city public service board of san antonio )0-0) · 2. by order dated october 10, 2008 in puct docket...

Nuclear Operating Company

South Texas Pro/ect Electric Generating Station 90 Bar 289 Madsmiorth. Texas 77483

March 26, 2015NOC-AE-1 5003219File No.: D57, G2510 CFR 50.75

U. S. Nuclear Regulatory CommissionAttention: Document Control DeskWashington, DC 20555-0001

South Texas ProjectUnits 1 and 2

Docket Nos. STN 50-498, STN 50-499Financial Assurance for Decommissioning - 2015 Update

Pursuant to 10 CFR 50.75(f)(1), the STP Nuclear Operating Company (STPNOC) submits theattached status reports regarding funds available, effective December 31, 2014, fordecommissioning South Texas Project Units 1 and 2. The data are assembled by the individualco-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 fundingprojections;

* 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. HarrisonExecutive Vice President and Chief Financial Officer

HCL

Attachments:1. Financial Assurance for Decommissioning - NRG South Texas LP A2. 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 of 2

cc:(paper copy) (electronic copy)

Regional Administrator, Region IVU.S. Nuclear Regulatory Commission1600 East Lamar BoulevardArlington, TX 76011-4511

Lisa M. RegnerSenior Project ManagerU.S. Nuclear Regulatory CommissionOne White Flint North (MS 8 G9A)11555 Rockville PikeRockville, MD 20852

Senior Resident InspectorU. S. Nuclear Regulatory CommissionP. 0. Box 289, Mail Code: MNl16Wadsworth, TX 77483

Attention: Document Control DeskU. S. Nuclear Regulatory CommissionWashington, DC 20555-0001

Morgan, Lewis & Bockius LLPSteve Frantz, Esquire

U.S. Nuclear Regulatory CommissionLisa M. Regner

NRG South Texas LPJohn RaganChris O'HaraJim von Suskil

CPS EnergyKevin PolioCris EugsterL. D. Blaylock

Crain Caton & James, P.C.Peter Nemeth

City of Austin - Austin EnergyCheryl MeleJohn Wester

Texas Dept. of State Health ServicesRichard A. RatliffRobert Free

ATTACHMENT I

SOUTH TEXAS PROJECT

FINANCIAL ASSURANCE FOR DECOMMISSIONING

2015 UPDATE

NRG SOUTH TEXAS LP

Attachment 1NOC-AE-1 5003219Page 1 of 4

FINANCIAL ASSURANCE FOR DECOMMISSIONINGNRG 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 calendaryear basis, beginning on March 31, 1999, and every two years thereafter, on the status of itsdecommissioning funding for each reactor or share of reactor it owns. The requested information is providedbelow.

1. Minimum decommissioning fund estimate,pursuant to 10 CFR 50.75(b) and (c)1 :

2. Amount accumulated at the end of the calendaryear preceding the date of the report for itemsincluded in 10 CFR 50.75(b) and (c):

3. Schedule of the annual amounts remaining to becollected for items in 10 CFR 50.75(b) and (c):

4. Assumptions used regarding escalation indecommissioning cost, rates of earnings ondecommissioning funds, and rates of otherfactors used in funding projections:

5. Contracts upon which the licensee is relyingpursuant to 10 CFR 50.75(e)(1)(v):

6. Modifications to a licensee's current methodproviding financial assurance occurring since thelast submitted report:

7. Material changes to trust agreements:

Total Required:

Amount Accumulated 2:

$68,229,416

$56,506,960

Amount Remaining 3: $0

13Number of Years to Collect:

Escalation Rate:

Earnings Rate:

2.471%

3.30% - 7.91%

None

None

None

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

2. By Order dated October 10, 2008 in PUCT Docket No. 35772, NRG South Texas LP was granted approval toestablish 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 largecomponents. The amounts allocable to the spent fuel management and pre-shutdown disposal subaccounts are notincluded in the reported amount. The reported amount includes funds accumulated based upon a site-specific studythat includes license termination and other costs.

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



30.8% Ownership of South Texas Project Unit 1









Total Required:

Amount Accumulated 2 :

$159,201,971

$138,319,017

Amount Remaining 3:

Number of Years to Collect:

Escalation Rate:

Earnings Rate:

$0

13

2.471%

3.30% - 7.91%

None

None

None












5. Contracts upon which the licensee is relyingpursuant to 10 CFR 50.75 (e)(1)(v):



Total Required:


$68,229,416

$68,278,426

Amount Remaining 3 : $0


Escalation Rate:

Earnings Rate:

2.476%

3.30% - 7.91%

None

None

None








1. Minimum decommissioning fund estimate,pursuant to 10 CFR 50.75(b) and (c)':







Total Required:

Amount Accumulated2 :

$159,201,971

$174,158,803



Escalation Rate:

Earnings Rate:

2.476%

3.30% - 7.91%

None

None

None




ATTACHMENT 2

SOUTH TEXAS PROJECT


2015 UPDATE

CITY PUBLIC SERVICE BOARD OF SAN ANTONIO


FINANCIAL ASSURANCE FOR DECOMMISSIONINGCity Public Service (CPS) Board of San Antonio

