                     795       466       111       64     3.314           632           1.458      6.840      6.840                  -     11,820                              46,051 32.2 Fuel Handling                               463       411       .42       22     1,104           364             673      3,079      3.079                  -      3,778                              32,978 32.3 Mechanical & Electrical Auxiliary           847       103        67       39     1,048           291             767      3.163      3,163                         7,345                              33,545 32 Totals                                    2,105       981       220      125     5,466        1.287            2.898     13.082     13,082                        22,943                             112,574 33 Terminate license                                                                                                    Note 1 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 ProjectElectric GeneratingStation                                                                                                                                                     DocumentS30.1499-002, Rev. 0 Decommissioning Cost Update                                                                                                                                                                            Appendix A, Page8 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                              656                                                                         98      754       754 2 Decon supplies                             1,197                                                                      299     1,497      1,497 3 DOC staff relocation expenses                -         1,192                                                          179     1,371      1.371 4 Process liquid waste                         867         -          465     718      2,818                          1.292     6,159      6,159                                    6,500                        992 5 Insurance                                                                                           1,678             168     1,845      1.734       11             -                 -
6 Property taxes                                                                                     15,199              -     16.199     11,537     2.142    1,520 7 Health physics supplies                             -  5,352                                                        1,338     6,690      6,90         -        -
8 Heavy equipment rental                                11,211                                                        1.682    12.892     11,603              1,289 9 Small lool allowance                                     488                                                             73      561       505                   56 10 Pipe cutting equipment                                    913                                                          137     1,050      1,050                 -
11 Deown rig                                   1,186-                                                                     178     1,364      1,364 12 Disposal of DAW generated                                         1.224        50     4,765                          1,321     7.360      7,360                         17,249                              40.613 13 Decommissioning Equipment Disposition                                  5        3       248            346             116       717        717                            572                                 778 14 Plant energy budget                                                                                 13,747           2,062    15,809     14,229              1,581          -
15 NRC Fees                                                                                             2,466             247     2,712      2.712                -
16 Emergency Planning Fees                                                                                342                34     376         -        376 17 Site Security Cost                                                                                   5,074             761     5.835      5,835 18 LLRW Processing Equipment                                                                              975             146     1.121      1.121        -
19 ISFSI Cask Purchases                                                                                18,400           2,760    21,160         -    21.160 20 Spent Fuel Pool O&M                                                                                  3,665             550     4,214                4,214 2`1 Spent Fuel Transfer                                                                                11.670           1,751    13,421               13,421 Subtotal Undistributed Costs Period 2                3,906      19,156      1.694     772      7.831         73,560          15,190   122,108     76,238   41,424     4,446      17,821     6,500                    42,383 Staff Costs DOC Staff Cost                                                      -       -           -          36,610           5,491    42,101     42,101        -       -            -         -
UtilityStaff Cost                                                                                --62,523           9,378    71,902     71,902 TOTAL PERIOD 2                                      15,485      48,136    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 PERIOD 3 Demolition of Remaining Site Buildings 35.1 Reactor                                                4,652                                                          698     5.350        803              4,548                                          99,608 36.2 Diesel Generator                                         634                                                            95      730                           730                                          10.947 35.3 Fuel Handling                                          2.062                                                          309     2,372        237              2,134                                          38,456 35.4 isul Valve Cubicle & Aux Fdwtr Stug Tnk                  535                                                             80     616                           616                                          11,338 35.5 Mechanical & Electrical Auxiliary                      4,943                                                          741     5,685        568              5,116                                          92.031 35.6 Tank Pads & Foundations                                  234                                                             35     269                           269                                           6,163 35.7 Transformer Pads                                         251                                                             38     288                           288                                           6.370 T7l Services, Inc.

South Texas ProjectElectric GeneratingStation                                                                                                                                        Document S30.1499-002,Rev. 0 DecommissioningCost Update                                                                                                                                                                 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 rounding Columns may not add due to                                                                                                  NRC        Spent      Site           LLW site         GTCC Craft Labor IlNumbei              Activitv Description          Decon Remove    Pack Shin      Burial       Other        Continmenev    Total    LieTerm     Fuel Mgt. Restor-   A CF    I CF V        CF   V CFW      n.rs Demolition of Remaining Site Buildings (continued) 35.8 Turbine Generator                                   2,302             -                      -345                   2,647                      -     2,647      -            - -     -        67,161 35.9 Turbine Generator Pedestal                            611              -       - -            -92                      703        -703                          -            * -     -        10.798 35 Totals                                             16,226            -         --                         2.434    18,659      1,608           -    17.051      -           -  -     -       342,872 Site Closeout Acilvties 36 Grade & landscape site                              1,720                                                   258      1.978        -                  1,978                                     8,697 37 Final report to NRC                                                                          141               21      163        163          -
38 GTCC Disposal                                                                            15.427           2,314    17.741     17,741                                                 679 Subtotal Period 3 Activity Costa                            17.945                                15,569           5,027    38,541     19.512                19,029                     -     679     351,569 Period 3  Undtstrlbuted Costs 1  Insurance                                                                                  465                46      511                   511        -
2  Property taxes                                                                           3.166              -      3,166                  1,210     1,956 3  Heavy equipment rental                             3,331                                                   500     3.831                     -      3,831 4  Smal tool allowance                                  121                                                      18      140                              140 5  Plant energy budget                                                                        402                60     462                     -        462 6  NRC ISFSI Fees                                                                             500                50     551                    551        -
7  Emergency Planning Fees                                                                    193                19    .212                    212        -
8  Site Security Cost                                                                       1,412             212     1,624                     -      1,624 9  Spent Fuel Transfer                                                                      1.092             164     1,256                  1,.256 Subtotal Undistributed Costs Period 3                        3,452                                 7,230           1,070    11.752                 3,740      8,012 Staff Costs DOC Staff Cost                                                                           5     0881        882     6,763                     -      6,763
                                                                          - -           -2,760 UtilityStaff Cost                                                                                          414     3,174      2,857          -        317 TOTAL PERIOD 3                                             21,398                                 31,440           7,393    60,231     22,369      3,740    34,122                      -     679     351,569 TLG Services, Inc.

