This is the accessible text file for GAO report number GAO-04-32 
entitled 'Nuclear Regulation: NRC Needs More Effective Analysis to 
Ensure Accumulation of Funds to Decommission Nuclear Power Plants' 
which was released on December 01, 2003.

This text file was formatted by the U.S. General Accounting Office 
(GAO) to be accessible to users with visual impairments, as part of a 
longer term project to improve GAO products' accessibility. Every 
attempt has been made to maintain the structural and data integrity of 
the original printed product. Accessibility features, such as text 
descriptions of tables, consecutively numbered footnotes placed at the 
end of the file, and the text of agency comment letters, are provided 
but may not exactly duplicate the presentation or format of the printed 
version. The portable document format (PDF) file is an exact electronic 
replica of the printed version. We welcome your feedback. Please E-mail 
your comments regarding the contents or accessibility features of this 
document to Webmaster@gao.gov.

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately.

Report to the Honorable Edward J. Markey, House of Representatives:

October 2003:

NUCLEAR REGULATION:

NRC Needs More Effective Analysis to Ensure Accumulation of Funds to 
Decommission Nuclear Power Plants:

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-32] GAO-04-32:

GAO Highlights:

Highlights of GAO-04-32, a report to the Honorable Edward J. Markey, 
House of Representatives 

Why GAO Did This Study:

Following the shutdown of a nuclear power plant a significant 
radioactive waste hazard remains until the waste is removed and the 
plant site decommissioned. In 1999, GAO reported that the combined 
value of the owners’ decommissioning funds was insufficient to ensure 
enough funds would be available for decommissioning. GAO was asked to 
update its 1999 report and to evaluate the Nuclear Regulatory 
Commission’s (NRC) analysis of the owners’ funds and its process for 
acting on reports that show insufficient funds.

What GAO Found:

Although the collective status of the owners’ decommissioning fund 
accounts has improved considerably since GAO’s last report, some 
individual owners are not on track to accumulate sufficient funds for 
decommissioning. Based on our analysis and most likely economic 
assumptions, the combined value of the nuclear power plant owners’ 
decommissioning fund accounts in 2000—about $26.9 billion—was about 47 
percent greater than needed at that point to ensure that sufficient 
funds will be available to cover the approximately $33 billion in 
estimated decommissioning costs when the plants are permanently 
shutdown. This value contrasts with GAO’s prior finding that 1997 
account balances were collectively 3 percent below what was needed. 
However, overall industry results can be misleading. Because funds are 
generally not transferable from funds that have more than sufficient 
reserves to those with insufficient reserves, each individual owner 
must ensure that enough funds are available for decommissioning its 
particular plants. We found that 33 owners with ownership interests in 
a total of 42 plants had accumulated fewer funds than needed through 
2000 to be on track to pay for eventual decommissioning. In addition, 
20 owners with ownership interests in a total of 31 plants recently 
contributed less to their trust funds than we estimate they needed to 
put them on track to meet their decommissioning obligations. 

NRC’s analysis of the owners’ 2001 biennial reports was not effective 
in identifying owners that might not be accumulating sufficient funds 
to cover their eventual decommissioning costs. In reviewing the 2001 
reports, NRC reported that all owners appeared to be on track to have 
sufficient funds for decommissioning. In reaching this conclusion, NRC 
relied on the owners’ future plans for fully funding their 
decommissioning obligations. However, based on the owners’ recent 
actual contributions, and using a different method, GAO found that 
several owners could be at risk of not meeting their financial 
obligations for decommissioning when these plants stop operating. In 
addition, for plants with more than one owner, NRC did not separately 
assess the status of each co-owner’s trust funds against each co-
owner’s contractual obligation to fund decommissioning. Instead, NRC 
assessed whether the combined value of the trust funds for the plant 
as a whole was reasonable. Such an assessment for determining whether 
owners are accumulating sufficient funds can produce misleading 
results because owners with more than sufficient funds can appear to 
balance out owners with less than sufficient funds even, though funds 
are generally not transferable among owners. Moreover, NRC has not 
established criteria for taking action if it determines that an owner 
is not accumulating sufficient funds. 

What GAO Recommends:

NRC should (1) develop an effective method for determining whether 
owners are accumulating decommissioning funds at sufficient rates and 
(2) establish criteria for taking action when it is determined that an 
owner is not accumulating sufficient funds. NRC disagreed with these 
recommendations suggesting that its method is effective and that it is 
better to deal with unacceptable levels of financial assurance on a 
case-by–case basis. GAO continues to believe that limitations in NRC’s 
method reduce its effectiveness and without criteria, NRC might not be 
able to ensure owners are accumulating decommissioning funds at 
sufficient rates.

www.gao.gov/cgi-bin/getrpt?GAO-04-32.

To view the full product, including the scope and methodology, click 
on the link above. For more information, contact Jim Wells, at (202) 
512-6877 or WellsJ@gao.gov.

[End of section]

Contents:

Letter: 

Results in Brief: 

Background: 

Despite Industry-wide Improvement, Some Owners of Nuclear Power Plants 
Are Not Accumulating Sufficient Decommissioning Funds: 

NRC's Analysis Did Not Effectively Determine Whether Each Owner Was 
Accumulating Sufficient Decommissioning Funds: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendixes:

Appendix I: Scope and Methodology of Our Analysis of the 
Decommissioning Trust Funds: 

Appendix II: Detailed Results of Our Analysis of the Decommissioning 
Trust Funds: 

Appendix III: Comments from the Nuclear Regulatory Commission: 

GAO Comments: 

Appendix IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Acknowledgments: 

Tables:

Table 1: Status of Individual Owners' Trust Fund Balances through 2000, 
Compared with Benchmark Trust Fund Balances, under Most Likely 
Assumptions: 

Table 2: Status of Individual Owners' Recent Trust Fund Contributions, 
Compared with Benchmark Trust Fund Contributions, under Most Likely 
Assumptions: 

Table 3: Status of Combined Trust Funds Compared with Benchmarks for 
Balances and Contributions (by Percentage above or below Benchmarks): 

Table 4: Owners with More, or Less, Than Benchmark Trust Fund Balances 
and Contributions, under Most Likely Assumptions (by Percentage above 
or below Benchmarks): 

Table 5: Selected Owners with More, or Less, Than Benchmark Trust Fund 
Balances and Contributions, under Optimistic Assumptions (by Percentage 
above or below Benchmarks): 

Table 6: Selected Owners with More, or Less, Than Benchmark Trust Fund 
Balances and Contributions, under Pessimistic Assumptions (by 
Percentage above or below Benchmarks): 

Abbreviations:

FERC: Federal Energy Regulatory Commission:

GDP: Gross Domestic Product:

NRC: Nuclear Regulatory Commission:

SAFSTOR: Safe Storage:

Letter October 30, 2003:

The Honorable Edward J. Markey: 
House of Representatives:

Dear Mr. Markey:

Following the retirement of a nuclear power plant and removal of the 
plant's spent or used fuel, a significant radioactive waste hazard 
remains until the waste is removed and disposed of, and the plant site 
decommissioned.[Footnote 1] Decommissioning of existing plants is 
expected to cost nuclear power plant owners about $33 billion 
dollars.[Footnote 2] The Nuclear Regulatory Commission (NRC), which 
licenses nuclear power plants, requires plant owners to submit biennial 
reports on decommissioning funding that, among other things, provide 
financial assurance that enough funding will be available when the 
power plants are retired.

In 1999, we reported that the combined value of the owners' 
decommissioning trust fund accounts (as of the end of 1997) was 3 
percent less than needed to ensure that enough funds would be available 
when the plants are retired.[Footnote 3] In addition, we found that NRC 
had not established criteria for responding to unacceptable levels of 
financial assurance. In December 2001, we reported that transfers of 
plant licenses among companies stemming from economic deregulation and 
the restructuring of the electricity industry had, in many cases, 
increased assurances that new plant owners would have sufficient 
decommissioning funds when their plants are retired.[Footnote 4] 
Nevertheless, in some instances, NRC's evaluation of the adequacy of 
funding arrangements was not rigorous enough to ensure that 
decommissioning funds would be adequate.

In this context, you asked us to update our earlier findings on the 
adequacy of owners' decommissioning funds. Specifically, this report 
(1) assesses the extent to which nuclear plant owners are accumulating 
funds at sufficient rates to pay decommissioning costs when their 
plants' licenses expire and (2) evaluates NRC's analysis of the owners' 
2001 biennial reports and its process for acting on reports that show 
unacceptable levels of financial assurance.

As part of our review, we collected data from the 2001 biennial reports 
on estimated decommissioning costs and actual decommissioning trust 
fund balances, generally as of December 31, 2000, for 122 nuclear power 
plants licensed by NRC. In addition, we surveyed the owners of the 
plants to determine how the trust fund balances were invested in 2000 
and to identify the annual amounts that the owners had contributed to 
the trust funds in recent years. Eighty-two percent of the owners 
responded to our survey.[Footnote 5] Using an approach similar to that 
used for our 1999 report,[Footnote 6] we analyzed both the combined 
efforts of all owners to accumulate funds to decommission all of the 
nuclear plants and each individual owner's efforts to accumulate funds 
for decommissioning each of its plants. For our analysis, we estimated 
the most likely future values of key assumptions, such as 
decommissioning costs, earnings on the decommissioning funds' assets, 
and the operating life of each plant. To address the inherent 
uncertainty associated with forecasting outcomes many years into the 
future, we also analyzed the effect of using pessimistic and optimistic 
values for these key assumptions. To evaluate NRC's analysis of the 
biennial reports and its process for acting on reports that have not 
satisfied decommissioning funding assurance requirements, we reviewed 
NRC's guidelines and policies for analyzing these reports and 
interviewed NRC's officials about how they conducted their analysis. 
Appendix I provides more detail on the scope and methodology of our 
review.

Results in Brief:

Although the collective status of the owners' decommissioning fund 
accounts has improved since our last report, some individual owners are 
not on track to accumulate sufficient funds for decommissioning. Using 
our most likely economic assumptions, the combined value of the nuclear 
plant owners' trust funds in 2000--about $26.9 billion--was about 47 
percent greater than needed at that point to ensure that sufficient 
funds will be available to cover the approximately $33 billion in 
estimated decommissioning costs when the plants are retired. This value 
contrasts with account balances that collectively were 3 percent below 
what was needed by the end of 1997. Overall industry results can be 
misleading, however. Because NRC does not allow owners to transfer 
funds from a trust fund with sufficient reserves to one without 
sufficient reserves, each individual owner must ensure that enough 
funds are available for decommissioning its particular plants. We found 
that 33 owners of all or parts of 42 different plants had accumulated 
less funds than we estimated they needed to have through 2000 to be on 
track to pay for eventual decommissioning. Under our most likely 
assumptions, these owners will have to increase the rates at which they 
accumulate funds to meet their future decommissioning obligations. Of 
the 33 owners, 26 provided contributions information for our survey. Of 
these 26 owners, only 8 appeared to be making up their shortfalls with 
recent increases in contributions to their trust funds.

NRC's analysis of the owners' 2001 biennial reports was not effective 
in identifying owners that might not be accumulating sufficient funds 
to cover their eventual decommissioning costs. In reviewing the 2001 
reports, NRC reported that all owners appeared to be on track to have 
sufficient funds for decommissioning. In reaching this conclusion, NRC 
relied on the owners' future plans for fully funding their 
decommissioning obligations. However, based on the actual contributions 
the owners recently made to their trust funds, we found that several 
owners could risk not meeting their financial obligations for 
decommissioning when these plants are retired. In addition, for the 
plants with more than one owner, NRC did not separately assess the 
status of each co-owner's trust funds against the co-owner's 
contractual obligation to fund decommissioning. Instead, NRC assessed 
whether the combined value of the trust funds for each plant as a whole 
was reasonable. Such an assessment for determining whether owners are 
accumulating sufficient funds can produce misleading results because 
owners with more than sufficient funds can appear to balance out owners 
with less than sufficient funds, even though funds are generally not 
transferable among owners. Furthermore, NRC has not established 
criteria for responding to any unacceptable levels of financial 
assurance. Accordingly, we are recommending that NRC develop and use an 
effective method for determining whether owners are accumulating funds 
at sufficient rates and establish criteria for responding to 
unacceptable levels of financial assurance.

Background:

NRC's primary mission is to protect the public health and safety, and 
the environment, from the effects of radiation from nuclear plants, 
materials, and waste facilities. Because decommissioning a nuclear 
power plant is a safety issue, NRC has authority to ensure that owners 
are financially qualified to decommission these plants.

Of the 125 nuclear power plants that have been licensed to operate in 
the United States since 1959, 3 have been completely decommissioned. Of 
the remaining 122 plants, 104 currently have operating licenses 
(although 1 has not operated since 1985), 11 plants are in safe storage 
(SAFSTOR) awaiting active decommissioning,[Footnote 7] and 7 plants are 
being decommissioned. At the time of our analysis, 43 plants were co-
owned by different owners.

NRC regulations limit commercial nuclear power plant licenses to an 
initial 40 years of operation but also permit such licenses to be 
renewed for additional 20 years if NRC determines that the plant can be 
operated safely over the extended period. NRC has approved license 
renewals for 16 plants (as of August 20, 2003).

In 1988, NRC began requiring owners to (1) certify that sufficient 
financial resources would be available when needed to decommission 
their nuclear power plants and (2) require them to make specific 
financial provisions for decommissioning.[Footnote 8] In 1998, NRC 
revised its rules to require plant owners to report to the NRC by March 
31, 1999, and at least once every 2 years thereafter on the status of 
decommissioning funding for each plant or proportional share of a plant 
they own.[Footnote 9] Under NRC requirements, the owners can choose 
from one or more methods, including the following, to provide 
decommissioning financial assurance:

* prepayment of cash or liquid assets into an account segregated from 
the owner's assets and outside the owner's administrative control;

* establishment of an external sinking fund maintained through periodic 
deposit of funds into an account segregated from the owner's assets and 
outside the owner's administrative control;

* use of a surety method (i.e., surety bond, letter of credit, or line 
of credit payable to a decommissioning trust account), insurance, or 
other method that guarantees that decommissioning costs will be paid; 
and:

* for federal licensees, a statement of intent that decommissioning 
funds will be supplied when necessary.

In September 1998, NRC amended its regulations to restrict the use of 
the external sinking fund method in deregulated electricity markets. 
Prior to this time, essentially all nuclear plant owners chose this 
method for accumulating decommissioning funds. However, under the 
amended regulations, owners may rely on periodic deposits only to the 
extent that those deposits are guaranteed through regulated rates 
charged to consumers.

In conjunction with its amended regulations, NRC issued internal 
guidance, describing the process for reviewing the adequacy of a 
prospective owner's financial qualifications to safely operate and 
maintain its plant(s) and the owner's proposed method(s) for ensuring 
the availability of funds to eventually decommission the 
plant(s).[Footnote 10] The guidance outlines a method for evaluating 
the owner's financial plans for fully funding decommissioning costs. In 
addition, the guidance states that, except under certain conditions, 
the NRC reviewer should, when plants have multiple owners, separately 
evaluate each co-owner's funding schedule for meeting its share of the 
plant's decommissioning costs.[Footnote 11]

Despite Industry-wide Improvement, Some Owners of Nuclear Power Plants 
Are Not Accumulating Sufficient Decommissioning Funds:

Using our most likely economic assumptions, the combined value of the 
nuclear power plant owners' decommissioning trust funds was about 47 
percent higher at the end of 2000 than necessary to ensure accumulation 
of sufficient funds by the time the plants' licenses expire. This 
situation contrasts favorably with the findings in our 1999 report, 
which indicated that the industry was about 3 percent below where it 
needed to be at the end of 1997 to ensure that enough funds would be 
available. However, because owners are not allowed to transfer funds 
from a trust fund with sufficient reserves to one without sufficient 
reserves, overall industry sufficiency can be misleading. When we 
individually analyzed the owners' trust funds, we found that 33 owners 
for several different plants had not accumulated funds at a rate that 
would be sufficient for eventual decommissioning.

Collectively the Nuclear Power Industry Is on Pace to Accumulate More 
Than Sufficient Funds for Decommissioning:

Through 2000, the owners of 122 operating and retired nuclear power 
plants collectively had accumulated about 47 percent more funds than 
would have been sufficient for eventually decommissioning, using our 
most likely economic assumptions. Specifically, the owners had 
accumulated about $26.9 billion--about $8.6 billion more than we 
estimate they needed at that point to ensure sufficient funds. This 
situation contrasts with the findings in our 1999 report, which 
indicated that the industry had accumulated about 3 percent less than 
the amount we estimated it should have accumulated by the end of 1997.