12% Ownership of South Texas Project Unit 1









Total Required: $62,027,313

$39,867,468Amount Accumulated 2:

Amount Remaining 3 : $0


Escalation Rate:

Earnings Rate:

2.471%

4.35%

None

None

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 afacility or site safely from service, and reduce residual radioactivity to levels that permit: (1) release of the propertyfor unrestricted use and termination of the license; or (2) release of the property under restricted conditions andtermination of the license. The cost of dismantling or demolishing non-radiological systems and structures is notincluded in NRC decommissioning cost estimates. The costs of managing and storing spent fuel on site untiltransfer 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 establishseparate spent fuel management and pre-shutdown activities subaccounts. The amounts allocable to thesesubaccounts are not included in the reported amount. The reported amount includes funds accumulated basedupon 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 andupdated escalation rates. Additional contributions ended December 31, 2008. If future estimates indicate thatfurther funding may be required, CPS Energy would be able to apply to the PUCT to seek further funding for NRClicense termination costs through cost-of-service recovery authorized by Texas law.


FINANCIAL ASSURANCE FOR DECOMMISSIONINGCity Public Service (CPS) Board of San Antonio28% Ownership of South Texas Project Unit 1









Total Required:


$144,730,396

$110,081,798

Amount Remaining 3 :


Escalation Rate:

Earnings Rate:

$0

13

2.471%

5.41%

None

None



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. Theamounts allocable to these subaccounts are not included in the reported amount. The reported amount includesfunds 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 andupdated escalation rates. Additional contributions ended January 31, 2008. If future estimates indicate that furtherfunding may be required, CPS Energy would be able to exercise its rate setting authority to collect and accumulatefurther funds for NRC license termination costs.


FINANCIAL ASSURANCE FOR DECOMMISSIONINGCity Public Service (CPS) Board of San Antonio










Total Required: $62,027,313

$53,467,192Amount Accumulated 2 :



Escalation Rate:

Earnings Rate:

2.476%

4.35%

None

None



2. By Order dated November 20, 2008 in PUCT Docket No. 35786, CPS Energy was granted approval to establishseparate spent fuel management and pre-shutdown activities subaccounts. The amounts allocable to thesesubaccounts are not included in the reported amount. The reported amount includes funds accumulated basedupon 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 andupdated escalation rates. Additional contributions ended December 31, 2008. If future estimates indicate thatfurther funding may be required, CPS Energy would be able to apply to the PUCT to seek further funding for NRClicense termination costs through cost-of-service recovery authorized by Texas law.


FINANCIAL ASSURANCE FOR DECOMMISSIONINGCity Public Service (CPS) Board of San Antonio28% Ownership of South Texas Project Unit 2


1. Minimum decommissioning fund estimate,pursuant to 10 CFR 50.75(b) and (c)':






7. . Material changes to trust agreements:

Total Required:

Amount Accumulated 2 :

$144,730,396

$131,558,684

Amount Remaining3 : $0


Escalation Rate:

Earnings Rate:

2.476%

5.41%

None

None



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. Theamounts allocable to these subaccounts are not included in the reported amount. The reported amount includesfunds 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 andupdated escalation rates. Additional contributions ended January 31, 2008. If future estimates indicate that furtherfunding may be required, CPS Energy would be able to exercise its rate setting authority to collect and accumulatefurther funds for NRC license termination costs.

ATTACHMENT 3

SOUTH TEXAS PROJECT


2015 UPDATE

CITY OF AUSTIN - AUSTIN ENERGY


FINANCIAL ASSURANCE FOR DECOMMISSIONINGCity of Austin - Austin Energy

16% Ownership of South Texas Project Unit I



2. Amount accumulated at the end of the calendaryear preceding the date of the report for itemsincluded in 10 CFR 50.75(b) and (c) 2:



5. Contracts upon which the licensee is relyingpursuant to 10 CFR 50.75(e)(1)(v)



Total Required:

Amount Accumulated:

Amount Remaining:


$82,615,898

$61,470,759

$23,328,763

13

Escalation Rate:

Earnings Rate:

4.918%

5.073%

None

None

None

1. The NRC formulas in 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove afacility or site safely from service, and reduce residual radioactivity to levels that permit: (1) release of the propertyfor unrestricted use and termination of the license; or (2) release of the property under restricted conditions andtermination of the license. The cost of dismantling or demolishing non-radiological systems and structures is notincluded in NRC decommissioning cost estimates. The costs of managing and storing spent fuel on site untiltransfer 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 thedivision of costs as referenced in footnote 1.


FINANCIAL ASSURANCE FOR DECOMMISSIONINGCity of Austin - Austin Energy



1. Minimum decommissioning fund estimate,pursuant to 10 CFR 50.75(b) and (c)1:

2. Amount accumulated at the end of the calendaryear preceding the date of the report for itemsincluded in 10 CFR 50.75(b) and (c) 2:






Total Required:

Amount Accumulated:

Amount Remaining:


$82,615,898

$68,956,723

$19,957,350

14

Escalation Rate:

Earnings Rate:

4.918%

5.073%

None

None

None


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

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