ML15097A014

Financial Assurance for Decommissioning - 2015 Update

ML15097A014
Person / Time
Site:	South Texas
Issue date:	03/26/2015
From:	Harrison G South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-1 5003219, STI: 34054098
Download: ML15097A014 (15)

Text

Nuclear Operating Company South Texas Pro/ect Electric GeneratingStation 90 Bar289 Madsmiorth. Texas 77483 March 26, 2015 NOC-AE-1 5003219 File No.: D57, G25 10 CFR 50.75 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Financial Assurance for Decommissioning - 2015 Update Pursuant to 10 CFR 50.75(f)(1), the STP Nuclear Operating Company (STPNOC) submits the attached status reports regarding funds available, effective December 31, 2014, for decommissioning South Texas Project Units 1 and 2. The data are assembled by the individual co-owners of the South Texas Project:

• NRG South Texas LP;

• City Public Service Board of San Antonio; and

" City of Austin - Austin Energy.

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

• Estimated amount of decommissioning funds required;

• Amount accumulated by December 31, 2014;

• A schedule of the annual amounts remaining to be collected;

• Assumptions for rates of escalation in decommissioning cost, and for rates used in funding projections;

• Contracts upon which the owners rely pursuant to 10 CFR 50.75(e)(1)(v);

• Modifications to method of providing financial fund assurance; and

• Material changes to trust agreements.

This letter contains no NRC commitments.

If there are any questions, please contact either Hung C. Le at (361) 972-7932 or me at (361) 972-8074.

George R. Harrison Executive Vice President and Chief Financial Officer HCL Attachments:

1. Financial Assurance for Decommissioning - NRG South Texas LP A

2. Financial Assurance for Decommissioning - City Public Service Board of San Antonio f )0-0)

3. Financial Assurance for Decommissioning - City of Austin - Austin Energy STI: 34054098

NOC-AE-1 5003219 Page 2 of 2 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV Morgan, Lewis & Bockius LLP U.S. Nuclear Regulatory Commission Steve Frantz, Esquire 1600 East Lamar Boulevard Arlington, TX 76011-4511 U.S. Nuclear Regulatory Commission Lisa M. Regner Lisa M. Regner Senior Project Manager NRG South Texas LP U.S. Nuclear Regulatory Commission John Ragan One White Flint North (MS 8 G9A) Chris O'Hara 11555 Rockville Pike Jim von Suskil Rockville, MD 20852 Senior Resident Inspector CPS Energy U. S. Nuclear Regulatory Commission Kevin Polio P. 0. Box 289, Mail Code: MNl16 Cris Eugster Wadsworth, TX 77483 L. D. Blaylock Attention: Document Control Desk Crain Caton & James, P.C.

U. S. Nuclear Regulatory Commission Peter Nemeth Washington, DC 20555-0001 City of Austin - Austin Energy Cheryl Mele John Wester Texas Dept. of State Health Services Richard A. Ratliff Robert Free

ATTACHMENT I SOUTH TEXAS PROJECT FINANCIAL ASSURANCE FOR DECOMMISSIONING 2015 UPDATE NRG SOUTH TEXAS LP

Attachment 1 NOC-AE-1 5003219 Page 1 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONING NRG South Texas LP 13.2% Ownership of South Texas Project Unit I Pursuant to 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning on March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor or share of reactor it owns. The requested information is provided below.

1. Minimum decommissioning fund estimate, Total Required: $68,229,416 pursuant to 10 CFR 50.75(b) and (c)1 :

2. Amount accumulated at the end of the calendar Amount Accumulated 2: $56,506,960 year preceding the date of the report for items included in 10 CFR 50.75(b) and (c):

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

Number of Years to Collect: 13

4. Assumptions used regarding escalation in Escalation Rate: 2.471%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 3.30% - 7.91%

factors used in funding projections:

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

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

7. Material changes to trust agreements: None

1. The NRC formulas in section 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service, and reduce residual radioactivity to levels that permit: (1) release of the property for unrestricted use and termination of the license; or (2) release of the property under restricted conditions and termination of the license.