Using alternative economic assumptions changes these results. For 
example, under higher decommissioning costs and other more pessimistic 
assumptions, the analysis shows that the combined value of the owners' 
accounts would be only about 0.2 percent above the amount we estimate 
the industry should have collected by the end of 2000. (See app. II for 
our results using more optimistic assumptions.):

The collective improvement in the status of the owners' trust funds 
(under most likely assumptions) since our last report is due to three 
main factors. First, all or parts of the estimated decommissioning 
costs were prepaid for 15 plants when they were sold to new owners. For 
example, the seller prepaid $396 million when the Pilgrim 1 nuclear 
plant was sold in 1998 for the plant's scheduled decommissioning in 
2012. Second, for 16 other plants, NRC approved 20-year license 
renewals, which will provide additional time for the owners to make 
contributions and for the earnings to accumulate on the decommissioning 
fund balances. Third, owners earned a higher rate of return on their 
trust fund accounts than we projected in our 1999 report. For example, 
the average return on the trust funds of owners who responded to our 
survey was about 8.5 percent[Footnote 12] (after-tax nominal return) 
per year, from 1998 through 2000, instead of the approximately 6.25 
percent per year we had assumed. The higher return was a result of the 
stronger than expected performance of financial markets in the late 
1990s.[Footnote 13] Since that time, however, the economy has slowed 
and financial markets--equities in particular--have generally 
performed poorly.

Several Owners Are Not Accumulating Sufficient Funds for 
Decommissioning Their Plants:

In contrast to the encouraging industry-wide results, when we analyzed 
the owners' trust fund accounts individually, we found that several 
owners were not accumulating funds at rates that would be sufficient to 
pay for decommissioning if continued until their plants are retired. 
Each owner has a trust fund for each plant that it owns in whole or in 
part. For example, the Exelon Generation Company owns all or part of 20 
different plants. For this analysis, we assessed the status of 222 
trust funds for 122 plants owned in whole or part by 99 owners. As 
shown in table 1, using our most likely assumptions, 33 owners of all 
or parts of 42 different plants (50 trust funds) had accumulated less 
funds than needed through 2000 to be on track to pay for eventual 
decommissioning (see app. II for details).[Footnote 14] Thirteen of 
these plants were shut down before sufficient funds had been 
accumulated for decommissioning. Although the remaining 78 owners of 
all or parts of 93 plants (172 trust funds) had accumulated more funds 
than we estimate they needed to have at the end of 2000, funds are 
generally not transferable from owners who have more than sufficient 
reserves to other owners who have insufficient reserves. Under our most 
likely assumptions, the owners whom we estimate to be behind will have 
to increase the rates at which they accumulate funds to meet their 
eventual decommissioning financial obligations.

For our analysis, we compared the trust fund balance that individual 
owners had accumulated for each plant by the end of 2000 with a 
"benchmark" amount of funds that we estimate they should have 
accumulated by that date. In setting the benchmark, we assumed that the 
owners would contribute increasing (but constant present-value) amounts 
annually to cover eventual decommissioning costs.[Footnote 15] For 
example, at the end of 2000, an owner's decommissioning fund for a 
plant that had operated one-half of a 40-year license period (begun in 
1980) should contain one-half of the present value of the estimated 
cost to decommission the owner's share of that plant in 2020. Although 
this benchmark is not the only way an owner could accrue enough funds 
to pay future decommissioning costs, it provides both a common standard 
for comparisons among owners and, from an equity perspective among 
ratepayers in different years, a financially reasonable growing 
current-dollar funding stream over time. Appendix I describes our 
methodology in more detail.



Table 1: Status of Individual Owners' Trust Fund Balances through 2000, 
Compared with Benchmark Trust Fund Balances, under Most Likely 
AssumptionsA:

Status: Above benchmark balance; Trust funds: 172; Owners: 78; Plants 
currently operating: 88; Plants shut down: 5.

Status: Below benchmark balance; Trust funds: 50; Owners: 33; Plants 
currently operating: 29; Plants shut down: 13.

Status: Total; Trust funds: 222; Owners: [B]; Plants currently 
operating: [B]; Plants shut down: [B].

Source: GAO analysis.

[A] Most likely assumptions include 20-year license renewals that have 
been approved by NRC for 16 plants as of August 20, 2003.

[B] Not applicable.

[End of table]

The status of each owner's fund balance at the end of 2000 is not, by 
itself, the only indicator of whether an owner will have enough funds 
for decommissioning. Whether the owner will accumulate the necessary 
funds also depends on the rate at which the owner contributes funds 
over the remaining operating life of the plant; by increasing their 
contribution rates, owners whose trust fund balances were below the 
benchmark level could still accumulate the needed funds. Consequently, 
for the owners who provided contributions information to us, we also 
analyzed whether their recent contribution rates would put them on 
track to meet their decommissioning obligations. For this second 
analysis, we compared the average of the amounts contributed in 1999 
and 2000 (cost-adjusted to 2000) with a benchmark amount equivalent to 
the average yearly present value of the amounts the owners would have 
to accumulate each year over the remaining life of their share of the 
plants to have enough decommissioning funds.

As table 2 shows, 28 owners with ownership shares in 44 different 
plants (50 trust funds) contributed less than the amounts we estimate 
they will need to meet their decommissioning obligations, under our 
most likely assumptions.

Table 2: Status of Individual Owners' Recent Trust Fund Contributions, 
Compared with Benchmark Trust Fund Contributions, under Most Likely 
AssumptionsA:

Status: Above benchmark contributions; Trust funds: 122; Owners: 58; 
Plants currently operating: 76; Plants shut down: 5.

Status: Below benchmark contributions; Trust funds: 50; Owners: 28; 
Plants currently operating: 34; Plants shut down: 10.

Status: Total; Trust funds: 172[B]; Owners: [C]; Plants currently 
operating: [C]; Plants shut down: [C].

Source: GAO analysis.

[A] Most likely assumptions include 20-year license renewals that have 
been approved by NRC for 16 plants as of August 20, 2003.

[B] Contributions not available for 50 other trust funds.

[C] Not applicable.

[End of table]

We compared the owners in table 1 with those in table 2 to see whether 
owners who are behind in balances were making up their shortfalls with 
recent increases in contributions. Of the 33 owners who we estimate had 
less than the benchmark balances through 2000, 26 owners of all or 
parts of 38 plants provided contributions information. Of these owners, 
only 8 owners of all or parts of 9 plants appeared to be making up 
their shortfalls with recent increases in contributions. By contrast, 
20 owners with ownership interests in 31 plants recently contributed 
less to their trust funds than we estimate they needed to put them on 
track to meet their decommissioning obligations.[Footnote 16]

These results would change under alternative economic assumptions. For 
example, if economic conditions improve to those assumed in our 
optimistic scenario, of the 20 owners who were below the benchmark 
under most likely assumptions on both balances and contributions, 12 
owners would still be below the benchmark in both categories, even 
under optimistic assumptions.

However, if economic conditions worsen to those in our pessimistic 
scenario, 34 owners who were above the benchmark under most likely 
assumptions on either balances or contributions would be below either 
of these benchmarks under pessimistic assumptions. (See app. II for 
detailed results.):

NRC's Analysis Did Not Effectively Determine Whether Each Owner Was 
Accumulating Sufficient Decommissioning Funds:

NRC's analysis of the 2001 biennial decommissioning status reports was 
not effective in identifying owners that might not be accumulating 
funds at sufficient rates to pay for decommissioning costs when their 
plants are permanently shut down. Although the NRC reported in 2001 
that all owners appeared to be on track to have sufficient funds for 
decommissioning,[Footnote 17] our analysis indicated that several 
owners might not be able to meet financial obligations for 
decommissioning. NRC's analysis was not effective for two reasons. 
First, NRC overly relied on the owners' future funding plans, or on 
rate-setting authority decisions, in concluding that the owners were on 
track to fully fund decommissioning. However, as discussed earlier, 
based on actual contributions the owners had recently made to their 
trust funds, several owners are at risk of not accumulating enough 
funds to pay for decommissioning. Second, for the plants with more than 
one owner, NRC did not separately assess the status of each co-owner's 
trust funds relative to the co-owner's contractual obligation to fund a 
certain portion of decommissioning. Instead, NRC combined funds on a 
plant-wide basis and assessed whether the combined trust funds would be 
sufficient for decommissioning. Such an assessment method can produce 
misleading results because the owners with more than sufficient trust 
funds can appear to balance out those with insufficient trust funds. 
Furthermore, if NRC had identified an owner with unacceptable levels of 
financial assurance, it would not have had an explicit basis for acting 
to remedy potential funding deficiencies because it has not established 
criteria for responding to unacceptable levels of financial assurances.

NRC officials said that their oversight of the owners' decommissioning 
funds is an evolving process and that they intend to learn from their 
review of prior biennial reports and make changes to improve their 
evaluation of the 2003 biennial reports. However, they also said that 
any specific changes they are considering are predecisional, and final 
decisions have not yet been made.

NRC's Review Relied on Owners' Future Plans for Making Contributions:

According to NRC officials, in reviewing the 2001 biennial reports, 
they used a "straight-line" method to establish a screening criterion 
for assessing whether owners were accumulating decommissioning funds at 
sufficient rates. Specifically, NRC compared the amount of funds 
accumulated through 2000 (expressed as a percentage of the total 
estimated cost as of 2000 to decommission the plant) to the expended 
plant life (expressed as a percentage of the total number of years the 
plant will operate). Under this method, the owner of a plant that has 
operated for one-half of its operating life would be expected to have 
accumulated at least one-half of the plant's estimated decommissioning 
costs (that is, it would be collecting at or above the straight-line 
rate). NRC found that the owners of 64 out of 104 plants currently 
licensed to operate were collecting at the above a straight-line rate, 
and that the owners of the remaining 40 plants were collecting at the 
less than a straight-line rate.[Footnote 18]

On a plant-wide basis, NRC then reviewed the owners' "amortization" 
schedules for making future payments to fully fund decommissioning. The 
schedules, required as part of the biennial reports, consist of the 
remaining funds that the owners expect to collect each year over the 
remaining operating life of the plants. In estimating the funds to be 
collected, the owners may factor in the earnings expected from their 
trust fund investments. To account for such earnings, NRC regulations 
allow an owner to increase its trust fund balance by up to 2 percent 
per year (net of estimated cost escalation), or higher, if approved by 
its regulatory rate-setting authority, such as a state public utility 
commission. Because these owners' amortization schedules identified 
sufficient future funds to enable them to reach the target funding 
levels, NRC concluded that all licensees appear to be on track to fund 
decommissioning when their plants are retired.

However, relying on amortization schedules is problematic, in part 
because the actual amounts the owners contribute to their funds in the 
future could differ (that is, worsen) from their planned amounts if 
economic conditions or other factors change. NRC officials said that 
owners are not required by regulation to report their recent actual 
contributions to the trust funds, and NRC does not directly monitor 
whether the owners' actual contributions match their planned 
contributions. Consequently, NRC relies on the owners' amortization 
schedules as reported in the biennial reports.

Such reliance is also problematic because in developing their 
amortization schedules, the owners could use widely varying rates of 
return to project the earnings on their trust fund investments. For 
example, each of the three co-owners of the Duane Arnold Energy Center 
nuclear plant assumed a different rate, ranging from 2 to 7 percent 
(net of estimated cost escalation). Other factors being equal, the 
owners using the higher rates would need to collect fewer funds than 
the owner using the lower rate of return. While the return that each 
owner actually earns on its investments may be higher or lower than 
these rates, by relying on the owners' amortization schedules, NRC 
effectively used a different set of assumptions to evaluate the 
reasonableness of the trust funds accumulated by each owner. 
Consequently, NRC did not use a consistent "benchmark" in assessing the 
owners' trust funds. By contrast, we used historical trends and 
economic forecasts to develop assumptions about rates of earnings and 
other economic variables, applied the same assumptions in evaluating 
the adequacy of each owner's trust fund, and based expected future 
contributions on actual amounts contributed in recent years.

NRC's Analysis Focused on the Adequacy of Trust Funds on a Plant-by-
Plant Basis:

NRC's internal guidance for evaluating the biennial reports states that 
for plants having more than one owner, except in certain circumstances, 
each owner's amortization schedule should be separately assessed for 
its share of the plant's decommissioning costs.[Footnote 19] For those 
plants that have co-owners, NRC used the total amount of funds 
accumulated for the plant as a whole in its analysis. However, as we 
demonstrated with our industry-wide analysis, such an assessment for 
determining whether owners are accumulating sufficient funds can 
produce misleading results because owners with more than sufficient 
funds can appear to balance out owners with less than sufficient funds, 
even though funds are generally not transferable among owners.

In explaining their approach, NRC officials said that the section of 
the guidance that calls for a separate evaluation of each owner's 
amortization schedule for its share of the plant is not compulsory. In 
addition, they said that they consider each owner's schedule to 
determine the total funds for the plant as a whole, but they believe 
that the same level of effort is not required for each individual trust 
fund balance unless there is a manifest reason to do so. They also 
stated that NRC's regulations do not prohibit each co-owner from being 
held responsible for decommissioning costs, even if these costs are 
more than the co-owner's individual ownership share. However, assessing 
the adequacy of decommissioning costs on a plant-wide basis is not 
consistent with the industry view, held by most plant owners, that each 
co-owner's responsibility should be limited to its pro rata share of 
decommissioning expenses and that NRC should not look to one owner to 
"bail out" another owner by imposing joint and several liability on all 
co-owners.[Footnote 20] NRC has implicitly accepted this view and has 
incorporated it into policy to continue it. In a policy statement on 
deregulation,[Footnote 21] NRC stated that it will not impose 
decommissioning costs on co-owners in a manner inconsistent with their 
agreed-upon shares,[Footnote 22] except in highly unusual circumstances 
when required by public health and safety considerations and that it 
would not seek more than the pro rata shares from co-owners with de 
minimis ownership. Nevertheless, unless NRC separately evaluates each 
co-owner's trust fund, NRC might eventually need to look to require 
some owners to pay more than their share.

NRC Has Not Established Criteria for Responding to Unacceptable Levels 
of Financial Assurance:

While the NRC has conducted two reviews of the owners' biennial reports 
to date, it has not established specific criteria for responding to any 
unacceptable levels of financial assurances that it finds in its 
reviews of the owners' biennial reports. As we noted in our 1999 
report, without such criteria, NRC will not have a logical, coherent, 
and predictable plan of action if and when it encounters owners whose 
plants have inadequate financial assurance. NRC officials said that 
their oversight of the owners' decommissioning funds is an evolving 
process, and they are learning from their prior reviews. However, they 
also said that any specific changes they are considering are 
predecisional and final decisions have not yet been made.

The absence of any specific criteria for acting on owners' 
decommissioning financial reports contrasts with the agency's practices 
for overseeing safety activities at nuclear power plants. According to 
NRC, its safety assessment process allows it to integrate information 
relevant to licensee safety performance, make objective conclusions 
regarding the information, take actions based on these conclusions in a 
predictable manner, and effectively communicate these actions to the 
licensees and to the public. Its oversight approach uses criteria for 
identifying and responding to levels of concern for nuclear plant 
performance. In determining its regulatory response, NRC uses an 
"Action Matrix" that provides for a range of actions commensurate with 
the significance of inspection findings and performance indicators. If 
the findings indicate that a plant is operating in a way that has 
little or no impact on safety, then NRC implements only its baseline 
inspection program. However, if the findings indicate that a plant is 
operating in a way that implies a greater degree of safety 
significance, NRC performs additional inspections and initiates other 
actions commensurate with the significance of the safety issues. A 
similar approach in the area of financial assurance for decommissioning 
would appear to offer the same benefits of objectivity and 
predictability that NRC has established in its safety oversight.

Conclusions:

Ensuring that nuclear power plant owners will have sufficient funds to 
clean up the radioactive waste hazard left behind when these plants are 
retired is essential for public health and safety. As our analysis 
identified, some owners may be at risk of not accumulating sufficient 
trust funds to pay for their share of decommissioning. NRC's analysis 
was not effective in identifying such owners because it relied too 
heavily on the owners' future funding plans without confirming that the 
plans were consistent with recent contributions. Moreover, it 
aggregated the owners' trust funds plant-wide instead of assessing 
whether each individual owner was on track to accumulate sufficient 
funds to pay for its share of decommissioning costs. In addition, NRC 
has not explained to the owners and the public what it intends to do if 
and when it determines an owner is not accumulating sufficient trust 
funds. Without a more effective method for evaluating owners' 
decommissioning trust funds, and without criteria for responding to any 
unacceptable levels of financial assurance, NRC will not be able to 
effectively ensure that sufficient funds will be available when needed.