South Texas ProjectElectricGeneratingStation                                                                                                                                                                                        Document S30-1499-002, Rev. 0 DecommissioningCost Update                                                                                                                                                                                                              Appendix A, Page10 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 NEC      Spent     Site            LLW site         GTCC   Craft Labori INtumebe             Activity Description                    Decon        Remove             Pack             Ship        Burial           Other         Contingency         Total   LibTerm   Fuel Met. Restore  A CF      B CF     C CF   CF      Hours TOTAL COST TO DECOMMISSION                                    17,316         71,249              13,918        4,301      68,258             367,806           99,302       642,151   501,057    95,834   45A260 139,794    16,907    459   679    1,831,604 Total cost to decommission with                       18.29% oontingency'. $      642,151,127 Total NRC license termination cost Is                78.03%         or       $    501,057,150 Non-nuclear demolition cost Is                         7.05%        or       $     45,259,548 Spent Fuel Management                                 14.92%        or       $     95,834,429 Total LLW site radwaste volume buried                                                 157,160   cubic feet Total I0CFR61 greater than class C waste buried                                            679  cubic feet Total scrap metal released from South Texas Project Unit 1                              33.033  tons Total craft labor requirements                                                      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 ProjectElectricGeneratingStation                                                                                                                         Document S30-1499-002, Rev. 0 DecommissioningCost Update                                                                                                                                              Appendix A, Page11 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                                               50           8        68       58 2 Notification of Cessation of Operations                                                                  Note 1 3 Remove fuel & source material                                                                            Note 2 4 Notification of Permanent Defueling                                                                      Note I 5 Deactivate plant systems & process waste                                                                 Note 1 6 Prepare and submit PSDAR                                                               78          12        89       89 7 Review plant dwgs & specs.                                                            178          27       205      205 8 Perform detailed red survey                                                                              Note 1 9 Estimate by-product Inventory                                                          39           6        45       45 10 End product description                                                                39           6        45       45 11 Detailed by-product Inventory                                                          50           8      *58        58 12 Define major work sequence                                                            291          44       334      334 13 Perform SER and EA                                                                    120          18       138      138 14 Perform Site-Specific Cost Study                                                      194          29       223      223 15 Prepare/submit License Termination Plan                                               159          24       183      183 16 Receive NRC approval of termination plan                                                                 Note I Acivity Specifications 17.1 Plant & temporary facilities                                                          191          29       219      197                 22 17.2 Plant systems                                                                         161          24       186      167                  19 17.3 NSSS Decontamination Flush                                                              19          3        22       22 17.4 Reactor Internals                                                                     275          41       316      316 17.5 Reactor vessel                                                                        252          38       290      290 17.6 Biological shield                                                                       19          3        22       22 17.7 Steam generators                                                                      121          18       139      139 17.8 Reinforced concrete                                                                    62           9        71       36                 36 17.9 Turbine & condenser                                                                    31           5        36                          36 17.10 Plant structures & buildings                                                          121          18       139       70                 70 17.11 Waste management                                                                      178          27       205      205 17.12 Facility & site closeout                                                               35           5        40       20                 20 17 Total                                                                               1.466         220     1,686    1,484                201 Planning & Site Preparations 18 Prepare dismantling sequence                                                           93          14       107      107 19 Plant prep. & temp. svces                                                           2,308         346     2,654    2,654 20 Design water clean-up system                                                           54           a        62       62 21 Rlgglng/CCEsltooting/etc.                                                           1,954         293     2,247    2,247 22 Procure casks/liners & containers                                                      48           7        55       55 TLG Services, Inc.

South Texas ProjectElectric GeneratingStation                                                                                                                                     Document 830-1499-002, Rev. 0 Decommissioning Cost Update                                                                                                                                                            Appendix A, Page12 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                                                                             183            28     211         190                     21 23.2 NSSS Decontaminatlon Flush                                                                 39             6       45          45 23.3 Vessel head                                                                                97            15     111          ItI 23.4 Reactor internals                                                                         97            15     111         111 23.5 Remaining buildings                                                                       52             8       60           15                   45 23.6 CRD cooling assembly                                                                      39             6       45          45 23.7 CRD housings & ICItubes                                                                   39             6       45          45 23.8 Incore instrumentation                                                                    39             6       45          45 23.9 Reactor vessel                                                                           141            21     162         162 23.10 Facility doseout                                                                           47             7       53          27                    27 23.11 Missile shields                                                                             17            3       20           20 23.12 Biological shield                                                                          47             7       53           53 23.13 Steam generators                                                                          178            27     205        205 23.14 Reinforced concrete                                                                        39             6       45          22                    22 23.15 Turbine & condensers                                                                      121            18     139          -                    139 23.16 Auxiliary building                                                                        106            16     122         110                     12 23.17 Reactor building                                                                          106            16     122         110                     12 23 Total                                                                                   1,385           208   1,593      1,314                    279 24 Decon primary loop                      987                                                             494   1,481      1,481                                                                     800 Period I Additional Costs 25 Site Characterization Survey                                                            1,692           508   2-200      2,200 26 Severance Plan                                                                        21,404         3,211  24,615     24,615 Subtotal Period 1 Activity Costs                  987                                            31,602         5,488  38,076     37,596                    480                                              800 Period I Undsrbilbuted Costs                      656 1 Deaon equipment                                                                                         98     754        754 2 Decon supplies                          40                                                              10       49          49 3 DOC staff relocation expenses                 1,192                                                    179   1,371      1,371 4 Process liquid waste                   149                543     545      3,183                     1,006   5,426      5,426           -                             6,990                       313 5 Insurance                                                                              1,715           171   1,886        581        1,305 6 Property taxes                                                                         6,139                 6,139      5,561          578 7 Health physics supplies                         249                                                     62     311        311          -
8 Heavy equipment rental                          274                                                     41     316        316 9 Small tool allowance                               0                                                     0        0            0 10 Disposal of PAWgenerated                                  330       12     1,114                       313   1,769      1,769                            4,031                                 10,965 11 Plant energy budget                                                                    4,944           742   5,686      5.686 12 ISFSI Cask Purchase                                                                   10,400         1,560  11,960          -       11,960 13 ISFSI site alterations                                                                 4,124           619   4,742         -         4.742 TLG Services, Inc.