2. By Order dated October 10, 2008 in PUCT Docket No. 35772, NRG South Texas LP was granted approval to establish a separate spent fuel management subaccount. By Order dated July 13, 2009 in PUCT Docket No. 36796, NRG South Texas LP was granted approval to establish a separate subaccount for pre-shutdown disposal of large components. The amounts allocable to the spent fuel management and pre-shutdown disposal subaccounts are not included in the reported amount. The reported amount includes funds accumulated based upon a site-specific study that includes license termination and other costs.

3. Target amounts to be collected were established by the PUCT-approved separate non-bypassable decommissioning charges established in PUCT Tariff Control No. 41970. Actual collections will vary but the charges are intended to produce the targeted annual collection amounts established in PUCT Docket No. 41580. All current collections are being deposited in the large component disposal subaccount.

Attachment 1 NOC-AE-1 5003219 Page 2 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONING NRG South Texas LP 30.8% Ownership of South Texas Project Unit 1 Pursuant to 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning on March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor or share of reactor it owns. The requested information is provided below.

1. Minimum decommissioning fund estimate, Total Required: $159,201,971 pursuant to 10 CFR 50.75(b) and (c)1 :

2. Amount accumulated at the end of the calendar Amount Accumulated 2 : $138,319,017 year preceding the date of the report for items included in 10 CFR 50.75(b) and (c):

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

Number of Years to Collect: 13

4. Assumptions used regarding escalation in Escalation Rate: 2.471%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 3.30% - 7.91%

factors used in funding projections:

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

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

7. Material changes to trust agreements: None

1. The NRC formulas in section 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service, and reduce residual radioactivity to levels that permit: (1) release of the property for unrestricted use and termination of the license; or (2) release of the property under restricted conditions and termination of the license.

2. By Order dated October 10, 2008 in PUCT Docket No. 35772, NRG South Texas LP was granted approval to establish a separate spent fuel management subaccount. By Order dated July 13, 2009 in PUCT Docket No. 36796, NRG South Texas LP was granted approval to establish a separate subaccount for pre-shutdown disposal of large components. The amounts allocable to the spent fuel management and pre-shutdown disposal subaccounts are not included in the reported amount. The reported amount includes funds accumulated based upon a site-specific study that includes license termination and other costs.

3. Target amounts to be collected were established by the PUCT-approved separate non-bypassable decommissioning charges established in PUCT Tariff Control No. 41941. Actual collections will vary but the charges are intended to produce the targeted annual collection amounts established in PUCT Docket No. 41580. All current collections are being deposited in the large component disposal subaccount.

Attachment 1 NOC-AE-1 5003219 Page 3 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONING NRG South Texas LP 13.2% Ownership of South Texas Project Unit 2 Pursuant to 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning on March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor or share of reactor it owns. The requested information is provided below.

1. Minimum decommissioning fund estimate, Total Required: $68,229,416 pursuant to 10 CFR 50.75(b) and (c)1 :

2. Amount accumulated at the end of the calendar Amount Accumulated 2: $68,278,426 year preceding the date of the report for items included in 10 CFR 50.75(b) and (c):

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

Number of Years to Collect: 14

4. Assumptions used regarding escalation in Escalation Rate: 2.476%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 3.30% - 7.91%

factors used in funding projections:

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

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

7. Material changes to trust agreements: None

1. The NRC formulas in section 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service, and reduce residual radioactivity to levels that permit: (1) release of the property for unrestricted use and termination of the license; or (2) release of the property under restricted conditions and termination of the license.

2. By Order dated October 10, 2008 in PUCT Docket No. 35772, NRG South Texas LP was granted approval to establish a separate spent fuel management subaccount. By Order dated July 13, 2009 in PUCT Docket No. 36796, NRG South Texas LP was granted approval to establish a separate subaccount for pre-shutdown disposal of large components. The amounts allocable to the spent fuel management and pre-shutdown disposal subaccounts are not included in the reported amount. The reported amount includes funds accumulated based upon a site-specific study that includes license termination and other costs.