Recommendations for Executive Action:

To ensure that owners are accumulating sufficient funds to decommission 
their nuclear power plants, we recommend that the Chairman, NRC, 
develop an effective method for determining whether owners are 
accumulating funds at sufficient rates to pay for decommissioning. For 
plants having more than one owner, this method should include 
separately evaluating whether each owner is accumulating funds at 
sufficient rates to pay for its share of decommissioning. We further 
recommend that the Chairman, NRC, establish criteria for taking action 
when NRC determines that an owner or co-owner is not accumulating 
decommissioning funds at a sufficient rate to pay for its share of the 
cost of decommissioning.

Agency Comments and Our Evaluation:

We provided a draft of this report to NRC for its review and comment. 
NRC's written comments, which are reproduced in appendix III, expressed 
three main concerns regarding our report. First, NRC disagreed with our 
observation that its analyses of funding levels of the co-owners of a 
nuclear plant are inconsistent with its internal guidance. We revised 
the report to remove any inferences that NRC was not complying with its 
own guidance. While clarifying this point, we remained convinced that 
NRC needs to do more to develop an effective method for assessing the 
adequacy of nuclear power plant owner's trust funds for 
decommissioning. NRC's current practice is to combine the trust funds 
for all co-owners of a nuclear plant, then assess whether the combined 
value of the trust funds is sufficient. However, as our analysis 
indicates, NRC's practice of combining the trust funds of several 
owners for its assessment can produce misleading results because co-
owners with more than sufficient funds can appear to balance out those 
with less than sufficient funds. As a practical matter, owners have a 
contractual agreement to pay their share of decommissioning costs, and 
owners generally cannot transfer funds from a trust fund with 
sufficient reserves to one without sufficient reserves. While NRC 
recognizes that private contractual arrangements among co-owners exist, 
the agency stated that it reserves the right, in highly unusual 
situations where adequate protection of public health and safety would 
be compromised if such action were not taken, to consider imposing 
joint and several liability on co-owners for decommissioning funding 
when one or more co-owners have defaulted. Nonetheless, we believe that 
NRC should take a proactive approach, rather than simply wait until one 
or more co-owners default on their decommissioning payment expenses, to 
ensure that sufficient funds will be available for decommissioning and 
that the adequate protection of public health and safety is not 
compromised. Such an approach, we believe, would involve developing an 
effective method that, among other things, separately evaluates the 
adequacy of each co-owner's trust fund.

Second, NRC disagreed with our view that some owners are not on track 
to accumulate sufficient funds for decommissioning. NRC's position is 
that it has a method for assessing the reasonableness of the owners' 
trust funds and that our method has not been reviewed and accepted by 
NRC. While we recognize that NRC has neither reviewed nor accepted our 
method, our report identifies several limitations in NRC's method that 
raise doubts about whether the agency's method can effectively identify 
owners who might be at risk of not having sufficient funds for 
decommissioning. A particularly problematic aspect of this method is 
NRC's reliance on the owners' future funding plans to make up any 
shortfalls without verifying whether those plans are consistent with 
the owners' recent contributions. We found some owners' actual 
contributions in 2001 were much less than what they stated in their 
2001 biennial reports to NRC that they planned to contribute. For 
example, one owner contributed about $1.5 million (or 39 percent) less 
than the amount they told NRC that they planned to contribute. In 
addition, based on our analysis using actual contributions the owners 
had recently made to their trust funds, we found that 28 owners with 
ownership shares in 44 different plants contributed less than the 
amounts we estimate they will need to make over the remaining operating 
life of their plants to meet their decommissioning obligations. 
Therefore, we continue to believe that some owners are not on track to 
accumulate sufficient funds to pay for decommissioning.

Finally, NRC disagreed with our view that it should establish criteria 
for responding to owners with unacceptable levels of financial 
assurance. NRC stated that its practice is to review the owners' plans 
on a case-by-case basis, engage in discussions with state regulators, 
and issue orders as necessary and appropriate. Since NRC has never 
identified an owner with unacceptable levels of financial assurance, it 
has never implemented this practice. We believe that NRC should take a 
more proactive approach to providing owners and the public with a more 
complete understanding of NRC's expectations of how it will hold owners 
who are not accumulating sufficient funds accountable. As stated in our 
draft report, this lack of criteria is in contrast to NRC's practices 
in overseeing safety issues at nuclear plants, where the NRC uses an 
"Action Matrix" that provides for a range of actions commensurate with 
the significance of safety inspection findings and performance 
indicators. In the area of financial assurance, a similar approach 
could involve monitoring the trust fund deposits of those owners who 
NRC determines are accumulating insufficient funds to verify that the 
deposits are consistent with the owners' funding plans.

We conducted our review from June 2001 to September 2003 in accordance 
with generally accepted government auditing standards. Unless you 
publicly announce the contents of this report earlier, we plan no 
further distribution until 30 days from the report date. At that time, 
we will send copies of this report to the appropriate congressional 
committees; the Chairman, NRC; Director, Office of Management and 
Budget; and other interested parties. We will also make copies 
available to others upon request. In addition, this report will be 
available at no charge on the GAO Web site at [Hyperlink, http://
www.gao.gov] http://www.gao.gov. If you or your staff have any 
questions, please call me at (202) 512-6877. Key contributors to this 
report are listed in appendix IV.

Sincerely yours,

Signed by: 

Jim Wells: 

Director, Natural Resources  and Environment:

[End of section]

Appendixes:

Appendix I Scope and Methodology of Our Analysis of the Decommissioning 
Trust Funds:

This appendix describes the scope and methodology of our review for our 
first objective: the extent to which nuclear power plant owners are 
accumulating funds at sufficient rates to pay decommissioning costs 
when their plants' licenses expire.

In addressing this objective, we analyzed the status of the 
decommissioning trust funds from two perspectives. First, we analyzed 
whether the industry as a whole is accumulating funds at rates that 
would be sufficient for decommissioning. For this analysis, we combined 
the trust funds of the owners of 122 nuclear plants. We then compared 
our results with those of our 1999 report to see whether the industry's 
status had changed.

Second, because owners generally cannot transfer funds from a trust 
fund with sufficient reserves to one without sufficient reserves, we 
also analyzed the status of each owner's trust fund for each plant in 
which the owner had an ownership share. For this analysis, we analyzed 
the status of 222 individual trust funds, representing 99 owners of all 
or parts of 122 plants.

For both the combined industry-wide trust funds and the individual 
owners' trust funds, we conducted two separate analyses (hereafter 
described in terms of our analysis of the individual owners' trust 
funds). This method is the same as that used in our earlier report on 
the adequacy of decommissioning funding.[Footnote 23] First, we looked 
backward from a base year--2000--and assessed whether, when taking into 
account key economic factors such as decommissioning cost-escalation 
rates and after-tax rates of return on the funds (the discount rate), 
each owner's decommissioning fund balance for its ownership share of 
each of its plants was consistent with the expended portion of the 
licensed operating life of that plant. In other words, we assessed 
whether the monies the owner had contributed to its fund as of the end 
of 2000, together with the past earnings on these monies, equaled a 
benchmark or expected balance the owner should have accumulated by that 
time.

To determine the benchmark balance for 2000 for each plant (owner's 
share), we multiplied the present value of the plant's estimated future 
decommissioning costs (owner's share) by the fraction of the plant's 
operating life used up by 2000. For example, a plant that began 
operating in 1980 would have used up one-half of its 40-year operating 
life by the end of 2000. Therefore, by the end of 2000, the owner for 
this plant should be expected to have accumulated in its trust fund 
one-half of the present value (in constant 2000 dollars) of the 
estimated decommissioning costs. Over the life of a plant, our 
benchmark measure presumes that an owner would contribute an annual 
amount that increases (but constant in present-value terms) at the 
trust fund's after-tax rate of return. The sum of these annual amounts 
plus the income earned on the investment of the funds would equal the 
total estimated (present value of) the decommissioning costs when the 
plant's operating license expires.[Footnote 24]

Although recent deregulation and restructuring of the electricity 
industry have led some owners to prepay decommissioning costs, many 
owners continue to fund the trust funds by collecting fees from 
electricity users. Thus, under our benchmark measure, by paying 
decommissioning "fees" that are deposited into the trust funds, 
electricity users pay for the present value of each year's accrued 
decommissioning costs. As a result, the benchmark embodies the 
principle of economic efficiency in that the price of a product (i.e., 
electricity) should, if possible, equal all of its costs--current and 
accrued. In addition, by assuming that current and future users pay the 
same decommissioning fees, in constant present-value terms, our 
benchmark ensures that decommissioning costs are accrued transparently 
over time.

In addition to the looking-backward analysis, we conducted a second 
analysis, a "looking forward" from a base year--end of 2000--and 
assessed whether each owner's recent contributions to its 
decommissioning funds for respective shares of each of its nuclear 
power plants were at a level consistent with the remaining portions of 
the licensed operating lives of each plant. In other words, we assessed 
whether the owner recently added monies to its decommissioning trust 
fund for each plant at the benchmark contribution necessary to have 
enough funds to decommission the plant when its operating license 
expires. For example, an owner who is behind in terms of trust fund 
balance through the end of 2000 could have recently contributed to its 
fund at much higher rates than it had in the past to make up for its 
shortfall over the remaining operating life of the plant.

To determine an owner's benchmark annual contribution, for each of its 
plants, we computed the annual-average present value of the required 
future contributions that are summed over the remaining life of the 
plant. The total present value contribution must equal the present 
value of the total future decommissioning costs minus the value of the 
current trust fund balance. We then compared this annual amount with 
the average contribution to the trust fund that the owner made in 1999 
and 2000 (cost adjusted to 2000). We assume that an owner will annually 
increase its most recent contribution (2-year average, cost adjusted to 
2000) over the remaining life of its plant by the assumed after-tax 
rate of return on its decommissioning fund. Owners whose recent average 
contributions exceeded the benchmark amount would be adding funds at a 
rate that would be more than sufficient, while owners whose recent 
average contributions were below the benchmark rate would be adding 
funds at an insufficient rate to pay for future decommissioning costs 
(under our specific economic assumptions).

For our assessment of the status of the industry as a whole (and for 
both the looking-backward and looking-forward analyses), we developed 
three different scenarios: baseline (i.e., most likely), pessimistic, 
and optimistic. For the baseline analysis, we used our most likely 
economic assumptions. For the pessimistic and optimistic scenarios, we 
used different values for several key assumptions, as described later 
in this appendix.

For our assessment of the status of each individual owner's trust 
funds, we looked at the status of each owner's trust funds under 
baseline (most likely) assumptions (for both the looking-backward and 
looking-forward analyses). In addition, for owners who were below the 
benchmark on both balances and contributions under the baseline 
assumptions, we reviewed the 2003 and 2001 biennial reports to 
ascertain whether the owner has and/or had an additional method (e.g., 
parent company guarantee) to support financial assurance obligations. 
We indicate in our detailed results when an owner reported having an 
additional method (see app. II, table 4). However, we did not evaluate 
the adequacy of these methods.

In addition, for selected owners depending upon our baseline results, 
we analyzed how these results might change under alternative 
conditions--optimistic or pessimistic assumptions. For example, for 
owners who were below the benchmark on both balances and contributions 
under the baseline (see app. II, table 5), we assessed the status of 
their trust funds under optimistic conditions to determine which of 
these owner's funds would still remain below benchmark on both our 
looking-backward and looking-forward measures. In addition, for owners 
who were from zero to 100 percent above the benchmark, under baseline 
assumptions for either balances or contributions, we assessed the 
status of their funds under pessimistic assumptions to determine 
whether their funds would fall below benchmarks for both balances and 
contributions (see app. II, table 6).[Footnote 25]

Key Data Used in Analysis:

To conduct our analysis we used a spreadsheet simulation model that 
uses a base year of 2000. In addition, for the key data in our 
analysis, we used the owner's 2001 biennial reports and responses from 
a mail survey that we administered to nuclear power plant owners.

More specifically, the key data used in the model are the following:

(1) Owner's name, percentage of each plant in which the owner has a 
share, year the plant was licensed to operate (or commenced operation, 
if earlier), and year the plant's license will expire. We obtained 
these data using the owners' 2001 biennial reports to Nuclear 
Regulatory Commission (NRC) and other NRC publications.

(2) A decommissioning cost estimate for each plant (that is, a current 
dollar amount for the year that the estimate was made). When available, 
we used a site-specific estimate of NRC-related costs (that is, 
radiation-related costs). If a site-specific estimate was not 
available, we used cost estimates derived from NRC's generic formula 
for these NRC-related costs. We obtained these data using the owners' 
2001 biennial reports to NRC.

(3) Decommissioning fund balances as of December 31, 2000 for each 
owner and its plant share. When indicated, we used that portion of the 
fund balance that the owner designated for NRC-type costs (that is, 
excluding the costs relating to nonradiation or spent-fuel activities). 
Otherwise we used the entire fund balance. We obtained these data from 
the owners' responses to our survey or from their 2001 biennial 
reports.

(4) Decommissioning fund contributions for 1999 and 2000 for each owner 
and its plant share. We assumed these contributions were for NRC-
related costs only. We obtained these data from the responses to our 
survey, and for owners who did not respond to our survey, we do not 
report on the adequacy of their contributions.

In some cases, the ownership shares of plants have changed hands since 
our survey and the 2001 biennial reports. In these cases, to make our 
analysis as current as possible, we assess the adequacy of the funds 
that were accumulated by the previous owner but report the results 
under the name of the new owner of the trust fund (see app. II, table 
4). Nonetheless, the new owner might accumulate trust funds at a 
different rate than the former owner.

Key Assumptions Used in the Analysis:

The analysis of the industry-wide trust funds and the individual 
owners' trust funds depends on the following six key assumptions. The 
values for these six assumptions vary based upon the scenario: baseline 
(most likely), pessimistic, or optimistic. For each scenario, we used 
the same assumption values for each owner and each plant in order to 
apply an "even-handed" standard.

(1) Future after-tax rate of return on decommissioning fund assets 
(discount rate): An after-tax rate of return was used to discount 
future trust fund contributions and plant decommissioning costs. In our 
survey, we asked owners for information on the financial assets 
contained in their respective decommissioning funds. We grouped these 
assets into five basic financial categories and calculated estimated, 
industry-wide, average weights for each type, these asset weights 
themselves reflecting the weights of the varying fund sizes. These 
categories, and calculated weighted-averages were: equities (e.g., 
common stocks), 47.1 percent; U.S. securities (e.g., federal government 
bonds), 26.7 percent; corporate bonds, 9.8 percent; municipal bonds, 
10.4 percent; and cash and short-term instruments, 6.0 percent. 
Therefore, on average, these decommissioning funds contained roughly a 
50-50 split between equities and bonds. We used these results for all 
of the decommissioning funds, for all three scenarios, but recognize 
three qualifications: (1) the variation in these asset weights among 
individual funds for 2000 was quite large, (2) our asset composition 
data represent only a time "snapshot" of such allocation--for year 2000 
only, and (3) these same (baseline) asset weights are also assumed for 
our other two scenarios, because appropriate data were lacking to do 
otherwise.

Using a long-term forecast from Global Insight (an economic forecasting 
company),[Footnote 26] we developed a forecast for each asset category 
under a baseline, pessimistic, and optimistic forecast scenario. For 
the baseline scenario, we used Global Insight's trend forecast; for the 
pessimistic scenario, we used their pessimistic forecast (representing 
slower real gross domestic product (GDP) growth); and for the 
optimistic scenario, we used their optimistic forecast (representing 
faster real GDP growth).

For the baseline scenario, we calculated a forecast (current-dollar) 
growth rate of 6.26 percent for equities, 6.83 percent for U.S. 
securities, 7.83 percent for corporate bonds, 6.27 percent for 
municipal bonds, and 5.02 percent for cash and short-term 
instruments.[Footnote 27] Multiplying these forecast rates with their 
respective asset weights in the owners' portfolios yielded a baseline 
"portfolio average" forecast pretax annual-average rate of return of 
6.49 percent. Similarly, we calculated pretax rates of return for the 
pessimistic and optimistic forecasts of 7.27 percent and 6.45 percent, 
respectively. The rate under the pessimistic forecast is higher than 
the rate under the baseline or optimistic forecasts because of higher 
inflation in the Global Insight pessimistic forecast and because of the 
owners' relatively high average allocation of trust fund investments in 
bonds. (In Global Insight's pessimistic forecast, the nominal-rate 
return on bonds is greater than on equities.):

To convert the "portfolio average" forecast pretax rate of return to an 
after-tax rate of return, we used the pre-and post-tax rates of return 
data that owners provided in our survey. Based on these data we 
determined that the pretax rate should be reduced by 0.87 percentage 
points to derive a baseline after-tax rate of return of 5.62 (6.49 - 
0.87) percent.[Footnote 28] Similarly, we calculated an after-tax rate 
of return of 6.40 (7.27 - 0.87) percent for the pessimistic scenario 
and an after-tax rate of return of 5.58 (6.45 - 0.87) percent for the 
optimistic scenario.