South Texas ProjectElectric GeneratingStation                                                                                                                                          Document 830-1499-002, Rev. 0 DecommissioningCost Update                                                                                                                                                                   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                                                                        609           91       700                 700 15 ISFSI licensing and permits                                                                   1,218          122     1,339               1.339 16 ISFSI O&M                                                                                        70             7       77.                   77 17 NRC Fees                                                                                        572           57       629        029 18 Emergency Planning Fees                                                                          92             9      101         -       101 19 Site Security Cost                                                                              975          146     1,121      1,121 20 Spent Fuel Pool O&M                                                                            1,496          224     1,720         -     1,720 21 Spent Fuel Pool Isolation                                                                      5,572          83      6,408               6,408 22 Spent Fuel Transfer                                                                            2,997          449     3,446         -     3,446 Subtotal Undistributed Costs Period 1              844     1,716          874       557      4,297      40,923        6,744    55,954     23,576   32,378                4,031        6,990                     11,278 Staff Costs DOC Staff Cost                                                 -         -          -         5.807          871     6,678      6,678       -
UbtlityStaff Cost                                                        -          -        28,144        4,222    32.365     32.365
!TOTAL PERIOD I COST                              1,831     1,716          874       857      4,297     106,475       17.324   133,074   100,216    32,378         480    4,031        8,990                     12,078 PERIOD 2 Nuclear Steam Supply System Removal 27.1 Reactor Coolant Piping                     98     190            12        16       590                      248     1,153      1.153                         1,361                                  10,880 27.2 Pressurizer Relief Tank                    16       90            6         6       298                      107       622        522                           688                                   4,129 27.3 Reactor Coolant Pumps & Motors             53      44            35        29     2,426                      652     3,237      3,237                         5,596                                   4,115 27.4 Pressurizer                                17      24             4         8       889                      238     1,179      1,179                         2,050                                   1,684 27.5 Steam Generators                        223     3,157        2,058       947      9,115       3,422        4.041    22,964     22,964                        21,027                                  24,566 27.6 Old Steam Generator Lower Sheo Units     -          30       1,709       824      8,892       3,137        2.996    17,587     17,587                        20,512                                  14.878 27.7 CRDMs/CIa/ServIce Structure Removal        76       53           74        16     1,605                      462     2,287      2,287                         3,703                                   4,717 27.8 Reactor Vessel Internals                   66   2.047        5.503       494      4,771                    5,453    18,335     18,335                         2,003          788    459              29,692 27.9 Reactor Vessel                             51   3,706        1.475       372      8,736                    7.634    21,973     21.973                         7,178        2Z629                     29,692 27 Totals                                  601     9,341       10.875     2,709     37,323       6,559       21,830    89.238     89,238                        64,119        3,417    459             124,353 28 Remove spent fuel racks                 335         30           14         3     1,654       3,815        1,163     7,016      7,016                         3,816           -     -       -        14,170 Removal of Major Equipment 29 Main Turbine/Generator                   -          73                                                         11       84                              84                                            3,298 30 Main Condensers                                   384                                                         58       441                             441                                           16,323 7L Services, Inc.

South Texas ProjectElectricGeneratingStation                                                                                                                                     Document S30-1499-002, Rev. 0 DecommissioningCost Update                                                                                                                                                          Appendix A, Page14 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)                         -    61                                                   9       70                               70                                           2.852 31.2 Auxiliary Feedwater (AF) RCA                   5        9                                                  4        17          17                                                                 523 31.3 Auxiliary Steam & Boilers (AS)                        84                                                  13       97                               97                                           3,985 31.4 Auxiliary Steam & Boilers (AS) RCA             3        5                                                  2         9           9                                                                 286 31.5 BOP Chemdcal Feed (CF/AD/CA)                          27                                                   4       31                               31                                           1,285 31.6 SOP Dlesal Generator (DB)                             18                                                   3       21                               21                                             852 31.7 Bonn Recycle (BR)                                    312       12        7       575         125        243     1,273     1,273                           1,326                                 11,843 31.8 Breathing Air (BA)                                    18                                                   3       21         -                     21                                             840 31.9 Breathing Air (BA) RCA                         3        6                                                  2        11          11                                                                 356 31.10 Chemical & Volume Control (CV)              614      638       19      11        988         128        736     3.134     3,134                           2,278                                 46.284 31.11 Chilled Water HVAC (CH)                               82                                                 12        94        -                      94                                           3,815 31.12 Chilled Water HVAC (CH) RCA                 132      258                                                105       495       495                                                                 15,433 31.13 Circulating Water (CW)                               385                                                 58       443        -                    443                                           18,541 31.14 Circulating Water Screen Wash (SC)                    59                                                   9       68                               68                                           2,764 31.15 Closed Loop Auxiliary Cooling Water (AC)              53                                                   8       61                               61                                           2,541 31.16 Component Cooling Water (CC) RCA            279      293                                                184       756       756                                                                 24,485 31.17 Condensate (CD)                                      290                                                 44       334           17                317                                           13,742 31.18 Condensate Polisher (CP)                             131                                                 20       150                             150                                            6,112 31.19 Condensate Storage (CT)                               31                                                   5       36                               36                                           1,429 31.20 Condenser Air Removal (CR)                            31                                                   5       35                               35                                           1,456 31.21 Containment Building (XC)                            725.       2        1        75         441        266     1,510     1,510                             174                                 25,371 31.22 Containment Building HVAC (HC)                     1,732       12        6       556       1.689        827    4,822      4,822                           1,281                                 58,382 31.23 Containment Combustible Gas Control (CG)              24        0        0          2         13           8       47          47                             4                                    933 31.24 Containment Hydrogen Monitoring (CM)                 124        1        1        50          37         49       262       262                             115                                  4,727 31.25 Containment Spray (CS)                        50      39                                                 31       119          74                  45                                            3,712 31.26 Control Room HIAC (HB) Clean                          81                                                 12        93        -                     93                                            3.671 31.27 Demineralizer Building HVAC (HW)                       9                                                   1       10                               10                                             408 31.28 Demineralizer Water (DW)                             208                                                 31       239                             239                                            9.631 31.29 Demlneralizer Water (DW) RCA                   4       9                                                   3       17           17                                                                 525 31.30 Diesel Generator Building (XG)                         8                                                   1       10                               10                                             375 31.31 ECW & ECW Screen Wash (EW)                           298                                                 45       342                             342                                           14,248 31.32 ECW & ECW Screen Wash (EW) RCA                84     143                                                 63       290       290                                                                  9,058 31.33 Electrical Auxiliary Building (XE)                    85                                                 13        98                              98                                            3,789 31.34 Electrical Auxiliary Building HVAC (HE)              189                                                 28       217                             217                                            8,538 31.35 Electrical Clean Non RCA                             715                                                107       822        -                    822                                           33,307 31.36 Electrical Clean RCA                        320    1,331                                                360    2,012      2,012                                                                 63,735 31.37 Electrical Contaminated                     -        668        8       4        357         193        287     1,517     1,517                            824                                  25,967 31.38 Electro-Hydraulic Controls (EH)                       15                                                  2        17                               17                                             697 31.39 Essential Cooling Pond Makeup (EP)                    23                                                   3       26                              26                                            1,075 31.40 Essential Cooling Pond Makeup (EP) RCA        23      41                                                 17        81          81                                                                2,479 31.41 Extraction Steam (ES)                                 84                                                 13        96                              96                                            4,027 TLG Services, Inc.