3. Target amounts to be collected were established by the PUCT-approved separate non-bypassable decommissioning charges established in PUCT Tariff Control No. 41970. Actual collections will vary but the charges are intended to produce the targeted annual collection amounts established in PUCT Docket No. 41580. All current collections are being deposited in the large component disposal subaccount.

Attachment 1 NOC-AE-1 5003219 Page 4 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONING NRG South Texas LP 30.8% Ownership of South Texas Project Unit 2 Pursuant to 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning on March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor or share of reactor it owns. The requested information is provided below.

1. Minimum decommissioning fund estimate, Total Required: $159,201,971 pursuant to 10 CFR 50.75(b) and (c)':

2. Amount accumulated at the end of the calendar Amount Accumulated2 : $174,158,803 year preceding the date of the report for items included in 10 CFR 50.75(b) and (c):

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

Number of Years to Collect: 14

4. Assumptions used regarding escalation in Escalation Rate: 2.476%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 3.30% - 7.91%

factors used in funding projections:

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

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

7. Material changes to trust agreements: None

1. The NRC formulas in section 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service, and reduce residual radioactivity to levels that permit: (1) release of the property for unrestricted use and termination of the license; or (2) release of the property under restricted conditions and termination of the license.

2. By Order dated October 10, 2008 in PUCT Docket No. 35772, NRG South Texas LP was granted approval to establish a separate spent fuel management subaccount. By Order dated July 13, 2009 in PUCT Docket No. 36796, NRG South Texas LP was granted approval to establish a separate subaccount for pre-shutdown disposal of large components. The amounts allocable to the spent fuel management and pre-shutdown disposal subaccounts are not included in the reported amount. The reported amount includes funds accumulated based upon a site-specific study that includes license termination and other costs.

3. Target amounts to be collected were established by the PUCT-approved separate non-bypassable decommissioning charges established in PUCT Tariff Control No. 41941. Actual collections will vary but the charges are intended to produce the targeted annual collection amounts established in PUCT Docket No. 41580. All current collections are being deposited in the large component disposal subaccount.

ATTACHMENT 2 SOUTH TEXAS PROJECT FINANCIAL ASSURANCE FOR DECOMMISSIONING 2015 UPDATE CITY PUBLIC SERVICE BOARD OF SAN ANTONIO

Attachment 2 NOC-AE-1 5003219 Page 1 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONING City Public Service (CPS) Board of San Antonio 12% Ownership of South Texas Project Unit 1 Pursuant to 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning on March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor or share of reactor it owns. The requested information is provided below.

1. Minimum decommissioning fund estimate, Total Required: $62,027,313 pursuant to 10 CFR 50.75(b) and (c)1 :

2. Amount accumulated at the end of the calendar Amount Accumulated 2: $39,867,468 year preceding the date of the report for items included in 10 CFR 50.75(b) and (c):

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

Number of Years to Collect: 13

4. Assumptions used regarding escalation in Escalation Rate: 2.471%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 4.35%

factors used in funding projections:

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

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

7. Material changes to trust agreements: No changes since 2013 report was submitted.

1. The NRC formulas in 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service, and reduce residual radioactivity to levels that permit: (1) release of the property for unrestricted use and termination of the license; or (2) release of the property under restricted conditions and termination of the license. The cost of dismantling or demolishing non-radiological systems and structures is not included in NRC decommissioning cost estimates. The costs of managing and storing spent fuel on site until transfer to the Department of Energy are not included in the cost formulas.

2. By Order dated November 20, 2008 in PUCT Docket No. 35786, CPS Energy was granted approval to establish separate spent fuel management and pre-shutdown activities subaccounts. The amounts allocable to these subaccounts are not included in the reported amount. The reported amount includes funds accumulated based upon a site-specific study that includes license termination and other costs.

3. CPS Energy estimates that the Trust is currently fully funded, based on the 2012 decommissioning cost study and updated escalation rates. Additional contributions ended December 31, 2008. If future estimates indicate that further funding may be required, CPS Energy would be able to apply to the PUCT to seek further funding for NRC license termination costs through cost-of-service recovery authorized by Texas law.

Attachment 2 NOC-AE-1 5003219 Page 2 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONING City Public Service (CPS) Board of San Antonio 28% Ownership of South Texas Project Unit 1 Pursuant to 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning on March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor or share of reactor it owns. The requested information is provided below.