(2) Future decommissioning cost escalation rate: For our baseline 
scenario, we assumed that decommissioning costs would increase annually 
at a nominal rate of 4.60 percent.[Footnote 29] Combining the after-tax 
rate of return and the cost escalation rate gave us an implied real 
(cost-adjusted) after-tax rate of return of 1.02 (5.62 - 4.60) percent 
for the baseline scenario.

To calculate real after-tax rates of return for the pessimistic and 
optimistic scenarios, we first adjusted the nominal after-tax rates of 
return using Global Insight's inflation forecasts. Its annual-average 
inflation forecast was about 2.47 percent for trend, or baseline, 3.04 
percent for pessimistic, and 2.15 percent for optimistic. Using these 
forecasts, the real forecast rates of return are 3.15 (5.62 - 2.47) 
percent for baseline, 3.36 (6.40 - 3.04) percent for pessimistic, and 
3.43 (5.58 - 2.15) percent for optimistic. We then used proportionality 
ratios to obtain real cost adjusted after-tax rates of return of 1.09 
percent for the pessimistic scenario and 1.11 percent for the 
optimistic scenario.[Footnote 30] From these real after-tax rates of 
return, we 
computed implied cost-escalation rates of 5.31 percent and 4.47 percent 
for the pessimistic and optimistic scenarios, respectively.[Footnote 
31]

Note that the real (cost-adjusted) after-tax rates of return are quite 
similar in value among our scenarios; therefore, any differing effect 
on model results caused by the combination of the fund rate of return 
and decommissioning cost-escalation assumptions will be fairly minimal. 
Nonetheless, all other things being equal, for these two assumptions 
only, the balance and contribution adequacy results for the pessimistic 
scenario will be slightly above those of the baseline scenario, and 
only slightly below those of the optimistic scenario.

(3) Alternative initial decommissioning cost estimates: In our baseline 
scenario, for the "initial" decommissioning (NRC-related) costs, we 
used the site-specific estimates when available. Otherwise, we used the 
cost estimates derived from NRC's generic formula. For the pessimistic 
and optimistic scenarios, we used professional judgment to adjust the 
estimate used in the baseline. For example, to reflect a general 
concern among industry observers that future decommissioning costs 
could be much higher than expected, we increased the initial cost 
estimate by 40 percent for the pessimistic scenario, and reduced the 
initial decommissioning cost estimate by only 5 percent for the 
optimistic scenario.

(4) Alternative start of decommissioning--years after shutdown: For the 
baseline scenario, we assumed that decommissioning would occur within 
the immediate 5 years after license termination; for simplification, we 
assumed "instantaneous" decommissioning at 2.5 years after 
shutdown.[Footnote 32] For the pessimistic assumption, decommissioning 
is assumed to occur within the first 4 years--at 2 years after 
shutdown. For the optimistic assumption, we assumed a 5-year delayed 
start of decommissioning--within 5-10 years after license termination-
-at 7.5 years after shutdown. Under certain circumstances (e.g., co-
located plants), NRC may permit a decommissioning delay. As long as the 
assumed after-tax rate of return exceeds the assumed cost-escalation 
rate (i.e., a positive, real, cost-adjusted rate of return), a delay in 
decommissioning will improve the outlook for an owner's trust fund in 
both the looking-backward (trust fund balance) and looking-forward 
(trust fund contributions) analysis, all else the same.

(5) Alternative operating license expiration year: The year of plant 
operating-license expiration is assumed to vary among our three 
scenarios to reflect that NRC has approved license renewals for some 
plants, and it may approve 20-year license renewals for other plants in 
the future. For the baseline and pessimistic scenarios, we include the 
renewals that have been approved for 16 plants, as of August 20, 
2003.[Footnote 33] In addition, because NRC has received renewal 
applications from owners of 14 plants, and it anticipates applications 
from owners of another 8 plants by the end of 2003 (as of August 20, 
2003), we assume in the optimistic scenario that license renewals will 
be approved for an additional 22 plants.[Footnote 34] In general, these 
plant license renewals suggest that the electricity market today is 
robust and owners expect higher electricity prices in the 
future.[Footnote 35]

(6) Alternative market values for decommissioning funds: For the 
baseline and optimistic scenarios, we use the actual market value of 
the trust fund balances as of the end of 2000. In contrast, for the 
pessimistic scenario, we reduced the actual market value of the funds 
by 5 percent for 2000 to simulate the effect of a slowing economy on 
investment returns from 2000 through 2002. The simulated decline is 
modest, and over the period, the overall increase in bond prices would 
have offset to some degree the overall decline in the value of common 
stocks.

[End of section]

Appendix II: Detailed Results of Our Analysis of the Decommissioning 
Trust Funds:

This appendix presents the detailed results of our analysis of the 
decommissioning trust funds. Specifically, table 3 shows industry-wide, 
weighted-average results under three scenarios--baseline (most likely) 
assumptions, pessimistic assumptions, and optimistic assumptions. 
Table 4 presents the results for individual owners under baseline, or 
most likely assumptions. Table 5 shows the results of our analysis 
under optimistic assumptions for individual owners whose trust funds 
were below the benchmarks for both balances and recent contributions 
under the baseline scenario. Table 6 presents the results under 
pessimistic assumptions for individual owners whose trust funds were 
zero to 100 percent above the benchmark balances and/or contributions 
under the baseline scenario. See appendix I for a description of our 
methodology.

Table 3: Status of Combined Trust Funds Compared with Benchmarks for 
Balances and Contributions (by Percentage above or below Benchmarks):

Analysis category: Balances through 2000; Number of owners: 99; Number 
of plants: 122; Scenario: Baseline[A]: (percent): 46.9; 
Scenario: Pessimistic[A]: (percent): 0.2; Scenario: Optimistic[B]: 
(percent): 82.5.

Analysis category: Recent Contributions[C]; Number of owners: 75; 
Number of plants: 109; Scenario: Baseline[A]: (percent): 
106.5; Scenario: Pessimistic[A]: (percent): -18.0; Scenario: 
Optimistic[B]: (percent): 224.4.

Source: GAO analysis.

Note: Percentages are weighted averages, measured relative to the 
benchmark balances or benchmark contributions.

[A] The baseline and pessimistic scenarios include the 20-year license 
renewals already granted for 16 plants, as of August 20, 2003.

[B] The optimistic scenario includes 20-year license renewals for 38 
plants, including renewals: (1) already granted for 16 plants, (2) for 
another 14 plants whose owners have applied for but not yet received 
renewals, and (3) for another 8 plants whose owners are expected to 
apply by December 2003 (all as of August 20, 2003).

[C] Adequacy of recent contributions is based on responses to our 
survey. The percentages are more, or less, than the benchmark 
contribution, meaning the owner has contributed more, or less, on 
average for 1999 and 2000 (cost adjusted to 2000) than the annual 
average of the present value of the amounts required in each subsequent 
year until the plant's license expires.

[End of table]

Table 4: Owners with More, or Less, Than Benchmark Trust Fund Balances 
and Contributions, under Most Likely Assumptions (by Percentage above 
or below Benchmarks):

Plant name: Arkansas; Nuclear 1[B]; Owner: Entergy Arkansas, Inc.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Arkansas; Nuclear 2[C]; Owner: Entergy Arkansas, Inc.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _.

Plant name: Beaver Valley 1; Owner: Ohio Edison Co.; Ownership share of 
plant (percent): 35; Baseline (most likely) scenario: Adequacy 
of trust fund balances as of end of 2000: +; Baseline (most likely) 
scenario: Adequacy of recent trust fund contributions[A]: +.

Plant name: Beaver Valley 1; Owner: Pennsylvania Power Co.; Ownership 
share of plant (percent): 65; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: _; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: _ _ 
_.

Plant name: Beaver Valley 2; Owner: Cleveland Electric Illuminating 
Co.; Ownership share of plant (percent): 24.47; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: +.

Plant name: Beaver Valley 2; Owner: Ohio Edison Co.; Ownership share of 
plant (percent): 41.88; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + +; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: _.

Plant name: Beaver Valley 2; Owner: Pennsylvania Power Co.; Ownership 
share of plant (percent): 13.74; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Beaver Valley 2; Owner: Toledo Edison Co.; Ownership share 
of plant (percent): 19.91; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + +; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: + +.

Plant name: Big Rock Point[D]; Owner: Consumers Energy Co.; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: Braidwood 1; Owner: Exelon Generation Co., LLC; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Braidwood 2; Owner: Exelon Generation Co., LLC; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Browns Ferry 1[C]; Owner: Tennessee Valley Authority; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: _ 
_; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Browns Ferry 2[C]; Owner: Tennessee Valley Authority; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: _ 
_; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Browns Ferry 3[C]; Owner: Tennessee Valley Authority; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: _ 
_; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Brunswick 1; Owner: North Carolina Eastern Municipal; 
Ownership share of plant (percent): 18.33; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: +.

Plant name: Brunswick 1[F]; Owner: Progress Energy Carolinas, Inc.; 
Ownership share of plant (percent): 81.67; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: _ 
_; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _.

Plant name: Brunswick 2; Owner: North Carolina Eastern Municipal; 
Ownership share of plant (percent): 18.33; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: +.

Plant name: Brunswick 2[ F]; Owner: Progress Energy Carolinas, Inc.; 
Ownership share of plant (percent): 81.67; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: _ 
_; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: +.

Plant name: Byron 1; Owner: Exelon Generation Co., LLC; Ownership share 
of plant (percent): 100; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + + +; Baseline 
(most likely) scenario: Adequacy of recent trust fund contributions[A]: 
_ _ _.

Plant name: Byron 2; Owner: Exelon Generation Co., LLC; Ownership share 
of plant (percent): 100; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + + +; Baseline 
(most likely) scenario: Adequacy of recent trust fund contributions[A]: 
+ + +.

Plant name: Callaway; Owner: AmerenUE; Ownership share of plant 
(percent): 100; Baseline (most likely) scenario: Adequacy of 
trust fund balances as of end of 2000: +; Baseline (most likely) 
scenario: Adequacy of recent trust fund contributions[A]: _ _.

Plant name: Calvert Cliffs 1[B]; Owner: Constellation Energy Group; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: Calvert Cliffs 2[B]; Owner: Constellation Energy Group; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: Catawba 1[H]; Owner: Duke Power Co.; Ownership share of 
plant (percent): 12.50; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: +; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: + + 
+.

Plant name: Catawba 1[H]; Owner: North Carolina Electric Membership; 
Ownership share of plant (percent): 28.1; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Catawba 1[H]; Owner: North Carolina Municipal Power; 
Ownership share of plant (percent): 37.50; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: +.

Plant name: Catawba 1[H]; Owner: Piedmont Municipal Power Agency; 
Ownership share of plant (percent): 12.50; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + +.

Plant name: Catawba 1[H]; Owner: Saluda River Electric Cooperative; 
Ownership share of plant (percent): 9.38; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Catawba 2[H]; Owner: Duke Power Co.; Ownership share of 
plant (percent): 12.5; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + +; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: + + + 
+.

Plant name: Catawba 2[H]; Owner: North Carolina Electric Membership; 
Ownership share of plant (percent): 28.1; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Catawba 2[H]; Owner: North Carolina Municipal Power; 
Ownership share of plant (percent): 37.5; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: +.

Plant name: Catawba 2[H]; Owner: Piedmont Municipal Power Agency; 
Ownership share of plant (percent): 12.5; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + +.

Plant name: Catawba 2[H]; Owner: Saluda River Electric Cooperative; 
Ownership share of plant (percent): 9.38; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Clinton; Owner: AmerGen Energy Co., Inc.; Ownership share 
of plant (percent): 100; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + + + +; Baseline 
(most likely) scenario: Adequacy of recent trust fund contributions[A]: 
+ + +.

Plant name: Columbia Generating Station; Owner: Energy Northwest; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _.

Plant name: Comanche Peak 1; Owner: Texas Utility Electric Co.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Comanche Peak 2; Owner: Texas Utility Electric Co.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Cook, D.C. 1[C]; Owner: Indiana Michigan Power Co.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: Cook, D.C. 2[C]; Owner: Indiana Michigan Power Co.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Cooper; Owner: Nebraska Public Power District; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Crystal River 3; Owner: City of Alachua Electric Dept.; 
Ownership share of plant (percent): 0.08; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: Crystal River 3; Owner: City of Bushnell Utility Dept.; 
Ownership share of plant (percent): 0.04; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: Crystal River 3; Owner: City of Gainesville Regional 
Utilities; Ownership share of plant (percent): 1.41; Baseline 
(most likely) scenario: Adequacy of trust fund balances as of end of 
2000: +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Crystal River 3; Owner: City of Kissimmee Utilities; 
Ownership share of plant (percent): 0.68; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: Crystal River 3; Owner: City of Leesburg Municipal 
Electric; Ownership share of plant (percent): 0.82; Baseline 
(most likely) scenario: Adequacy of trust fund balances as of end of 
2000: +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: Crystal River 3; Owner: City of Ocala Utilities Division; 
Ownership share of plant (percent): 1.33; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: Crystal River 3; Owner: New Smyrna Beach Utilities Comm.; 
Ownership share of plant (percent): 0.56; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[ E].

Plant name: Crystal River 3; Owner: Orlando Utilities Comm.; Ownership 
share of plant (percent): 1.60; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: Crystal River 3; Owner: Progress Energy Florida; Ownership 
share of plant (percent): 91.8; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[ E].

Plant name: Crystal River 3; Owner: Seminole Electric Cooperative, 
Inc.; Ownership share of plant (percent): 1.7; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + +.

Plant name: Davis-Besse; Owner: Cleveland Electric Illuminating Co.; 
Ownership share of plant (percent): 51.38; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Davis-Besse; Owner: Toledo Edison Co.; Ownership share of 
plant (percent): 48.62; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: +; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: + + + 
+.

Plant name: Diablo Canyon 1; Owner: Pacific Gas & Electric Co.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: Diablo Canyon 2; Owner: Pacific Gas & Electric Co.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: Dresden 1[D]; Owner: Exelon Generation Co., LLC; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: _ _ _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Dresden 2[H]; Owner: Exelon Generation Co., LLC; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Dresden 3[H]; Owner: Exelon Generation Co., LLC; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Duane Arnold; Owner: Central Iowa Power Cooperative; 
Ownership share of plant (percent): 20; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: _ _ _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Duane Arnold; Owner: Corn Belt Power Cooperative; Ownership 
share of plant (percent): 10; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: _ _; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: _ _.

Plant name: Duane Arnold; Owner: IPL; Ownership share of plant 
(percent): 70; Baseline (most likely) scenario: Adequacy of 
trust fund balances as of end of 2000: _ _; Baseline (most likely) 
scenario: Adequacy of recent trust fund contributions[A]: _ _.

Plant name: Farley 1[C]; Owner: Alabama Power Co.; Ownership share of 
plant (percent): 100; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: +; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: + + + 
+.

Plant name: Farley 2[C]; Owner: Alabama Power Co.; Ownership share of 
plant (percent): 100; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + +; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: + + + 
+.

Plant name: Fermi 1[D]; Owner: Detroit Edison Co.; Ownership share of 
plant (percent): 100; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: _; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: _ _ 
_.

Plant name: Fermi 2; Owner: Detroit Edison Co.; Ownership share of 
plant (percent): 100; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + + +; Baseline 
(most likely) scenario: Adequacy of recent trust fund contributions[A]: 
+ + + +.

Plant name: FitzPatrick; Owner: Entergy Nuclear Operations, Inc.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: Fort Calhoun[H]; Owner: Omaha Public Power District; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Ginna[H]; Owner: Rochester Gas & Electric Corp.; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: Grand Gulf 1; Owner: South Mississippi Electric Power; 
Ownership share of plant (percent): 10; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: _ _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Grand Gulf 1; Owner: System Energy Resources, Inc.; 
Ownership share of plant (percent): 90; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Haddam Neck[D]; Owner: Connecticut Yankee Atomic Power Co.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[ E].

Plant name: Harris 1; Owner: North Carolina Eastern Municipal; 
Ownership share of plant (percent): 16.17; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _.

Plant name: Harris 1; Owner: Progress Energy Carolinas, Inc.; Ownership 
share of plant (percent): 83.83; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: +.

Plant name: Hatch 1[B]; Owner: City of Dalton (Georgia); Ownership 
share of plant (percent): 2.2; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [E, G].

Plant name: Hatch 1[B]; Owner: Georgia Power Co.; Ownership share of 
plant (percent): 50.1; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + + +; Baseline 
(most likely) scenario: Adequacy of recent trust fund contributions[A]: 
+ + + +.