South Texas ProjectElectricGeneratingStation                                                                                                                                       DocumentS30-1499-002, Rev. 0 DecomnissioningCost Update                                                                                                                                                            Appendix A, Page16 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)                                           195                                                  29       225                          225                                           9,288 31.43 Feodwater (FW) RCA                             7          12                                                   5       24         24                                                                755 31.44 Fire Protection (FP)                                    173                                                  26       198                          198                                           8,155 31.45 Fire Protection (FP) RCA                      21         40                                                  16        77         77                                                             2,416 31.46 Fresh Water Supply (SW)                                  37                                                    6       43                            43                                          1.751 31.47 Fuel Handling Building (XF)                              21           0     0          3                       7       34         34 3                                                            7                                    80O 31.48 Fuel Handling Building HVAC (HF)                      1,027        3        1       129         836         415     2.411    2,411                           297                                35,438 31.49 Gas H2 Storage (HY)                                        1                                                   0        1                                                                            34 31.50 Gas N2 High Pressure Supply (NH)                           0                                                   0        0                             0                                              17 31.51 Gaseous Waste Processing (NG)                           122        1        1        65          57          55       300      300                           149                                 4,637 31.52 Generator CO2 & H2 (GG)                                   10                                                   2       12       -                    12                                            469 31.53 Generator Hydrogen Seat Oil (SO)                          18                                                   3       20                           20                                             819 31.54 Heater Drip & Vent (HD/HV)                              177                                                  27       203                          203                                           8,456 31.55 Hot Shop & Decontamination Fadcily (XN)                  37        0        0        10          19          14        80         80                          22                                 1,405 31.56 Instrument Air (IA)                                     134                                                  20       155       -                  155                                           6,353 31.57 Integrated Leak Rate Test (IL)                          151        0        0        24          47          51       274      274                            56                                 5,843 31.58 IsolaSton Valve Cubicle Building (XV)                      4                                                   1        5                             5                                             183 31.59 Lighting Diesel Generator (DL)                             5                                                   1        6                             6                                            233 31.60 Liquid Waste Processing (WL)              1,110       1,019       17       10       830         852       1,148    4,985     4,985                         1,916                                77.196 31.61 Low Pressure Nitrogan (NL)                               41                                                    6       47       -                   47                                           1,967 31.62 Lube Oil Purification Strg &Tmsfr (LO)                   36                                                    6       41                           41                                           1,674 31.53 MAB Plant Vent Header (VE)                              322        2        1        86         281         144       836      836                           198                                10.791 31.64 Main Generator (GE/GM/NN)                                 13                                                   2       15                            15                                            583 31.65 Main Steam (MS)                                         191                                                  29       220                          220                                           9.155 31.66 Main Steam (MS) RCA                            9          15                                                   7       30         30                                                               949 31.67 Main Turbine & Lube Oil (LT/TM)             -            63                                                    9       72       -                   72                                           2908 31.68 Mechanical Auxiliary Bldg HVAC (HM) RCA  4,134          986                                               2,215    7,335     7.335                                                             196,311 31.69 Mechanical Auxiliary Building (XM)          -           235        0        0          9         60          70       375      375                            22                                 8,852 31.70 Miscellaneous Drains (MD)                                30                                                    5       35                           35                                           1,428 31.71 Miscellaneous HVAC (HZ)                                 113                                                  17       131                          131                                           5.175 31.72 Miscellaneous HVAC (HZ) RCA                   78          17                                                 41       136      136                                                               3,633 31.73 Miscellaneous Reactor Coolant (RC)                      699       31       16     1,430         168         563    2.907     2.907                         3.298                                27,237 31.74 Miscellaneous Yard Areas & Bldgs (XY)            -    1,518                                                 228     1.746                        1,746                                          70.842 31.75 Nonradioactive Chemical Waste (NC)                       79                                                  12        91      -                    91                                           3,734 31.75 Norvadloactlve Dms & Smps (DR) RCA            75        138                                                  58       272      272                                                               8,460 31.77 Nonradloactive Plumbing Dms & Smps (DR)                  66                                                  10        76      -                    76                                           3,175 31.78 Oily Waste (OW)                                    -    140 22       170                          170                                           7,114 31.79 Open Loop Auxiliary Cooling (OC)                        125                                                  19       143                          143                                           5,960 31.80 Plant Fuel Oil Storage & Transfer (FO)                   41                                                    6       47                           47                                           1,921 31.81 Post Accident Monitor/Sample (AM/AP)                    374        0        0        17         112         115       619      619                            40                                14,480 31.82 Potable Water (PW)                                       51                                                    8       59                           59                                           2,452 TLG Services, Inc.