1. Minimum decommissioning fund estimate, Total Required: $144,730,396 pursuant to 10 CFR 50.75(b) and (c)1 :

2. Amount accumulated at the end of the calendar Amount Accumulated 2: $110,081,798 year preceding the date of the report for items included in 10 CFR 50.75(b) and (c):

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

Number of Years to Collect: 13

4. Assumptions used regarding escalation in Escalation Rate: 2.471%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 5.41%

factors used in funding projections:

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

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

7. Material changes to trust agreements: No changes since 2013 report was submitted.

1. The NRC formulas in 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service, and reduce residual radioactivity to levels that permit: (1) release of the property for unrestricted use and termination of the license; or (2) release of the property under restricted conditions and termination of the license. The cost of dismantling or demolishing non-radiological systems and structures is not included in NRC decommissioning cost estimates. The costs of managing and storing spent fuel on site until transfer to the Department of Energy are not included in the cost formulas.

2. Consistent with the approach taken for its 12% interest in the Order dated November 20, 2008, in PUCT Docket No.

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

3. CPS Energy estimates that the Trust is currently fully funded, based on the 2012 decommissioning cost study and updated escalation rates. Additional contributions ended January 31, 2008. If future estimates indicate that further funding may be required, CPS Energy would be able to exercise its rate setting authority to collect and accumulate further funds for NRC license termination costs.

Attachment 2 NOC-AE-1 5003219 Page 3 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONING City Public Service (CPS) Board of San Antonio 12% Ownership of South Texas Project Unit 2 Pursuant to 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning on March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor or share of reactor it owns. The requested information is provided below.

1. Minimum decommissioning fund estimate, Total Required: $62,027,313 pursuant to 10 CFR 50.75(b) and (c)1 :

2. Amount accumulated at the end of the calendar Amount Accumulated 2 : $53,467,192 year preceding the date of the report for items included in 10 CFR 50.75(b) and (c):

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

Number of Years to Collect: 14

4. Assumptions used regarding escalation in Escalation Rate: 2.476%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 4.35%

factors used in funding projections:

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

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

7. Material changes to trust agreements: No changes since 2013 report was submitted.

1. The NRC formulas in 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service, and reduce residual radioactivity to levels that permit: (1) release of the property for unrestricted use and termination of the license; or (2) release of the property under restricted conditions and termination of the license. The cost of dismantling or demolishing non-radiological systems and structures is not included in NRC decommissioning cost estimates. The costs of managing and storing spent fuel on site until transfer to the Department of Energy are not included in the cost formulas.

2. By Order dated November 20, 2008 in PUCT Docket No. 35786, CPS Energy was granted approval to establish separate spent fuel management and pre-shutdown activities subaccounts. The amounts allocable to these subaccounts are not included in the reported amount. The reported amount includes funds accumulated based upon a site-specific study that includes license termination and other costs.

3. CPS Energy estimates that the Trust is currently fully funded, based on the 2012 decommissioning cost study and updated escalation rates. Additional contributions ended December 31, 2008. Iffuture estimates indicate that further funding may be required, CPS Energy would be able to apply to the PUCT to seek further funding for NRC license termination costs through cost-of-service recovery authorized by Texas law.

Attachment 2 NOC-AE-1 5003219 Page 4 of 4 FINANCIAL ASSURANCE FOR DECOMMISSIONING City Public Service (CPS) Board of San Antonio 28% Ownership of South Texas Project Unit 2 Pursuant to 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning on March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor or share of reactor it owns. The requested information is provided below.

1. Minimum decommissioning fund estimate, Total Required: $144,730,396 pursuant to 10 CFR 50.75(b) and (c)':

2. Amount accumulated at the end of the calendar Amount Accumulated 2 : $131,558,684 year preceding the date of the report for items included in 10 CFR 50.75(b) and (c):

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

Number of Years to Collect: 14

4. Assumptions used regarding escalation in Escalation Rate: 2.476%

decommissioning cost, rates of earnings on decommissioning funds, and rates of other Earnings Rate: 5.41%

factors used in funding projections:

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

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

7. . Material changes to trust agreements: No changes since 2013 report was submitted.