Plant name: Hatch 1[B]; Owner: Municipal Electric Authority of Georgia; 
Ownership share of plant (percent): 17.7; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Hatch 1[B]; Owner: Oglethorpe Power Co.; Ownership share of 
plant (percent): 30; Baseline (most likely) scenario: Adequacy 
of trust fund balances as of end of 2000: + + +; Baseline (most likely) 
scenario: Adequacy of recent trust fund contributions[A]: + + + +.

Plant name: Hatch 2[B]; Owner: City of Dalton (Georgia); Ownership 
share of plant (percent): 2.2; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [E, G].

Plant name: Hatch 2[B]; Owner: Georgia Power Co.; Ownership share of 
plant (percent): 50.1; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + + + +; Baseline 
(most likely) scenario: Adequacy of recent trust fund contributions[A]: 
+ + + +.

Plant name: Hatch 2[B]; Owner: Municipal Electric Authority of Georgia; 
Ownership share of plant (percent): 17.7; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Hatch 2[B]; Owner: Oglethorpe Power Co.; Ownership share of 
plant (percent): 30; Baseline (most likely) scenario: Adequacy 
of trust fund balances as of end of 2000: + + +; Baseline (most likely) 
scenario: Adequacy of recent trust fund contributions[A]: + +.

Plant name: Hope Creek 1; Owner: PSEG Nuclear, LLC; Ownership share of 
plant (percent): 100; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + + + +[ I]; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: Humboldt Bay 3[D]; Owner: Pacific Gas & Electric Co.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: Indian Point 1[D, F]; Owner: Entergy Nuclear Operations, 
Inc.; Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: _ 
_ _[ I]; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _[I].

Plant name: Indian Point 2; Owner: Entergy Nuclear Operations, Inc.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Indian Point 3; Owner: Entergy Nuclear Operations, Inc.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: Kewaunee; Owner: Wisconsin Power & Light; Ownership share 
of plant (percent): 41; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + + + +; Baseline 
(most likely) scenario: Adequacy of recent trust fund contributions[A]: 
+ + + +[E].

Plant name: Kewaunee; Owner: Wisconsin Public Service Corporation; 
Ownership share of plant (percent): 59; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + + 
+[I]; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E, I].

Plant name: LaCrosse[D, F]; Owner: Dairyland Power Cooperative; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: LaSalle County 1; Owner: Exelon Generation Co., LLC; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _.

Plant name: LaSalle County 2; Owner: Exelon Generation Co., LLC; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + +.

Plant name: Limerick 1[J]; Owner: Exelon Generation Co., LLC; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Limerick 2[J]; Owner: Exelon Generation Co., LLC; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _.

Plant name: Maine Yankee[D]; Owner: Maine Yankee Atomic Power Co.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: _ 
_; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _.

Plant name: McGuire 1[H]; Owner: Duke Power Co.; Ownership share of 
plant (percent): 100; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: +; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: + + 
+.

Plant name: McGuire 2[H]; Owner: Duke Power Co.; Ownership share of 
plant (percent): 100; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: +; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: + + + 
+.

Plant name: Millstone 1[D, F, J]; Owner: Dominion; Nuclear Connecticut; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: Millstone 2; Owner: Dominion; Nuclear Connecticut; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: Millstone 3; Owner: Central Vermont Public Service; Corp.; 
Ownership share of plant (percent): 1.73; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: Millstone 3; Owner: Dominion; Nuclear Connecticut; 
Ownership share of plant (percent): 93.47; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [E, G].

Plant name: Millstone 3; Owner: Massachusetts Municipal Wholesale 
Electric Co.; Ownership share of plant (percent): 4.80; 
Baseline (most likely) scenario: Adequacy of trust fund balances as of 
end of 2000: + + + +; Baseline (most likely) scenario: Adequacy of 
recent trust fund contributions[A]: [G].

Plant name: Monticello; Owner: Xcel Energy; Ownership share of plant 
(percent): 100; Baseline (most likely) scenario: Adequacy of 
trust fund balances as of end of 2000: _; Baseline (most likely) 
scenario: Adequacy of recent trust fund contributions[A]: + +.

Plant name: Nine Mile Point 1[F]; Owner: Constellation Energy Group; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: 
_[I]; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: Nine Mile Point 2; Owner: Constellation Energy Group; 
Ownership share of plant (percent): 82; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + +[ I]; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: Nine Mile Point 2; Owner: Long Island Power Authority; 
Ownership share of plant (percent): 18; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: North Anna 1[B, K]; Owner: Old Dominion Cooperative; 
Ownership share of plant (percent): 10.4; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [E, G].

Plant name: North Anna 1[B, K]; Owner: Virginia Electric & Power Co.; 
Ownership share of plant (percent): 89.6; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: North Anna 2[B, K]; Owner: Old Dominion Cooperative; 
Ownership share of plant (percent): 10.4; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [E, G].

Plant name: North Anna 2[B, K]; Owner: Virginia Electric & Power Co.; 
Ownership share of plant (percent): 89.6; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Oconee 1[B]; Owner: Duke Power Co.; Ownership share of 
plant (percent): 100; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + +; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: + + + 
+.

Plant name: Oconee 2[B]; Owner: Duke Power Co.; Ownership share of 
plant (percent): 100; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + +; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: + + + 
+.

Plant name: Oconee 3[B]; Owner: Duke Power Co.; Ownership share of 
plant (percent): 100; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + + +; Baseline 
(most likely) scenario: Adequacy of recent trust fund contributions[A]: 
+ + + +.

Plant name: Oyster Creek; Owner: AmerGen Energy Co., Inc.; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: Palisades; Owner: Consumers Energy Co.; Ownership share of 
plant (percent): 100; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + + + +; Baseline 
(most likely) scenario: Adequacy of recent trust fund contributions[A]: 
+ + + +[E].

Plant name: Palo Verde 1; Owner: Arizona Public Service Co.; Ownership 
share of plant (percent): 29.1; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Palo Verde 1; Owner: El Paso Electric Co.; Ownership share 
of plant (percent): 15.8; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: _; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: +.

Plant name: Palo Verde 1; Owner: Los Angeles Dept. of Water & Power; 
Ownership share of plant (percent): 5.7; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: Palo Verde 1; Owner: Public Service Company of New Mexico; 
Ownership share of plant (percent): 10.2; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Palo Verde 1; Owner: Salt River Project Agricultural 
Improvement & Power District; Ownership share of plant (percent): 
17.49; Baseline (most likely) scenario: Adequacy of trust fund 
balances as of end of 2000: + + +; Baseline (most likely) scenario: 
Adequacy of recent trust fund contributions[A]: [G].

Plant name: Palo Verde 1; Owner: Southern California Edison Co.; 
Ownership share of plant (percent): 15.8; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [E, G].

Plant name: Palo Verde 1; Owner: Southern California Public Power; 
Ownership share of plant (percent): 5.91; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: Palo Verde 2; Owner: Arizona Public Service Co.; Ownership 
share of plant (percent): 29.1; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Palo Verde 2; Owner: El Paso Electric Co.; Ownership share 
of plant (percent): 15.8; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: _; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: _.

Plant name: Palo Verde 2; Owner: Los Angeles Dept. of Water & Power; 
Ownership share of plant (percent): 5.70; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: Palo Verde 2; Owner: Public Service Company of New Mexico; 
Ownership share of plant (percent): 10.2; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + +.

Plant name: Palo Verde 2; Owner: Salt River Project Agricultural 
Improvement & Power District; Ownership share of plant (percent): 
17.49; Baseline (most likely) scenario: Adequacy of trust fund 
balances as of end of 2000: + + +; Baseline (most likely) scenario: 
Adequacy of recent trust fund contributions[A]: [G].

Plant name: Palo Verde 2; Owner: Southern California Edison Co.; 
Ownership share of plant (percent): 15.8; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [E, G].

Plant name: Palo Verde 2; Owner: Southern California Public Power; 
Ownership share of plant (percent): 5.91; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: Palo Verde 3; Owner: Arizona Public Service Co.; Ownership 
share of plant (percent): 29.1; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + +.

Plant name: Palo Verde 3; Owner: El Paso Electric Co.; Ownership share 
of plant (percent): 15.80; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: _; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: +.

Plant name: Palo Verde 3; Owner: Los Angeles Dept. of Water & Power; 
Ownership share of plant (percent): 5.7; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: Palo Verde 3; Owner: Public Service Company of New Mexico; 
Ownership share of plant (percent): 10.2; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Palo Verde 3; Owner: Salt River Project Agricultural 
Improvement & Power District; Ownership share of plant (percent): 
17.49; Baseline (most likely) scenario: Adequacy of trust fund 
balances as of end of 2000: + + +; Baseline (most likely) scenario: 
Adequacy of recent trust fund contributions[A]: [G].

Plant name: Palo Verde 3; Owner: Southern California Edison Co.; 
Ownership share of plant (percent): 15.8; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [E, G].

Plant name: Palo Verde 3; Owner: Southern California Public Power; 
Ownership share of plant (percent): 5.91; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: Peach Bottom 1[D, J]; Owner: Exelon Generation Co., LLC; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: _ 
_ _; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Peach Bottom 2[B, J]; Owner: Exelon Generation Co., LLC; 
Ownership share of plant (percent): 50; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + +[I]; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + +.

Plant name: Peach Bottom 2[B]; Owner: PSEG Nuclear, LLC; Ownership 
share of plant (percent): 50; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + + +[ I]; Baseline 
(most likely) scenario: Adequacy of recent trust fund contributions[A]: 
[G].

Plant name: Peach Bottom 3[B, J]; Owner: Exelon Generation Co., LLC; 
Ownership share of plant (percent): 50; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + +[ I]; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Peach Bottom 3[B]; Owner: PSEG Nuclear, LLC; Ownership 
share of plant (percent): 50; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + + + +[ I]; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: Perry 1; Owner: Cleveland Electric Illuminating Co.; 
Ownership share of plant (percent): 44.85; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Perry 1; Owner: Ohio Edison Co.; Ownership share of plant 
(percent): 30; Baseline (most likely) scenario: Adequacy of 
trust fund balances as of end of 2000: + +; Baseline (most likely) 
scenario: Adequacy of recent trust fund contributions[A]: + + +.

Plant name: Perry 1; Owner: Pennsylvania Power Co.; Ownership share of 
plant (percent): 5.24; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: +; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: + + 
+.

Plant name: Perry 1; Owner: Toledo Edison Co.; Ownership share of plant 
(percent): 19.91; Baseline (most likely) scenario: Adequacy of 
trust fund balances as of end of 2000: + +; Baseline (most likely) 
scenario: Adequacy of recent trust fund contributions[A]: + + + +.

Plant name: Pilgrim 1; Owner: Entergy Nuclear Operations, Inc.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Point Beach 1; Owner: Wisconsin Electric Power Co.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: Point Beach 2; Owner: Wisconsin Electric Power Co.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: Prairie Island 1; Owner: Xcel Energy; Ownership share of 
plant (percent): 100; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: +; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: + + + 
+.

Plant name: Prairie Island 2; Owner: Xcel Energy; Ownership share of 
plant (percent): 100; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: +; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: + + + 
+.

Plant name: Quad Cities 1[H]; Owner: Exelon Generation Co., LLC; 
Ownership share of plant (percent): 75; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + +.

Plant name: Quad Cities 1[H]; Owner: MidAmerican Energy Holdings Co.; 
Ownership share of plant (percent): 25; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Quad Cities 2[H]; Owner: Exelon Generation Co., LLC; 
Ownership share of plant (percent): 75; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Quad Cities 2[H]; Owner: MidAmerican Energy Holdings Co.; 
Ownership share of plant (percent): 25; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: +.

Plant name: Rancho Seco[D]; Owner: Sacramento Municipal Utility 
District; Ownership share of plant (percent): 100; Baseline 
(most likely) scenario: Adequacy of trust fund balances as of end of 
2000: _ _; Baseline (most likely) scenario: Adequacy of recent trust 
fund contributions[A]: _ _ _.

Plant name: River Bend 1; Owner: Entergy Gulf States, Inc.; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Robinson 2[F, H]; Owner: Progress Energy Carolinas, Inc.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: _ 
_; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _.

Plant name: Salem 1; Owner: Exelon Generation Co., LLC; Ownership share 
of plant (percent): 42.59; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: _; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: _ _.

Plant name: Salem 1; Owner: PSEG Nuclear, LLC; Ownership share of plant 
(percent): 57.41; Baseline (most likely) scenario: Adequacy of 
trust fund balances as of end of 2000: + + +[ I]; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: [E, 
G].

Plant name: Salem 2; Owner: Exelon Generation Co., LLC; Ownership share 
of plant (percent): 42.59; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: _; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: _.

Plant name: Salem 2; Owner: PSEG Nuclear, LLC; Ownership share of plant 
(percent): 57.41; Baseline (most likely) scenario: Adequacy of 
trust fund balances as of end of 2000: + + +[ I]; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: [G].

Plant name: San Onofre 1[D]; Owner: San Diego Gas & Electric Co.; 
Ownership share of plant (percent): 20; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [E, G].

Plant name: San Onofre 1[D]; Owner: Southern California Edison Co.; 
Ownership share of plant (percent): 80; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [E, G].

Plant name: San Onofre 2; Owner: Anaheim Public Utilities Dept.; 
Ownership share of plant (percent): 3.16; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [E, G].

Plant name: San Onofre 2; Owner: Riverside Utilities Dept.; Ownership 
share of plant (percent): 1.79; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [E, G].

Plant name: San Onofre 2; Owner: San Diego Gas & Electric Co.; 
Ownership share of plant (percent): 20; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [E, G].

Plant name: San Onofre 2; Owner: Southern California Edison Co.; 
Ownership share of plant (percent): 75.05; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [E, G].

Plant name: San Onofre 3; Owner: Anaheim Public Utilities Dept.; 
Ownership share of plant (percent): 3.16; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [E, G].

Plant name: San Onofre 3; Owner: Riverside Utilities Dept.; Ownership 
share of plant (percent): 1.79; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [E, G].

Plant name: San Onofre 3; Owner: San Diego Gas & Electric Co.; 
Ownership share of plant (percent): 20; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [E, G].

Plant name: San Onofre 3; Owner: Southern California Edison Co.; 
Ownership share of plant (percent): 75.05; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [E, G].

Plant name: Saxton[D]; Owner: GPU Nuclear; Ownership share of plant 
(percent): 100; Baseline (most likely) scenario: Adequacy of 
trust fund balances as of end of 2000: + + + +; Baseline (most likely) 
scenario: Adequacy of recent trust fund contributions[A]: [E, G].

Plant name: Seabrook 1; Owner: FPL Energy; Ownership share of plant 
(percent): 88.2; Baseline (most likely) scenario: Adequacy of 
trust fund balances as of end of 2000: + + +[ I]; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: + + + 
+[I].

Plant name: Seabrook 1; Owner: Hudson Light & Power Dept.; Ownership 
share of plant (percent): 0.08; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Seabrook 1; Owner: Massachusetts Municipal Wholesale 
Electric Co.; Ownership share of plant (percent): 11.6; 
Baseline (most likely) scenario: Adequacy of trust fund balances as of 
end of 2000: + +; Baseline (most likely) scenario: Adequacy of recent 
trust fund contributions[A]: + + +.

Plant name: Seabrook 1; Owner: Taunton Municipal Lighting Plant; 
Ownership share of plant (percent): 0.1; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Sequoyah 1; Owner: Tennessee Valley Authority; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Sequoyah 2; Owner: Tennessee Valley Authority; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: South Texas Project 1; Owner: AEP (Texas Central Co.); 
Ownership share of plant (percent): 25.20; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +[ I]; Baseline (most likely) scenario: Adequacy of recent trust 
fund contributions[A]: + + + +[ I].

Plant name: South Texas Project 1; Owner: City of Austin--Austin; 
Energy; Ownership share of plant (percent): 16; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: South Texas Project 1; Owner: City Public Service Board of 
San Antonio; Ownership share of plant (percent): 28; Baseline 
(most likely) scenario: Adequacy of trust fund balances as of end of 
2000: + + +; Baseline (most likely) scenario: Adequacy of recent trust 
fund contributions[A]: + + + +.

Plant name: South Texas Project 1; Owner: Texas Genco; Ownership share 
of plant (percent): 30.80; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + + + +[ I]; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[I].

Plant name: South Texas Project 2; Owner: AEP (Texas Central Co.); 
Ownership share of plant (percent): 25.20; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +[ I]; Baseline (most likely) scenario: Adequacy of recent trust 
fund contributions[A]: + + + +[ I].