South Texas Project ElectricGeneratingStation                                                                                                                                                Document S30-1499-002, Rev. 0 Decommissioning Cost Update                                                                                                                                                                     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 NRC         Spent    Site                  LLW site           GTCC    Craft Labor
'D                                                 I*
Decan  . 1RAmn*A Remove     Pack       Ship      Burial     Other     Contingency  Total    LicTerm     Fuel Mgt Restore     A CF          B CF     C CF     CF      Hoursl Number                 Activit Desert tion Disposal of Plant Systems (continued) 31.83 Potable Water (PW) RCA                          12          25                                                    10        46          46                                                                   1.496 31.84 Primary Process Sampling (PS)                 -       . 40         0         0        10           12          14        77          77                              23                                   1,531 31.85 Radiation Monitoring (RA)                         8 "       56                                                    12        77          12                   65       -                                      2,885 31.86 Radioactive Vents & Drains (ED)               772         718        14         7       648         111          747    3,019      3,019                           1,496                                   54,381 31.87 Reactor Coolant Pump Oil Change-Out (PO)                    13        0         0          5          26            8       63          53                              12                                     500 31.88 Reactor Head Degassing (RO)                                 63        1         1        67           31          37      201        201                             156                                     2,395 31.89 Reactor Makeup Water (RM)                                 290         2         1        88         252          132      765        765                             202                                    11.207 31.90 Residual Heat Removal (RH)                                345        31        17     1,527          166         499    2,585      2,585                           3,523                                    13,478 31.91 SO Sludge Lancing & Chem Cleaning (SL)                       0                                                      0        0        -                       0       -                                           8 31.92 Safety Injection (SI)                                   1,198        65       36      3.153       1,086        1,262    6,798      6.798                           7,274                                   46,584 31.03 Secondary Process Sampling (SS)                            26                                                       4       30        -                      30       -                                      1,212 31.94 Service Air (SA)                                            82                                                    12        94                               94                                              3.902 31.95 Service Water (TW)                                         45                                                       7       52        -          -           52                                              2,145 31.96 Sewage Treatment (ST)                                       50                                                      7       57                               57                                              2.412 31.97 Sodium Hypochlorite (SH)                                    81                                                    12        93                               93       -                                      3,787 31.98 Solid Waste Processing (WS)                     41         38         1         1        60           25          49      215        215                             139                                     2,978 31.99 Spent Fuel Pool Cooling & Cleanup (FC)                    311        20       11        952         235          355    1,883      1,883                           2,197                                   12,108 31.100 Standby DG Fuel Oil Strg & Tmsfr (DO)                      26                                                      4        30       -                       30       -                                      1,166 31.101 Standby Diesel Gen Starting Air(SD)                         12                                                      2       13                               13                                                534 31.102 Standby Diesel Generator (DG)                              82                                                     12        94                               94                                              3,831 31.103 Standby Diesel Generator Bldg HWAC(HG)                     57                                                       9       66                               66                                              2,595 31.104 Standby Diesel Generator Lube Oil (LU)                       3                                                      0        3                                3                                                124 31.105 Standby Diesel Jacket Water (JW)                             3                                                     0         4                                4                                                146 31.106 Stator Cooling Water (GC)                                    4                                                      1        4                                4                                                175 31.107 Steam Generator Blowdown (SB)                              40                                                       6       46                   -           46                                              1,907 31.108 Steam Generator Blowdown (SB) RCA               23         43                                                     18        84         84                                                                    2,618 31.109 Turbine Generator Building (XT)                            77                                                     12        89       -                       89                                              3,516 31.110 Turbine Generator Building HVAC (HT)                      217                                                     33      249                             249                                                9.786 31.111 Turbine Gland Seal (GS)                                     20                                                      3       22                               22                                                903 31.112 Well Water Supply (WW)                                    188                                                     28      216        -                    216                                                8,883 31 Totals                                      7,805      21,974       241      134     11,718       7,005       12,347   61,225    62,776                 8,449     27.031                                1,186.227 Decontamination of Site Buildings 32.1 Reactor                                      795         466       111       64      3.314         632        1.458    6,840      6.840                   -      11,820                                   46,051 32.2 Fuel Handling                                463         411        42       22      1.104         364          673    3,079      3,079                           3,778                                   32,978 32.3 Mechanical & Electrical Auxiliary            847         103        67       39      1,048         291          767    3.163      3,163                           7,345                                   33,545 32 Totals                                     1.729         805       181      103      8.581         901        2,898   13,082     13,082                          22,943                                  112,574 33 Terminate license                                                                                                      Note 1 TW Services, Ine.

South Texas ProjectElectric GeneratingStation                                                                                                                                       Document 830-1499-002, Rev. 0 Decommissioning Cost Update                                                                                                                                                              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                                                                    7,875        2.362   10,237    10,237                                                               121.892 Subtotal Period 2 Activity Costs                  10.470   32,607      11.312    2,949     59,278      26,155       40.670  181,323  172,349                8,974   117,909        3.417   459            1,578,837 Period 2 Undistributed Costs 1 Decon equipment                          656       -          -        -           -                         98     754       754 1,198       -                                                       299    1,497     1,497 2 Decon supplies 3 DOC staff retocaton expenses                     1,192                  -                                    179   1,371     1,371 4 Process liquid waste                      861                  458      710      2,776          -         1,277    6,082     6.082                                      6,405                        984 1,681           168                         111 5 Insramnce                                                               -                                          1,849     1,738 6 Property taxes                                                                              13,808                13,808    10,280     2,147     1,381 7 Health physics supplies                          5,801                                                    1,450    7,251     7,251 11,238                                                    1,686   12.923    11,631               1,292        -
8 Heavy equipment rental 9 Small tool allowance                               533                                                        80     613       552                  611 10 Pipe cutting equipment                             913                                                      137    1,050     1.050 11 Decon rig                               1,186                                                               178. 1,364     1.364 12 Disposal of DAW generated                                    1,227        51     4,836          -         1,339    7,462     7,452                        17.505                                  40,711 13 Decommissioning Equipment Disposition                            5         3       248         405          124      786       786                           572                                     778 14 Plant energy budget                                                                         19.206        2,881   22,087    19,878               2.209       -
15 ISFSI O&M                                                                                      392            39     431        -        431 16 NRC Fees                                                                                     2.472          247    2.719     2,719 17 Emergency Planning Fees                                                                        342            34     377        -        377 18 Site Security Cost                                                                           7.878        1,182    9,059     8,606       453 19 LLRW Processing Equipment                                                                      927          139    1,060     1,066 20 ISFSI Cask Purchase                                                                         30.400        4.560   34,960              34,960 21 Spent Fuel Pool O&M                                                                          3.662          549    4,211               4,211 22 Spent Fuel Transfer                                                                         11.714        1,757   13,471              13,471 Subtotal Undtabibuted Costs Period 2               3.901   19,878       1,690      764      7,860      92,886       18,404  146,180    84,076    56,161     4,943    18.077        6,405                     42,473 Staff Costs                                                                                           46.653        6,998   53,651    53,651 DOC Staff Cost UtilityStaff Cost                                                                          81,652       12,248   93,900   91,265      2.635 TOTAL PERIOD 2                                   14,371   52,284      13,002    3,712     67,136     247,346       78,319  474,054  401,340     58,796    13,917   135,986        9,822   459            1,621.310 TLG Services, Inc.