1. The NRC formulas in 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service, and reduce residual radioactivity to levels that permit: (1) release of the property for unrestricted use and termination of the license; or (2) release of the property under restricted conditions and termination of the license. The cost of dismantling or demolishing non-radiological systems and structures is not included in NRC decommissioning cost estimates. The costs of managing and storing spent fuel on site until transfer to the Department of Energy are not included in the cost formulas.

2. Consistent with the approach taken for its 12% interest in the Order dated November 20, 2008, in PUCT Docket No.

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

3. CPS Energy estimates that the Trust is currently fully funded, based on the 2012 decommissioning cost study and updated escalation rates. Additional contributions ended January 31, 2008. Iffuture estimates indicate that further funding may be required, CPS Energy would be able to exercise its rate setting authority to collect and accumulate further funds for NRC license termination costs.

ATTACHMENT 3 SOUTH TEXAS PROJECT FINANCIAL ASSURANCE FOR DECOMMISSIONING 2015 UPDATE CITY OF AUSTIN - AUSTIN ENERGY

Attachment 3 NOC-AE-1 5003219 Page 1 of 2 FINANCIAL ASSURANCE FOR DECOMMISSIONING City of Austin - Austin Energy 16% Ownership of South Texas Project Unit I Pursuant to 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning on March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor or share of reactor it owns. The requested information is provided below.

1. Minimum decommissioning fund estimate, Total Required: $82,615,898 pursuant to 10 CFR 50.75(b) and (c)1 :

2. Amount accumulated at the end of the calendar Amount Accumulated: $61,470,759 year preceding the date of the report for items included in 10 CFR 50.75(b) and (c) 2:

3. Schedule of the annual amounts remaining to be Amount Remaining: $23,328,763 collected for items in 10 CFR 50.75(b) and (c):

Number of Years to Collect: 13

4. Assumptions used regarding escalation in Escalation Rate: 4.918%

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

factors used in funding projections:

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

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

7. Material changes to trust agreements: None

1. The NRC formulas in 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service, and reduce residual radioactivity to levels that permit: (1) release of the property for unrestricted use and termination of the license; or (2) release of the property under restricted conditions and termination of the license. The cost of dismantling or demolishing non-radiological systems and structures is not included in NRC decommissioning cost estimates. The costs of managing and storing spent fuel on site until transfer to Department of Energy are not included in the cost formulas.

2. On October 1, 2008, an accounting division of the Decommissioning Trust balance was recorded to reflect the division of costs as referenced in footnote 1.

Attachment 3 NOC-AE-1 5003219 Page 2 of 2 FINANCIAL ASSURANCE FOR DECOMMISSIONING City of Austin - Austin Energy 16% Ownership of South Texas Project Unit 2 Pursuant to 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning on March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor or share of reactor it owns. The requested information is provided below.

1. Minimum decommissioning fund estimate, Total Required: $82,615,898 pursuant to 10 CFR 50.75(b) and (c)1 :

2. Amount accumulated at the end of the calendar Amount Accumulated: $68,956,723 year preceding the date of the report for items included in 10 CFR 50.75(b) and (c) 2:

3. Schedule of the annual amounts remaining to be Amount Remaining: $19,957,350 collected for items in 10 CFR 50.75(b) and (c):

Number of Years to Collect: 14

4. Assumptions used regarding escalation in Escalation Rate: 4.918%

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

factors used in funding projections:

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

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

7. Material changes to trust agreements: None

1. The NRC formulas in 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service, and reduce residual radioactivity to levels that permit: (1) release of the property for unrestricted use and termination of the license; or (2) release of the property under restricted conditions and termination of the license. The cost of dismantling or demolishing non-radiological systems and structures is not included in NRC decommissioning cost estimates. The costs of managing and storing spent fuel on site until transfer to the Department of Energy are not included in the cost formulas.

2. On October 1, 2008, an accounting division of the Decommissioning Trust balance was recorded to reflect the division of costs as referenced in footnote 1.