Plant name: South Texas Project 2; Owner: City of Austin--Austin 
Energy; Ownership share of plant (percent): 16; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: South Texas Project 2; Owner: City Public Service Board of 
San Antonio; Ownership share of plant (percent): 28; Baseline 
(most likely) scenario: Adequacy of trust fund balances as of end of 
2000: + + + +; Baseline (most likely) scenario: Adequacy of recent 
trust fund contributions[A]: + + + +.

Plant name: South Texas Project 2; Owner: Texas Genco; Ownership share 
of plant (percent): 30.80; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + + + +[ I]; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E, I].

Plant name: St Lucie 1[H]; Owner: Florida Power & Light Co.; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: St Lucie 2[H]; Owner: Florida Municipal Power Agency; 
Ownership share of plant (percent): 8.7; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: St Lucie 2[H]; Owner: Florida Power & Light Co.; Ownership 
share of plant (percent): 85.2; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: St Lucie 2[H]; Owner: Orlando Utilities Comm.; Ownership 
share of plant (percent): 6.05; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [E, G].

Plant name: Summer[H]; Owner: South Carolina Electric & Gas Co.; 
Ownership share of plant (percent): 66.67; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: _ 
_; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Summer[H]; Owner: South Carolina Public Service Authority; 
Ownership share of plant (percent): 33.33; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Surry 1[B]; Owner: Virginia Electric & Power Co.; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Surry 2[B]; Owner: Virginia Electric & Power Co.; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Susquehanna 1; Owner: Allegheny Electric Cooperative; 
Ownership share of plant (percent): 10; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: _ _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _.

Plant name: Susquehanna 1; Owner: PPL Susquehanna, LLC; Ownership share 
of plant (percent): 90; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: +; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: +.

Plant name: Susquehanna 2; Owner: Allegheny Electric Cooperative; 
Ownership share of plant (percent): 10; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: _ _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _.

Plant name: Susquehanna 2; Owner: PPL Susquehanna, LLC; Ownership share 
of plant (percent): 90; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: +; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: + + + 
+.

Plant name: Three Mile Island 1; Owner: AmerGen Energy Co., Inc.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: Three Mile Island; 2[D]; Owner: Jersey Central Power & 
Light; Ownership share of plant (percent): 25; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: _[ 
I]; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: Three Mile Island; 2[D]; Owner: Metropolitan Edison Co.; 
Ownership share of plant (percent): 50; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: _[ I]; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: Three Mile Island; 2[D]; Owner: Pennsylvania Electric Co.; 
Ownership share of plant (percent): 25; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: _[ I]; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: Trojan[D, F, J]; Owner: Eugene Water & Electric Board; 
Ownership share of plant (percent): 30; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: _ _ _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: [G].

Plant name: Trojan[D, F, J]; Owner: Pacific Power & Light Co.; 
Ownership share of plant (percent): 2.50; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Trojan[D, F, J]; Owner: Portland General Electric Co.; 
Ownership share of plant (percent): 67.50; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: _ 
_ _; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Turkey Point 3[B]; Owner: Florida Power & Light Co.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: Turkey Point 4[B]; Owner: Florida Power & Light Co.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +[E].

Plant name: Vermont Yankee; Owner: Entergy Nuclear Operations, Inc.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: +[ 
I]; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + +[I].

Plant name: Vogtle 1; Owner: City of Dalton (Georgia); Ownership share 
of plant (percent): 1.60; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + + + +; Baseline 
(most likely) scenario: Adequacy of recent trust fund contributions[A]: 
[E, G].

Plant name: Vogtle 1; Owner: Georgia Power Co.; Ownership share of 
plant (percent): 45.70; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + + + +; Baseline 
(most likely) scenario: Adequacy of recent trust fund contributions[A]: 
+ + + +.

Plant name: Vogtle 1; Owner: Municipal Electric Authority of Georgia; 
Ownership share of plant (percent): 22.70; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Vogtle 1; Owner: Oglethorpe Power Co.; Ownership share of 
plant (percent): 30; Baseline (most likely) scenario: Adequacy 
of trust fund balances as of end of 2000: +; Baseline (most likely) 
scenario: Adequacy of recent trust fund contributions[A]: _ _ _.

Plant name: Vogtle 2; Owner: City of Dalton (Georgia); Ownership share 
of plant (percent): 1.60; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + + + +; Baseline 
(most likely) scenario: Adequacy of recent trust fund contributions[A]: 
[E, G].

Plant name: Vogtle 2; Owner: Georgia Power Co.; Ownership share of 
plant (percent): 45.70; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: + + + +; Baseline 
(most likely) scenario: Adequacy of recent trust fund contributions[A]: 
+ + + +.

Plant name: Vogtle 2; Owner: Municipal Electric Authority of Georgia; 
Ownership share of plant (percent): 22.70; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: + 
+ + +; Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Vogtle 2; Owner: Oglethorpe Power Co.; Ownership share of 
plant (percent): 30; Baseline (most likely) scenario: Adequacy 
of trust fund balances as of end of 2000: _; Baseline (most likely) 
scenario: Adequacy of recent trust fund contributions[A]: _ _ _.

Plant name: Waterford 3; Owner: Entergy Louisiana, Inc.; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: +.

Plant name: Watts Bar 1; Owner: Tennessee Valley Authority; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: + + + +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Wolf Creek 1; Owner: Kansas City Power & Light Co.; 
Ownership share of plant (percent): 47; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: +; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _.

Plant name: Wolf Creek 1; Owner: Kansas Electric Power Cooperative; 
Ownership share of plant (percent): 6; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: _ _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Wolf Creek 1; Owner: Kansas Gas & Electric Co.; Ownership 
share of plant (percent): 47; Baseline (most likely) scenario: 
Adequacy of trust fund balances as of end of 2000: +; Baseline (most 
likely) scenario: Adequacy of recent trust fund contributions[A]: +.

Plant name: Yankee Rowe[D]; Owner: Yankee Atomic Electric Co.; 
Ownership share of plant (percent): 100; Baseline (most 
likely) scenario: Adequacy of trust fund balances as of end of 2000: _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: + + + +.

Plant name: Zion 1[D]; Owner: Exelon Generation Co., LLC; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: _ _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Plant name: Zion 2[D]; Owner: Exelon Generation Co., LLC; Ownership 
share of plant (percent): 100; Baseline (most likely) 
scenario: Adequacy of trust fund balances as of end of 2000: _ _ _; 
Baseline (most likely) scenario: Adequacy of recent trust fund 
contributions[A]: _ _ _.

Legend:

+ means that fund balance/recent contributions were 0 to 25 percent 
more than benchmark.

++ means that fund balance/recent contributions were 26 to 50 percent 
more than benchmark.

+++ means that fund balance/recent contributions were 51 to 100 percent 
more than benchmark.

++++ means that fund balance/recent contributions were 101 percent or 
more than benchmark.

_ means that fund balance/recent contributions were 0.1 to 25 percent 
less than benchmark.

_ _ means that fund balance/recent contributions were 26 to 50 percent 
less than benchmark.

_ _ _ means that fund balance/recent contributions were 51 to 100 
percent less than benchmark.

Source: GAO analysis.

[A] Adequacy of recent contributions is based on responses to our 
survey. The percentages are more, or less, than the benchmark, meaning 
the owner has contributed more, or less, on average for 1999 and 2000 
(cost adjusted to 2000) than the annual average of the present value 
amounts required in each subsequent year until its plant is retired.

[B] Plant's operating license extended for 20 years.

[C] Plants whose owners are expected to apply for 20-year license 
renewals by December 2003.

[D] Plant has permanently shut down.

[E] Trust fund balance exceeds present value of estimated 
decommissioning costs.

[F] Owner has, as of March 31, 2003, an additional method to support 
financial assurance obligations (e.g., parent company guarantee, 
statement of intent).

[G] Contributions data are not available.

[H] Plants whose owners have applied for 20-year license renewals, as 
of August 20, 2003.

[I] Includes balances and/or contributions from a previous owner's 
biennial report and/or responses to our survey.

[J] Owner had, as of March 31, 2001, an additional method to support 
financial assurance obligations (e.g., parent company guarantee, 
statement of intent).

[K] Liability is for decommissioning share and not ownership share.

[End of table]

Table 5: Selected Owners with More, or Less, Than Benchmark Trust Fund 
Balances and Contributions, under Optimistic Assumptions (by Percentage 
above or below Benchmarks):

Plant name: Beaver Valley 1; Owner[A]: Pennsylvania Power Co.; 
Ownership: share of plant (percent): 65; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: +; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
_ _ _.

Plant name: Browns Ferry 1[D]; Owner[A]: Tennessee Valley Authority; 
Ownership: share of plant (percent): 100; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: + +; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
_ _ _.

Plant name: Browns Ferry 2[D]; Owner[A]: Tennessee Valley Authority; 
Ownership: share of plant (percent): 100; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: + +; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
_ _ _.

Plant name: Browns Ferry 3[D]; Owner[A]: Tennessee Valley Authority; 
Ownership: share of plant (percent): 100; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: + +; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
_ _ _.

Plant name: Brunswick 1; Owner[A]: Progress Energy Carolinas, Inc.; 
Ownership: share of plant (percent): 81.67; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
+.

Plant name: Columbia Generating Station; Owner[A]: Energy Northwest; 
Ownership: share of plant (percent): 100; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
_ _.

Plant name: Dresden 1[E]; Owner[A]: Exelon Generation Co., LLC; 
Ownership: share of plant (percent): 100; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _ _ _; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
_ _ _ [G].

Plant name: Duane Arnold; Owner[A]: Central Iowa Power Cooperative; 
Ownership: share of plant (percent): 20; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _ _ _; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
_ _ _.

Plant name: Duane Arnold; Owner[A]: Corn Belt Power Cooperative; 
Ownership: share of plant (percent): 10; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _ _; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
_ _.

Plant name: Duane Arnold; Owner[A]: IPL; Ownership: share of plant 
(percent): 70; Optimistic scenario[B]: Adequacy of trust fund 
balances as of end of 2000: _; Optimistic scenario[B]: Adequacy of 
recent trust fund contributions[C]: _.

Plant name: Fermi 1[E]; Owner[A]: Detroit Edison Co.; Ownership: share 
of plant (percent): 100; Optimistic scenario[B]: Adequacy of 
trust fund balances as of end of 2000: +; Optimistic scenario[B]: 
Adequacy of recent trust fund contributions[C]: + + + +[F].

Plant name: Grand Gulf 1; Owner[A]: South Mississippi Electric Power; 
Ownership: share of plant (percent): 10; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
_ _ _.

Plant name: Indian Point 1[E]; Owner[A]: Entergy Nuclear Operations, 
Inc.; Ownership: share of plant (percent): 100; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _ _ 
_[G]; Optimistic scenario[B]: Adequacy of recent trust fund 
contributions[C]: _ _ _[G].

Plant name: LaCrosse[E]; Owner[A]: Dairyland Power Cooperative; 
Ownership: share of plant (percent): 100; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: +; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
+ + + +[ F].

Plant name: Limerick 1; Owner[A]: Exelon Generation Co., LLC; 
Ownership: share of plant (percent): 100; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
_ _.

Plant name: Limerick 2; Owner[A]: Exelon Generation Co., LLC; 
Ownership: share of plant (percent): 100; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
+.

Plant name: Maine Yankee[E]; Owner[A]: Maine Yankee; Atomic Power Co.; 
Ownership: share of plant (percent): 100; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
_.

Plant name: Palo Verde 2; Owner[A]: El Paso Electric Co.; Ownership: 
share of plant (percent): 15.80; Optimistic scenario[B]: 
Adequacy of trust fund balances as of end of 2000: +; Optimistic 
scenario[B]: Adequacy of recent trust fund contributions[C]: +.

Plant name: Peach Bottom 1[E]; Owner[A]: Exelon Generation Co., LLC; 
Ownership: share of plant (percent): 100; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _ _ _; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
_ _ _.

Plant name: Rancho Seco[E]; Owner[A]: Sacramento Municipal Utility 
District; Ownership: share of plant (percent): 100; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _ _; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
_ _ _.

Plant name: Robinson 2[D]; Owner[A]: Progress Energy Carolinas, Inc.; 
Ownership: share of plant (percent): 100; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: +; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
+ + + +.

Plant name: Salem 1; Owner[A]: Exelon Generation Co., LLC; Ownership: 
share of plant (percent): 42.59; Optimistic scenario[B]: 
Adequacy of trust fund balances as of end of 2000: _; Optimistic 
scenario[B]: Adequacy of recent trust fund contributions[C]: _.

Plant name: Salem 2; Owner[A]: Exelon Generation Co., LLC; Ownership: 
share of plant (percent): 42.59; Optimistic scenario[B]: 
Adequacy of trust fund balances as of end of 2000: +; Optimistic 
scenario[B]: Adequacy of recent trust fund contributions[C]: +.

Plant name: Sequoyah 1; Owner[A]: Tennessee Valley Authority; 
Ownership: share of plant (percent): 100; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
_ _ _.

Plant name: Sequoyah 2; Owner[A]: Tennessee Valley Authority; 
Ownership: share of plant (percent): 100; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: +; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
_ _ _.

Plant name: Summer[D]; Owner[A]: South Carolina Electric & Gas Co.; 
Ownership: share of plant (percent): 66.67; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: + +; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
+ +.

Plant name: Susquehanna 1; Owner[A]: Allegheny Electric Cooperative; 
Ownership: share of plant (percent): 10; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _ _; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
+.

Plant name: Susquehanna 2; Owner[A]: Allegheny Electric Cooperative; 
Ownership: share of plant (percent): 10; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _ _; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
+.

Plant name: Trojan[E]; Owner[A]: Portland General Electric Co.; 
Ownership: share of plant (percent): 67.50; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _ _; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
_ _.

Plant name: Vogtle 2; Owner[A]: Oglethorpe Power Co.; Ownership: share 
of plant (percent): 30; Optimistic scenario[B]: Adequacy of 
trust fund balances as of end of 2000: +; Optimistic scenario[B]: 
Adequacy of recent trust fund contributions[C]: _ _ _.

Plant name: Wolf Creek 1; Owner[A]: Kansas Electric; Power Cooperative; 
Ownership: share of plant (percent): 6; Optimistic 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _ _; 
Optimistic scenario[B]: Adequacy of recent trust fund contributions[C]: 
_ _.

Plant name: Zion 1[E]; Owner[A]: Exelon Generation Co., LLC; Ownership: 
share of plant (percent): 100; Optimistic scenario[B]: 
Adequacy of trust fund balances as of end of 2000: _ _; Optimistic 
scenario[B]: Adequacy of recent trust fund contributions[C]: _ _ _.

Plant name: Zion 2[E]; Owner[A]: Exelon Generation Co., LLC; Ownership: 
share of plant (percent): 100; Optimistic scenario[B]: 
Adequacy of trust fund balances as of end of 2000: _ _; Optimistic 
scenario[B]: Adequacy of recent trust fund contributions[C]: _ _ _.

Legend:

+ means that fund balance/recent contributions were 0 to 25 percent 
more than benchmark.

++ means that fund balance/recent contributions were 26 to 50 percent 
more than benchmark.

+++ means that fund balance/recent contributions were 51 to 100 percent 
more than benchmark.

++++ means that fund balance/recent contributions were 101 percent or 
more than benchmark.

_ means that fund balance/recent contributions were 0.1 to 25 percent 
less than benchmark.

_ _ means that fund balance/recent contributions were 26 to 50 percent 
less than benchmark.

_ _ _ means that fund balance/recent contributions were 51 to 100 
percent less than benchmark.

Source: GAO analysis.

[A] Owners' funds were selected to be screened under optimistic 
assumptions based on our baseline results; namely, that the status of 
their trust funds was below baseline benchmarks on both balances and 
contributions.

[B] See appendix I for description of optimistic assumptions.

[C] Adequacy of recent contributions is based on responses to our 
survey. The percentages are more, or less, than the benchmark, meaning 
the owner has contributed more, or less, on average for 1999 and 2000 
(cost adjusted to 2000) than the annual average of the present value 
amounts required in each subsequent year until its plant is retired.

[D] Plant whose owners have applied for 20-year license renewals or are 
expected to apply by December 2003, as of August 20, 2003.

[E] Plant has permanently shut down.

[F]Trust fund balance exceeds present value of estimated 
decommissioning cost.

[G] Includes balances and/or contributions from a previous owner's 
biennial report and/or responses to our survey.

[End of table]

Table 6: Selected Owners with More, or Less, Than Benchmark Trust Fund 
Balances and Contributions, under Pessimistic Assumptions (by 
Percentage above or below Benchmarks):

Plant name: Arkansas Nuclear 2[D]; Owner[A]: Entergy Arkansas, Inc.; 
Ownership: share of plant (percent): 100; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: _ _ _.