South Texas ProjectElectric GeneratingStation                                                                                                                                     Document S30-1499-002, Rev. 0 DecommissioningCost Update                                                                                                                                                           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                                          4,652                                                   698   5.350        803               4,548                                            99,608 35.2 Basins                                              85                                                    13       98                              98                                           1.021 35.3 Circulating Water Intake & Discharge             3,985                                                   598   4,583                          4.583                                            53.943 35.4 Diesel Generator                                   634                                                    95     730                            730                                            10.947 35.5 Essential Cooling Pond/Intake/Discharge            639                                                    96     735                            735                                            10,712 35.6 Fuel Handling                                    2,062                                                   309   2,372        237               2.134                                            38,456 35.7 Isol Valve Cubicle & Aux Fdwtr Strg Tnk            535                                                    80     616                            616                                            11,338 35.8 Maintenance Operations Facility                    376                                                    56     432                            432                                             8,479 35.9 Mechanical & Electrical Auxiliary                4.943                                                   741   5,685        568               5.116                                            92,031 35.10 Miscellaneous Slabs, Foundations & Pads            913                                                   137   1,050                          1,050                                            19,844 35.11 Miscellaneous Yard Buildings                     1,995                                                   299   2,295                          2,295                                            44,016 35.12 Nuclear Support Center                             486                                                    73     558                            558                                            11,701 35.13 Nuclear Training Facility& Annex                   282                                                    42     324                            324                                             7.203 35.14 Sewage Treatment Plant                              56                                                     8       65                              65                                             671 35.15 Steam Generator Mausoleum                          266                                                    40     305                            305                                             4,131 35.16 Tank Pads & Foundations                            235                                                    35     270                            270                                             6,183 35.17 Transformer Pads                                   263                                                    40     303                            303                                             6,678 35.18 Trenches & Culverts                              1,122                                                   168   1.290                          1.290                                            25.578 35.19 Turbine Generator                                2.302                                                   345   2,647                          2.647                                            67,161 35.20 Turbine Generator Pedestal                         611                                                    92     703                            703                                            10,798 35.21 Warehouses                                       2.316                                                   347   2,664                          2.664                                            45.588 3522 Yard Piping                                          91                                                    14     105                            105                                             1,279 35 Totals                                          28,852                                                 4,328  33,180      1,608              31.572                                           577.366 Site Closeout Activities 36 Remove Rubble                                    1,184                                                   178   1,361                          1,361                  -  -    -        -         2.326 37 Grade & landscape site                           2,497                                                   375   2,872                          2,872                 -   -    -        .        12,627 38 Final report to NRC                                                                          60            9       70        70                  -
Period 3 Additional Costs 39 ISFSI License Termination                       2.449      161        70      5,385      2,607        2,376  13,049               13,049               12,422                                 63,467 40 ISFSI Demolition and Site Restoration            1,503                                      270          416   2,190                2,190                                                       6.701 41 Firing Range Restoration                             8                 17         49                      16       90                              90 42 Reservoir Restoration                                                                   22,162        3,324  25,486                         26,486 43 GTCC Disposal                                                                15,427                   2,314  17,741     17,741                                                       679 Subtotal Period 3 Activity Costa                          36,493      161        87    20,861      25,100       13,336  96,039     19,419    15.239    61,381     12,422               -        679     662,488 T7W Services, Inc.

C South Texas ProjectElectricGeneratingStation                                                                                                                                                                                        DocumentS30-1499-002, Rev. 0 Decommissioning Cbst Update                                                                                                                                                                                                              Appendix A, Page19 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                                                                                                                             1,671          167           1,838               1,838        -
2 Property taxes                                                                                                                       9,341                         9,341              8,800         741 3 Heavy equipment rental                                               3,331                                                              -            500           3,831                  -      3,831 4 Small tool allowance                                                    202                                                             -             30             232                            232 5 Plant energy budget                                                                                                                   1,025          154           1,179                 -       1,179 6 ISFSI O&M                                                                                                                               825          124             948                 948        -
7 NRC ISFSI Fees                                                                                                                       3,558           356           3,914              3,914 8 Emergency Planning Fees                                                                                                              1,331           133           1.464              1,464         -
9 Site Security Cost                                                                                                                   6,735         1,010           7.746              7,228         518 10 Spent Fuel Transfer                                                                                                                   7.843         1,176           9.019              9,019         -
Subtotal Undistributed Costs Period 3                                           3.533                                                          32.329         3,650         39,512              33,011      6,501 Staff Costs DOC Staff Cost                                                                                                                       9,985         1,498         11,482       -                 11,482 UtilityStaff Cost                                                                                                                   20,118         3.018         23.135     3,928    16,894      2,314 TOTAL PERIOD 3                                                        -       40,026                     161          87      20,861           87,531        21 501        170,169    23,347    65,144     81,678    12,422                         6-79     662,488 TOTAL COST TO DECOMMISSION                                        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 Total cost to decommission with                        17.75% contingency $          777,296,8946 Total NRC license termination cost is                  67.53%        or      $       524,903,585 Non-nuclear demolition cost is                         12.36%        or      $        96,075,107 Spent Fuel Management                                  20.11%                $       156,318,253 169,710 cubic feet Total LLWsite radwasta volume buried Total I0CFR61 greater than class C waste buried                                               679 cubic feet Total scrap metal released from South Texas Prole ct Unit 2                                40,869 tons Total craft labor requirements                                                         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 ProjectElectric GeneratingStation                                                     Document S30-1499-002, Rev. 0 DecommissioningCost 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 ProjectElectric GeneratingStation              Document S30-1499.002, Rev. 0 DecommissioningCost Update                                      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         Period 2             Site            Site Year     Planning    Decommissioning        Restoration     Restoration        Total Offset 2027      11,866,676                    0                0               0     11,866,676 2028      33,795,520                    0                0               0     33,795,520 2029       4,446,988           27,069,260                0               0     31,516,247 2030               0           28,222,431                0               0     28,222,431 2031               0           23,455,482                0               0     23,455,482 2032               0           22,827,410                0               0     22,827,410 2033               0           18,835,127                0               0     18,835,127 2034               0            2,078,759          247,897               0      2,326,656 2035               0                    0          793,217               0        793,217 2036               0                    0           19,407      6,262,589       6,281,996 2037               0                    0                0      5,279,187       5,279,187 2038               0                    0                0               0               0 2039               0                    0                0              0                0 2040               0                    0                0               0               0 2041               0                    0                0              0                0 2042               0                    0                0              0                0 2043               0                    0                0              0                0 2044               0                    0                0              0                0 2045               0                    0                0              0                0 2046               0                    0                0              0                0 2047               0                    0                0      5,262,074       5,262,074 2048               0                    0                0              0                0 50,109,184          122,488,469        1,060,520     16,803,851     190,462,024 TLG Services, Inc.

South Texas ProjectElectric GeneratingStation             Document S30-1499-002, Rev. 0 DecommissioningCost Update                                       Appendix B, Page3 of 9 TABLE B-l.b TEXAS GENCO, LP - SCHEDULE OF ANNUAL EXPENDITURES DECON Alternative - Unit 2 (2004 Dollars, 10% Contingency)
Post Decommissioning ISFSI Operations Period 1      Period 2          Site      Spent Fuel       ISFSI Year    Planning         D&D        Restoration     Transfer       'D&D           Total 2028       1,303,315              0              0             0            0      1,303,315 2029      26,600,662              0              0             0            0     26,600,662 2030      11,565,870     21,175,059              0             0            0     32,740,929 2031               0     30,894,125              0             0            0     30,894,125 2032               0     27,769,217              0             0            0     27,769,217 2033               0     26,922,988              0             0            0     26,922,988 2034               0     23,623,247              0             0            0     23,623,247 2035               0     10,093,723              0             0            0     10,093,723 2036               0        126,006     14,998,503             0            0     15,124,510 2037               0              0     12,643,318       224,017            0     12,867,335 2038               0              0              0     1,277,599            0      1,277,599 2039               0              0              0     1,277,599            0      1,277,599 2040               0              0              0     1,281,099            0      1,281,099 2041               0              0              0     1,277,599            0      1,277,599 2042               0              0              0     1,277,599            0      1,277,599 2043               0              0              0     1,277,599            0      1,277,599 2044               0              0              0     1,281,099            0      1,281,099 2045               0              0              0     1,277,599            0      1,277,599 2046               0              0              0     1,277,599            0      1,277,599 2047               0              0              0     6,214,148    3,170,564      9,384,712 2048               0              0              0             0    1,716,125      1,716,125 2049               0              0              0             0            0              0 39,469,846    140,604,365     27,641,821    17,943,553    4,886,689   230,546,274 TLG Services,Inc.

South Texas ProjectElectric GeneratingStation              Document 830-1499-002, Rev. 0 DecommissioningCost Update                                      Appendix B, Page4 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         Period 2             Site            Site Year     Planning     Decommissioning       Restoration     Restoration        Total Offset 2027       9,706,189                    0                0              0       9,706,189 2028      27,642,593                    0                0              0      27,642,593 2029       3,637,354           22,140,939                0              0      25,778,293 2030                0          23,084,160                0              0      23,084,160 2031                0          19,185,097                0              0      19,185,097 2032                0          18,671,375                0              0      18,671,375 2033                0          15,405,940                0              0      15,405,940 2034                0           1,700,293         202,764               0       1,903,057 2035                0                   0         648,801               0         648,801 2036                0                   0           15,873      5,122,401       5,138,275 2037                0                   0                0      4,318,041       4,318,041 2038                0                   0                0              0                0 2039                0                   0                0              0                0 2040                0                   0                0              0                0 2041                0                   0                0              0                0 2042                0                   0                0              0                0 2043                0                   0                0              0                0 2044                0                   0                0              0                0 2045                0                   0                0              0                0 2046                0                   0                0              0                0 2047                0                   0                0      4,304,043       4,304,043 2048                0                   0                0              0                0 40,986,136          100,187,804         867,438      13,744,485     155,785,863 TLG Services, Inc.

South Texas ProjectElectric GeneratingStation             Document S30-1499-002, Rev. 0 Decommissioning Cost Update                                      Appendix B, Page5 of 9 TABLE B-2.b AEP TEXAS CENTRAL CO. - SCHEDULE OF ANNUAL EXPENDITURES DECON Alternative - Unit 2 (2004 Dollars, 10% Contingency)
Post Decommissioning ISFSI Operations Period 1      Period 2          Site      Spent Fuel       ISFSI Year    Planning         D&D        Restoration     Transfer        D&D           Total 2028       1,066,029              0              0             0            0      1,066,029 2029      21,757,655              0              0             0            0     21,757,655 2030       9,460,149     17,319,856              0             0            0     26,780,004 2031               0     25,269,436              0             0            0     25,269,436 2032               0     22,713,460              0             0            0     22,713,460 2033               0     22,021,298              0             0            0     22,021,298 2034               0     19,322,319              0             0            0     19,322,319 2035               0      8,256,026              0             0            0      8,256,026 2036               0        103,065     12,267,825             0            0     12,370,890 2037               0              0     10,341,433       183,232            0     10,524,664 2038               0              0              0     1,044,995            0      1,044,995 2039               0              0              0     1,044,995            0      1,044,995 2040               0              0              0     1,047,858            0      1,047,858 2041               0              0              0     1,044,995            0      1,044,995 2042               0              0              0     1,044,995            0      1,044,995 2043               0              0              0     1,044,995            0      1,044,995 2044               0              0              0     1,047,858            0      1,047,858 2045               0              0              0     1,044,995            0      1,044,995 2046               0              0              0     1,044,995            0      1,044,995 2047               0              0              0    5,082,779     2,593,320      7,676,099 2048               0              0              0             0    1,403,681      1,403,681 2049               0              0              0             0            0              0 32,283,833    115,005,459     22,609,257   14,676,689     3,997,002    188,572,239 MG Services, Inc.