Plant name: Beaver Valley 1; Owner[A]: Ohio Edison Co.; Ownership: 
share of plant (percent): 35; Pessimistic assumptions 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _ _; 
Pessimistic assumptions scenario[B]: Adequacy of recent trust fund 
contributions[C]: _ _ _.

Plant name: Beaver Valley 2; Owner[A]: Cleveland Electric Illuminating 
Co.; Ownership: share of plant (percent): 24.47; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: _ _.

Plant name: Beaver Valley 2; Owner[A]: Ohio Edison Co.; Ownership: 
share of plant (percent): 41.88; Pessimistic assumptions 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _; 
Pessimistic assumptions scenario[B]: Adequacy of recent trust fund 
contributions[C]: _ _.

Plant name: Beaver Valley 2; Owner[A]: Toledo Edison Co.; Ownership: 
share of plant (percent): 19.91; Pessimistic assumptions 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _; 
Pessimistic assumptions scenario[B]: Adequacy of recent trust fund 
contributions[C]: _.

Plant name: Big Rock Point[E]; Owner[A]: Consumers Energy Co.; 
Ownership: share of plant (percent): 100; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _ _; Pessimistic assumptions scenario[B]: Adequacy of recent 
trust fund contributions[C]: _ _ _.

Plant name: Brunswick 1; Owner[A]: North Carolina Eastern Municipal; 
Ownership: share of plant (percent): 18.33; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _ _; Pessimistic assumptions scenario[B]: Adequacy of recent 
trust fund contributions[C]: _ _.

Plant name: Brunswick 2; Owner[A]: North Carolina Eastern Municipal; 
Ownership: share of plant (percent): 18.33; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _ _; Pessimistic assumptions scenario[B]: Adequacy of recent 
trust fund contributions[C]: _ _.

Plant name: Brunswick 2; Owner[A]: Progress Energy Carolinas, Inc.; 
Ownership: share of plant (percent): 81.67; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _ _; Pessimistic assumptions scenario[B]: Adequacy of recent 
trust fund contributions[C]: _ _.

Plant name: Callaway; Owner[A]: AmerenUE; Ownership: share of plant 
(percent): 100; Pessimistic assumptions scenario[B]: Adequacy 
of trust fund balances as of end of 2000: _ _; Pessimistic assumptions 
scenario[B]: Adequacy of recent trust fund contributions[C]: _ _ _.

Plant name: Calvert Cliffs 1[F]; Owner[A]: Constellation Energy Group; 
Ownership: share of plant (percent): 100; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: [G].

Plant name: Calvert Cliffs 2[F]; Owner[A]: Constellation Energy Group; 
Ownership: share of plant (percent): 100; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: [G].

Plant name: Catawba 1[D]; Owner[A]: Duke Power Co.; Ownership: share of 
plant (percent): 12.50; Pessimistic assumptions scenario[B]: 
Adequacy of trust fund balances as of end of 2000: _; Pessimistic 
assumptions scenario[B]: Adequacy of recent trust fund 
contributions[C]: _.

Plant name: Catawba 1[D]; Owner[A]: North Carolina Electric Membership; 
Ownership: share of plant (percent): 28.1; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _ _; Pessimistic assumptions scenario[B]: Adequacy of recent 
trust fund contributions[C]: _ _ _.

Plant name: Catawba 1[D]; Owner[A]: Piedmont Municipal Power Agency; 
Ownership: share of plant (percent): 12.5; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: _.

Plant name: Catawba 2[D]; Owner[A]: North Carolina Electric Membership; 
Ownership: share of plant (percent): 28.1; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: _ _ _.

Plant name: Crystal River 3; Owner[A]: City of Alachua Electric Dept.; 
Ownership: share of plant (percent): 0.08; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: [G].

Plant name: Crystal River 3; Owner[A]: City of Bushnell Utility Dept.; 
Ownership: share of plant (percent): 0.04; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: [G].

Plant name: Crystal River 3; Owner[A]: City of Kissimmee Utilities; 
Ownership: share of plant (percent): 0.68; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _ _; Pessimistic assumptions scenario[B]: Adequacy of recent 
trust fund contributions[C]: [G].

Plant name: Crystal River 3; Owner[A]: City of Leesburg Municipal 
Electric; Ownership: share of plant (percent): 0.82; 
Pessimistic assumptions scenario[B]: Adequacy of trust fund balances as 
of end of 2000: _ _; Pessimistic assumptions scenario[B]: Adequacy of 
recent trust fund contributions[C]: [G].

Plant name: Crystal River 3; Owner[A]: City of Ocala Utilities 
Division; Ownership: share of plant (percent): 1.33; 
Pessimistic assumptions scenario[B]: Adequacy of trust fund balances as 
of end of 2000: _ _; Pessimistic assumptions scenario[B]: Adequacy of 
recent trust fund contributions[C]: [G].

Plant name: Crystal River 3; Owner[A]: Seminole Electric Cooperative, 
Inc.; Ownership: share of plant (percent): 1.70; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: _ _.

Plant name: Dresden 2[D]; Owner[A]: Exelon Generation Co., LLC; 
Ownership: share of plant (percent): 100; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: _.

Plant name: Dresden 3[D]; Owner[A]: Exelon Generation Co., LLC; 
Ownership: share of plant (percent): 100; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: _.

Plant name: Farley 1[D]; Owner[A]: Alabama Power Co.; Ownership: share 
of plant (percent): 100; Pessimistic assumptions scenario[B]: 
Adequacy of trust fund balances as of end of 2000: _; Pessimistic 
assumptions scenario[B]: Adequacy of recent trust fund 
contributions[C]: _.

Plant name: Haddam Neck[E]; Owner[A]: Connecticut Yankee Atomic Power 
Co.; Ownership: share of plant (percent): 100; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: _ _ _.

Plant name: Harris 1; Owner[A]: North Carolina Eastern Municipal; 
Ownership: share of plant (percent): 16.17; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: _ _.

Plant name: Harris 1; Owner[A]: Progress Energy Carolinas, Inc.; 
Ownership: share of plant (percent): 83.83; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: _ _.

Plant name: Humboldt Bay 3[E]; Owner[A]: Pacific Gas & Electric Co.; 
Ownership: share of plant (percent): 100; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _ _; Pessimistic assumptions scenario[B]: Adequacy of recent 
trust fund contributions[C]: _ _ _.

Plant name: Indian Point 2; Owner[A]: Entergy Nuclear Operations, Inc.; 
Ownership: share of plant (percent): 100; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: _.

Plant name: Millstone 2; Owner[A]: Dominion Nuclear Connecticut; 
Ownership: share of plant (percent): 100; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: [G].

Plant name: Monticello; Owner[A]: Xcel Energy; Ownership: share of 
plant (percent): 100; Pessimistic assumptions scenario[B]: 
Adequacy of trust fund balances as of end of 2000: _ _; Pessimistic 
assumptions scenario[B]: Adequacy of recent trust fund 
contributions[C]: _ _.

Plant name: Palo Verde 1; Owner[A]: El Paso Electric Co.; Ownership: 
share of plant (percent): 15.8; Pessimistic assumptions 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _ _; 
Pessimistic assumptions scenario[B]: Adequacy of recent trust fund 
contributions[C]: _ _.

Plant name: Palo Verde 3; Owner[A]: El Paso Electric Co.; Ownership: 
share of plant (percent): 15.8; Pessimistic assumptions 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _ _; 
Pessimistic assumptions scenario[B]: Adequacy of recent trust fund 
contributions[C]: _ _.

Plant name: Palo Verde 3; Owner[A]: Public Service Co. of New Mexico; 
Ownership: share of plant (percent): 10.20; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: _ _ _.

Plant name: Peach Bottom 2[F]; Owner[A]: Exelon Generation Co., LLC; 
Ownership: share of plant (percent): 50; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _[H]; Pessimistic assumptions scenario[B]: Adequacy of recent 
trust fund contributions[C]: _.

Plant name: Pilgrim 1; Owner[A]: Entergy Nuclear Operations, Inc.; 
Ownership: share of plant (percent): 100; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: _ _ _.

Plant name: Prairie Island 1; Owner[A]: Xcel Energy; Ownership: share 
of plant (percent): 100; Pessimistic assumptions scenario[B]: 
Adequacy of trust fund balances as of end of 2000: _; Pessimistic 
assumptions scenario[B]: Adequacy of recent trust fund 
contributions[C]: _.

Plant name: Quad Cities 1[D]; Owner[A]: Exelon Generation Co., LLC; 
Ownership: share of plant (percent): 75; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: _ _ _.

Plant name: Quad Cities 2[D]; Owner[A]: Exelon Generation Co., LLC; 
Ownership: share of plant (percent): 75; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: _ _.

Plant name: Quad Cities 2[D]; Owner[A]: MidAmerica Energy Holdings; 
Ownership: share of plant (percent): 25; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _ _; Pessimistic assumptions scenario[B]: Adequacy of recent 
trust fund contributions[C]: _ _.

Plant name: Susquehanna 1; Owner[A]: PPL Susquehanna, LLC; Ownership: 
share of plant (percent): 90; Pessimistic assumptions 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _ _; 
Pessimistic assumptions scenario[B]: Adequacy of recent trust fund 
contributions[C]: _ _.

Plant name: Vermont Yankee; Owner[A]: Entergy Nuclear Operations, Inc.; 
Ownership: share of plant (percent): 100; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _ _[H]; Pessimistic assumptions scenario[B]: Adequacy of recent 
trust fund contributions[C]: _ _[H].

Plant name: Vogtle 1; Owner[A]: Oglethorpe Power Co.; Ownership: share 
of plant (percent): 30; Pessimistic assumptions scenario[B]: 
Adequacy of trust fund balances as of end of 2000: _ _; Pessimistic 
assumptions scenario[B]: Adequacy of recent trust fund 
contributions[C]: _ _ _.

Plant name: Waterford 3; Owner[A]: Entergy Louisiana, Inc.; Ownership: 
share of plant (percent): 100; Pessimistic assumptions 
scenario[B]: Adequacy of trust fund balances as of end of 2000: _ _; 
Pessimistic assumptions scenario[B]: Adequacy of recent trust fund 
contributions[C]: _ _.

Plant name: Wolf Creek 1; Owner[A]: Kansas City Power & Light Co.; 
Ownership: share of plant (percent): 47; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _ _; Pessimistic assumptions scenario[B]: Adequacy of recent 
trust fund contributions[C]: _ _.

Plant name: Wolf Creek 1; Owner[A]: Kansas Gas & Electric Co.; 
Ownership: share of plant (percent): 47; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _; Pessimistic assumptions scenario[B]: Adequacy of recent trust 
fund contributions[C]: _ _.

Plant name: Yankee Rowe[E]; Owner[A]: Yankee Atomic Electric Co.; 
Ownership: share of plant (percent): 100; Pessimistic 
assumptions scenario[B]: Adequacy of trust fund balances as of end of 
2000: _ _; Pessimistic assumptions scenario[B]: Adequacy of recent 
trust fund contributions[C]: _ _ _.

Legend:

+ means that fund balance/recent contributions were 0 to 25 percent 
more than benchmark.

++ means that fund balance/recent contributions were 26 to 50 percent 
more than benchmark.

+++ means that fund balance/recent contributions were 51 to 100 percent 
more than benchmark.

++++ means that fund balance/recent contributions were 101 percent or 
more than benchmark.

_ means that fund balance/recent contributions were 0.1 to 25 percent 
less than benchmark.

_ _ means that fund balance/recent contributions were 26 to 50 percent 
less than benchmark.

_ _ _ means that fund balance/recent contributions were 51 to 100 
percent less than benchmark.

Source: GAO analysis.

[A] Owners' funds were selected to be screened under pessimistic 
assumptions based on our baseline results; namely, that the status of 
their trust funds was 0 to 100 percent above baseline benchmark on 
balances and/or contributions.

[B] See app. I for description of pessimistic assumptions.

[C] Adequacy of recent contributions is based on responses to our survey. 
The percentages are more, or less, than the benchmark, meaning the 
owner has contributed more, or less, on average for 1999 and 2000 (cost 
adjusted to 2000) than the annual average of the present value amounts 
required in each subsequent year until its plant is retired.

[D] Plant whose owners have applied for 20-year license renewals or are 
expected to apply by December 2003, as of August 20, 2003.

[E] Plant has permanently shut down.

[F] Plant's operating license extended for 20 years.

[G] Contributions data are not available.

[H] Includes balances and/or contributions from a previous owner's 
biennial report and/or responses to our survey.

[End of table]

[End of section]

Appendix III: Comments from the Nuclear Regulatory Commission:

UNITED STATES:

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001:

October 3, 2003:

Mr. James E. Wells:

Director, Natural Resources and Environment: 
United States General Accounting Office:

441 G Street, NW Washington, D.C. 20548:

Dear Mr. Wells:

I would like to thank you for the opportunity to review and submit 
comments on the draft of the General Accounting Office's (GAO's) report 
entitled "Nuclear Regulation - NRC Needs More Effective Analysis to 
Ensure Accumulation of Funds to Decommission Nuclear Power Plants." The 
United States Nuclear Regulatory Commission (NRC) appreciates the time 
and effort that you and your staff have taken to review this topic.

GAO concludes that the NBC's analyses of funding levels of co-owners of 
a nuclear power plant are inconsistent with its internal guidance, the 
NRC does not have a method of determining whether licensees are 
accumulating funds at sufficient rates to pay for decommissioning, and 
the NRC needs to establish criteria for taking action when licensees 
are at unacceptable levels of funding assurance.

The NRC disagrees with GAO's first two conclusions and believes that to 
establish criteria for taking action when licensees are at unacceptable 
funding levels is secondary to its primary concern which is to assure 
that licensees are accumulating funds at appropriate rates. Further, in 
NBC's view, it is questionable whether the development of criteria to 
address insufficient funding levels is warranted, given the unique set 
of circumstances and considerations that would apply to each licensee.

Therefore, the NRC recommends that GAO state, in its report, that: (1) 
NBC's practice with respect to analyzing decommissioning funds where 
nuclear power plants have co-owners is consistent with its internal 
guidance; (2) the NRC has a methodology that is different from GAO's 
for assessing whether funds are being accumulated appropriately, and 
GAO's conclusions regarding sufficient accumulation of funds is based 
on GAO's methodology that has not been reviewed and accepted by the 
NRC; and (3) the NBC's practice is to review licensees who have not 
accumulated sufficient funds on a case-by-case basis due, in part, to 
the complexity and range of circumstances that may arise with any given 
licensee, particularly those that are subject to the jurisdiction of 
State regulators. Specific comments are provided on the three main GAO 
conclusions, as described below, and are elaborated on in greater 
detail in the enclosure.

* First, the GAO report states that NBC's internal guidance requires NRC 
to separately assess the status of each co-owner's trust funds against 
each co-owner's contractual obligations with other co-owners to fund 
decommissioning. We do not agree that the guidance requires assessment 
against co-owners' contractual obligations. The NRC:

reviews the accumulated balances and planned future contributions of 
each co-owner in order to evaluate the total trust fund balance 
expected for each reactor. Where a nuclear power plant has multiple 
owners, it is the owners' collective responsibility to meet the funding 
requirements for the plant.

Second, while the GAO report suggests that the NRC use a "benchmark" 
amount of funds that owners should have accumulated by the end of year 
2000 to determine if owners are "on track" to pay for eventual 
decommissioning, NRC regulations do not establish intermediate 
benchmarking levels, but rather establish the minimum balance that must 
be obtained at the permanent termination of operations. The NRC has 
always deferred to the State public utility commission, or other 
regulatory authority with rate making powers, to set rates to fund 
decommissioning trusts. The NRC determines whether there is reasonable 
assurance that adequate funds will be available for decommissioning by 
reviewing a licensee's current fund balance, its plan for future 
deposits, and its projected earnings, to the extent provided by NRC 
regulations, consistent with and in recognition of the significant role 
State regulatory authorities and FERC have in setting the rates at 
which licensees collect decommissioning funds.

Third, the NBC's practice is to deal with licensees who have not 
accumulated sufficient funds on a case-by-case basis due in part, to 
the complexity and range of circumstances that may arise with any given 
licensee, particularly those that are subject to the jurisdiction of 
State regulators.

The NRC will continue to evaluate its processes and policies associated 
with the decommissioning of power reactor facilities. The enclosed NRC 
comments are intended to provide a more comprehensive perspective 
related to the conclusions and recommendations contained in the draft 
GAO report.

Should you have any questions about these comments, please contact 
either Mr. William Dean at 301-415-1703 or Ms. Melinda Malloy at 301-
415-1785, of my staff.