South Texas ProjectElectric GeneratingStation              Document S30-1499-002, Rev. 0 DecommissioningCost 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         Period 2            Site            Site Year     Planning     Decommissioning       Restoration     Restoration        Total Offset 2027        9,794,209                    0               0              0       9,794,209 2028      27,893,268                     0               0              0      27,893,268 2029        3,670,339           22,341,722               0              0      26,012,061 2030                0           23,293,497               0              0      23,293,497 2031                0           19,359,076               0              0      19,359,076 2032                0           18,840,695               0              0      18,840,695 2033                0           15,545,648               0              0      15,545,648 2034                0            1,715,712        204,602               0       1,920,315 2035                0                    0        654,685               0         654,685 2036                0                    0          16,017      5,168,853       5,184,871 2037                0                    0               0      4,357,198       4,357,198 2038                0                    0               0              0                0 2039                0                    0               0              0                0 2040                0                    0               0              0                0 2041                0                    0               0              0                0 2042                0                    0               0              0                0 2043                0                    0               0              0                0 2044                0                    0               0              0                0 2045                0                    0               0              0                0 2046                0                    0               0              0                0 2047                0                    0               0      4,343,074       4,343,074 2048                0                    0               0              0                0 41,357,816          101,096,350        875,305      13,869,126     157,198,596 TLG Services, Inc.

South Texas ProjectElectric GeneratingStation             Document S30-1499-002, Rev. 0 DecommissioningCost 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 ISFSI Operations Period 1      Period 2         Site       Spent Fuel       ISFSI Year    Planning         D&D         Restoration    Transfer        D&D           Total 2028       1,075,696              0              0             0            0       1,075,696 2029      21,954,963              0              0             0            0     21,954,963 2030       9,545,937     17,476,920              0             0            0     27,022,857 2031               0     25,498,590              0             0            0     25,498,590 2032               0     22,919,435              0             0            0     22,919,435 2033               0     22,220,996              0             0            0     22,220,996 2034               0     19,497,542              0             0            0      19,497,542 2035               0      8,330,895              0             0            0       8,330,895 2036               0        104,000     12,379,075             0            0      12,483,075 2037               0              0     10,435,213       184,894            0      10,620,107 2038               0              0                    1,054,471            0       1,054,471 2039               0              0                    1,054,471            0       1,054,471 2040               0              0              0     1,057,360            0       1,057,360 2041               0              0              0     1,054,471            0       1,054,471 2042               0              0              0     1,054,471            0       1,054,471 2043               0              0              0     1,054,471            0       1,054,471 2044               0              0              0     1,057,360            0       1,057,360 2045               0              0              0     1,054,471            0       1,054,471 2046               0              0              0     1,054,471            0       1,054,471 2047               0              0              0     5,128,872    2,616,837       7,745,709 2048               0              0              0             0    1,416,411       1,416,411 2049               0              0              0             0            0               0 32,576,596    116,048,377     22,814,288    14,809,783    4,033,248    190,282,292 TLG Services, Inc.

South Texas ProjectElectric GeneratingStation              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         Period 2             Site            Site Year     Planning     Decommissioning       Restoration     Restoration        Total Offset 2027       5,597,262                    0                0              0       5,597,262 2028      15,940,638                    0                0              0      15,940,638 2029       2,097,551           12,768,002                0              0      14,865,553 2030                0          13,311,929                0              0      13,311,929 2031                0          11,063,459                0              0      11,063,459 2032                0          10,767,211                0              0      10,767,211 2033                0           8,884,135                0              0       8,884,135 2034                0             980,507         116,928               0       1,097,435 2035                0                   0         374,144               0         374,144 2036                0                   0            9,154      2,953,932       2,963,086 2037                0                   0                0      2,490,082       2,490,082 2038                0                   0                0              0                0 2039                0                   0                0              0                0 2040                0                   0                0              0                0 2041                0                   0                0              0                0 2042                0                   0                0              0                0 2043                0                   0                0              0                0 2044                0                   0                0              0                0 2045                0                   0                0              0                0 2046                0                   0                0              0                0 2047                0                   0                0      2,482,010       2,482,010 2048                0                   0                0              0                0 23,635,451           57,775,242         500,225       7,926,024      89,836,943.
TLG Services, Inc.

South Texas ProjectElectric GeneratingStation             Document S30-1499-002, Rev. 0 DecommissioningCost Update                                       Appendix B, Page9 of 9 TABLE B-4.b COA - SCHEDULE OF ANNUAL EXPENDITURES DECON Alternative - Unit 2 (2004 Dollars, 10% Contingency)
Post Deconmmissioning ISFSI Operations Period 1       Period 2        Site       Spent Fuel       ISFSI Year    Planning         D&D         Restoration    Transfer         D&D          Total 2028          614,746             0              0             0            0        614,746 2029      12,546,974              0              0             0            0     12,546,974 2030        5,455,378     9,987,831              0             0            0     15,443,209 2031                0    14,572,111              0             0            0     14,572,111 2032                0    13,098,157              0             0            0     13,098,157 2033                0    12,699,009              0             0            0     12,699,009 2034                0    11,142,590              0             0            0     11,142,590 2035                0     4,760,998              0             0            0      4,760,998 2036                0        59,435      7,074,479             0            0      7,133,914 2037                0             0O     5,963,588       105,664            0      6,069,252 2038                0             0              0       602,616            0        602,616 2039                0             0              0       602,616            0        602,616 2040                0             0              0       604,267            0        604,267 2041                0             0              0       602,616            0        602,616 2042                0             0              0       602,616            0        602,616 2043                0             0              0       602,616            0        602,616 2044               0             0              0       604,267            0        604,267 2045               0             0              0       602,616            0        602,616 2046               0             0              0       602,616            0        602,616 2047               0             0              0    2,931,083     1,495,488      4,426,572 2048                0            0              0             0      809,460        809,460 2049                0            0              0             0            0              .0 18,617,099    66,320,131     13,038,067     8,463,598    2,304,949    108,743,843 TLG Services, Inc.}}