Sincerely,

William D. Travers:

Executive Director for Operations:

Signed by William D. Travers:

Enclosure: As stated:

NRC Comments on the Draft General Accounting Office Report "Nuclear 
Regulation - NRC Needs More Effective Analysis to Ensure Accumulation 
of Funds to Decommission Nuclear Power Plants" (GAO-04-32):

1. The GAO report states on page 4: "Although the collective status of 
the owners' decommissioning fund accounts has improved since our last 
report, some individual owners are not on track to accumulate 
sufficient funds for decommissioning.":

The NRC disagrees with GAO's conclusion that some individual owners are 
not on track to accumulate sufficient funds for decommissioning because 
GAO's conclusion is based on GAO's methodology which is different from 
the NBC's and has not been reviewed and accepted by NRC.

The NRC recommends that GAO state, in its report, that NRC has a 
different methodology than GAO for assessing whether an owner is "on 
track." The NBC's methodology with respect to licensees who are 
authorized to accumulate funds over time assesses the reasonableness of 
the collection schedules proffered by licensees by weighing several 
factors such as the current fund balance, the licensee's plan for 
future deposits, and the projected earnings to the extent provided by 
NRC regulations, consistent with and in recognition of the significant 
role State regulatory authorities and FERC have in setting the rates at 
which licensees collect decommissioning funds.

2. On page 5, the GAO report states: ". . . contrary to NBC's internal 
guidance, for the plants with more than one owner, NRC did not 
separately assess the status of each co-owner's trust funds against the 
co-owner's contractual obligation to fund decommissioning.":

The NRC does not agree that its assessment of plants is contrary to 
NBC's internal guidance. The NRC review process for decommissioning 
trust fund assurance does, in fact, incorporate the information 
regarding each licensee's amortization schedule, where multiple owners 
per license exist, and where such information for each licensee has 
been submitted individually (in some cases, a lead licensee will report 
information for all co-owners). The phrase "for its share of the 
facility" as taken from page 11 of NUREG-1577, Rev. 1, "Standard Review 
Plan on Power Reactor Licensee Financial Qualifications and 
Decommissioning Funding Assurance," only reflects that an individual 
co-owner should report its own information (absent other arrangements 
for a lead licensee to report on behalf of the other co-owners), and is 
not obligated to provide information for other co-owners. The phrase 
does not indicate that the NRC must analyze each co-owner's 
decommissioning funds with regard to its private contractual 
obligations. The NRC does not separately assess the status of each co-
owner's decommissioning funding against the co-owner's private 
contractual obligation to fund decommissioning.

Enclosure:

While the NRC recognizes that private contractual arrangements among 
co-owners exist, the NBC's primary concern is that on a plant basis, 
there are adequate funds available from the licensees of the plant on a 
collective or aggregate basis. The NRC reserves the right, in highly 
unusual situations where adequate protection of public health and 
safety would be compromised if such action were not taken, to consider 
imposing joint and several liability on co-owners for decommissioning 
funding when one or more co-owners have defaulted. The NBC's practice 
is consistent with this policy.

The NRC recommends that GAO revise its report to state that the staff's 
practice in analyzing decommissioning funding for plants with multiple 
owners is consistent with its internal guidance.

3. On page 6, the GAO report states: ". . . NRC has not established 
criteria for responding to any unacceptable levels of financial 
assurance. Accordingly, we are recommending that NRC develop and use an 
effective method for determining whether owners are accumulating funds 
at sufficient rates and establish criteria for responding to 
unacceptable levels of financial assurance.":

The NRC disagrees with GAO's finding that the NRC has not developed and 
used a method of determining whether owner utilizing sinking funds are 
accumulating funds at sufficient rates. The NRC has a method which 
assesses the reasonableness of the collection schedule by weighing 
several factors. Therefore, the NRC recommends that GAO revise its 
report to state that the NRC has a method for determining whether 
owners are reasonably accumulating sufficient funds. If it is 
determined that unacceptable levels of financial assurance exist, the 
NRC will immediately seek licensees' plans to provide acceptable 
funding mechanisms, review those plans on a case-by-case basis in light 
of the specific circumstances involved, engage in discussions with 
relevant State regulators, and issue orders as necessary and 
appropriate. Beyond the general activities, the NRC has not established 
criteria for responding to unacceptable levels of financial assurance 
nor do we believe that such a criteria is worthwhile given the 
complexity and range of circumstances that may arise with any given 
licensee, particularly those who are subject to jurisdiction of State 
regulators.

4. On page 10, the GAO report includes a section entitled "Several 
Owners Are Not Accumulating Sufficient Funds for Decommissioning Their 
Plants.":

The NRC analyzed a sample of licensees in 2001 to determine whether 
they were accumulating sufficient funds for decommissioning their 
plants. Based on the sample, the NRC did not find any owners who were 
not accumulating sufficient funds. The NRC recognizes that GAO's 
conclusions are based on GAO's own method of analysis, however, that 
method of analysis has not been accepted by the NRC.

Therefore, the NRC recommends that GAO clarify its report to state that 
its conclusion that several owners are not accumulating sufficient 
funds is based on a GAO methodology or criteria that has not been 
accepted by the NRC. The NRC further recommends that GAO acknowledge in 
its report that there may be other acceptable methodologies or criteria 
to determine whether adequate funds are being collected that could 
yield different conclusions, particularly since there are many 
variables that reasonably can be incorporated into a given methodology.

5. On page 16, the GAO report states: "They [NRC official] also stated 
that NBC's regulations do not prohibit each co-owner from being held 
responsible for decommissioning costs even if these costs are more than 
the co-owner's individual ownership share. However, assessing the 
adequacy of decommissioning costs on plant-wide basis is not consistent 
with the industry view, held by most plant owners, that each co-owner 
should be limited to its pro rata share of decommissioning 
expenses....":

The NRC recognizes the existence of licensee arrangements via private 
contracts where licensees are responsible for decommissioning costs in 
proportion to their ownership interests, and does not object to these 
private contractual arrangements. However, the NRC reserves the right, 
in highly unusual situations where adequate protection of public health 
and safety would be compromised if such action were not taken, to 
consider imposing joint and several liability on co-owners for 
decommissioning funding when one or more co-owners have defaulted. 
Therefore, the GAO should revise its report to clarify that while there 
are a variety of industry practices and views, the NBC's primary intent 
is assuring the collective accumulation of decommissioning funds.

The following are GAO's comments on NRC's letter dated October 3, 2003.

GAO Comments:

1. Rather than concluding that NRC does not have a method, we stated 
that the agency's analysis was not effective in identifying owners who 
might be at risk of accumulating insufficient funds to pay for 
decommissioning. For example, NRC relied on the owners' future funding 
plans to make up any shortfalls without verifying whether the plans are 
consistent with the owners' recent contributions. See also our response 
in the Agency Comments and Our Evaluation section on page 16.

2. We agree that NRC should be primarily concerned with ensuring that 
owners of nuclear power plants will have sufficient funds for 
decommissioning. However, we believe that NRC should take a proactive, 
rather than reactive, approach to providing owners and the public with 
a more complete understanding of NRC's expectations as to how they will 
hold owners who are not accumulating sufficient funds accountable. As 
discussed in the report, the lack of any specific criteria for acting 
on owners' decommissioning financial reports contrasts with NRC's 
practices in overseeing safety issues at nuclear plants, where the 
agency uses an "Action Matrix" that provides for a range of actions 
commensurate with the significance of safety inspection findings and 
performance indicators. Without similar criteria in its oversight of 
decommissioning funding assurance, NRC will not have a logical, 
coherent, consistent, and predictable plan of action if and when it 
encounters owners whose plants have inadequate financial assurance. See 
also our response in the Agency Comments and Our Evaluation section on 
page 16.

3. See our responses to comments 5, 6, and 9 in this appendix.

4. See our responses to comment 9.

5. We agree that current NRC regulations do not establish intermediate 
benchmarking levels, but rather establish the minimum balance that must 
be obtained when plants are retired. We also agree that the state 
regulatory authorities and Federal Energy Regulatory Commission play a 
role. However, we believe that NRC should take a more proactive 
approach in developing an effective method for ensuring that sufficient 
funds will be available for decommissioning. For example, a common 
expected rate of return could be used to project the earnings of each 
owner's trust fund. NRC's current method allows the owners to use up to 
2 percent (real) or another rate if approved by its state regulator. As 
we stated in our report, one state regulator approved owners of the 
same plant to use widely varying rates of return to project earnings on 
their trust fund investments. Other factors being equal, the owner 
using the higher rate would need to collect fewer funds than the owner 
using a lower rate of return. While the actual rate the owners will 
earn on their funds could be higher or lower, NRC accepted the state 
regulator-approved rates without assessing whether they were consistent 
with market expectations.

In another example, in its 2001 biennial report, one owner using NRC's 
2 percent rate of return estimated that the amount of funds needed for 
decommissioning under NRC's regulations would be insufficient at five 
of its nuclear power plants. Therefore, the owner provided additional 
assurance in the form of a parent guarantee. However, the owner sought 
and subsequently received approval from its state regulator to use a 
higher real rate of return. After receiving the approval, the owner 
withdrew its parent guarantee since under the higher rate, the 
projected trust funds were sufficient to cover estimated 
decommissioning costs. We believe that by being more proactive, and not 
simply deferring to others, the NRC can develop a more effective and 
consistent method and better achieve its primary concern of ensuring 
that owners are accumulating funds at sufficient rates.

6. We found no evidence during our review that NRC has ever determined 
that an owner is not accumulating sufficient funds. Therefore, without 
any experience that its "practice" has been applied, we believe that 
without clear criteria, NRC will not have a logical, coherent, 
consistent, and predictable plan of action if and when it encounters 
owners whose plants have inadequate financial assurance. Accordingly, 
we are recommending that NRC establish criteria for responding to 
unacceptable levels of financial assurance.

7. We agree that our method is different from that used by NRC. Our 
draft discussed and reviewed NRC's analysis. Based on our review, we 
concluded that NRC's analysis was not effective in identifying owners 
who might be at risk of accumulating insufficient funds to pay for 
eventual decommissioning. For example, NRC relied on the owners' future 
funding plans, or on rate-setting authority decisions, in concluding 
that the owners were on track to fully fund decommissioning. However, 
we found some owners' actual contributions in 2001 were much less than 
what they stated in their 2001 biennial reports to NRC that they 
planned to contribute. For example, one owner contributed about $1.5 
million (or 39 percent) less than the amount it told NRC that it 
planned to contribute. Moreover, using actual contributions the owners 
had recently made to their trust funds, we identified several owners 
that are at risk of accumulating insufficient funds to pay for eventual 
decommissioning.

8. We do not believe any changes are needed.

9. We agree, and the our draft report stated, that NRC does not 
separately assess the status of each co-owner's decommissioning funding 
against the co-owner's private contractual obligation to fund 
decommissioning. The NRC guidance states: "Some licensees are part 
owners of power reactors. In such cases, the [NRC] reviewer should 
evaluate separately each licensee's [co-owner's] amortization schedule 
[i.e., decommissioning funding] for its share of the facility, unless 
the lead licensee has agreed to coordinate funding documentation and 
reporting for all co-owners." Nonetheless, we revised the report to 
remove any inferences that NRC's practice is inconsistent with its 
internal guidance. Notwithstanding NRC's characterization of its 
practice, we believe that both the guidance and NRC's actions do not go 
far enough. For example, the guidance allows for an exception when the 
lead licensee agrees to coordinate documentation and reporting. More 
importantly, the critical issue is that NRC should do more to develop 
an effective method for assessing the adequacy of nuclear power plant 
owner's trust funds for decommissioning. Under NRC's current method, it 
combines the trust funds for all co-owners of a nuclear plant and then 
assesses the adequacy of decommissioning funds on a plant-wide basis. 
However, as our analysis indicates, combining the trust funds of 
several owners can produce misleading results because those co-owners 
with more than sufficient funds can appear to balance out those with 
less than sufficient funds. In addition, as a practical matter, owners 
have contractual agreements to pay for their share of decommissioning, 
and the trust funds are generally not transferable among owners. Unless 
NRC separately evaluates the adequacy of each co-owners' 
decommissioning trust fund, the agency's existing process would appear 
to require some co-owners to pay more than their fair share of 
decommissioning costs. We believe this would be inconsistent with NRC's 
stated policy of generally not looking to one co-owner to bail out 
another.

10. Rather than state that NRC has not developed and used a method, we 
found that the agency's method was not effective in identifying owners 
who might be at risk of accumulating insufficient funds to pay for 
decommissioning. For example, we identified several limitations in 
NRC's method, including the agency's practice of combining the trust 
funds for all the co-owners of a nuclear plant and then assessing 
whether the combined value of the trust funds is sufficient. We believe 
that this practice can produce misleading results because those co-
owners with more than sufficient funds can appear to balance out those 
with less than sufficient funds.

In addition, we agree that NRC has not established criteria for taking 
action when it finds cases of unacceptable levels of financial 
assurance. According to NRC officials we spoke to, NRC has never 
identified an owner with unacceptable levels of financial assurance. 
Moreover, the general activities that NRC stated above are not included 
in its internal guidance for reviewing the owners' biennial reports. We 
believe that NRC should take a more proactive approach to providing 
owners and the public with a more complete understanding of NRC's 
expectations as to how they will hold owners who are not accumulating 
sufficient funds accountable. We believe having established criteria 
for taking action when it is determined that unacceptable levels of 
financial assurance exist will better prepare NRC to make this 
determination. Furthermore, having such criteria would not only 
increase public confidence that NRC has a plan to take action to ensure 
sufficient funds will be available for decommissioning but also would 
make its determination of inadequacy more transparent to owners.

11. As indicated in our draft report, we reviewed NRC's analysis of the 
owners' 2001 biennial reports. Our review clearly points out that the 
agency's method has limitations that reduce its effectiveness. For 
example, NRC relied on the owners' future funding plans to make up any 
shortfalls without verifying whether those plans are consistent with 
the owners' recent contributions. We found that some owners' actual 
contributions in 2001 were much less than what they stated in their 
2001 biennial reports to NRC that they planned to contribute. For 
example, one owner contributed about $1.5 million (or 39 percent) less 
than the amount they told NRC that they planned to contribute. In 
addition, based on our analysis using the actual contributions the 
owners recently made to their trust funds, we found that 28 owners with 
ownership shares in 44 plants contributed less than the amounts we 
estimate they will need to contribute over the remaining life of their 
plants to meet their decommissioning obligations. Accordingly, we 
believe that our recommendation to NRC to develop an effective method 
is clearly warranted to ensure that all owners are accumulating funds 
at sufficient rates. See also our response to comment 12.

12. As stated in our draft, our conclusions are based on a method that 
uses a benchmark to assess the adequacy of each nuclear plant owner's 
decommissioning trust fund. In addition, our draft stated that this 
benchmark is not the only way an owner could accrue enough funds to pay 
future decommissioning costs. Still, we believe that our benchmark is 
useful for assessing the status of the owners' decommissioning trust 
funds because it (1) provides a common standard for comparisons among 
owners, (2) embodies the principle of economic efficiency in that the 
price of a product (i.e., electricity) should, if possible, equal all 
of its costs--current and accrued, and (3) provides for transparency in 
that it assumes that current and future users pay the same 
decommissioning fees, in constant present-value terms.

13. As we stated in our draft, NRC stated that it will not impose 
decommissioning costs on co-owners in a manner inconsistent with their 
agreed-upon shares, except in highly unusual circumstances when 
required by public health and safety considerations and that it would 
not seek more than the pro rata shares from co-owners with de minimis 
ownership. Nevertheless, unless NRC separately evaluates the adequacy 
of each co-owners' decommissioning trust fund, the agency's existing 
process would appear to require some co-owners to pay more than their 
fair share of decommissioning costs. We believe this would be 
inconsistent with NRC's stated policy of generally not looking to one 
co-owner to bail out another one.

[End of section]

Appendix IV: GAO Contact and Staff Acknowledgments:

GAO Contact: 

Tim Guinane (202) 512-4939:

Acknowledgments: 

In addition, Ronald La Due Lake, Carolyn McGowan, Cynthia Norris, 
Michael Sagalow, Barbara Timmerman, Daniel G. Williams, and Dwayne 
Weigel made key contributions to this report.

:

(360094):



FOOTNOTES

[1] Retirement means the permanent cessation of a plant's operation.

[2] Costs in 2000 present value dollars and are for decommissioning the 
plant site only and exclude costs for cleaning up nonradiological 
hazards and storing spent fuel. 

[3] U.S. General Accounting Office, Nuclear Regulation: Better 
Oversight Needed to Ensure Accumulation of Funds to Decommission 
Nuclear Power Plants, GAO/RCED-99-75 (Washington, D.C.: May 3, 1999). 

[4] U.S. General Accounting Office, Nuclear Regulation: NRC's 
Assurances of Decommissioning Funding during Utility Restructuring 
Could Be Improved, GAO-02-48 (Washington, D.C.: Dec. 3, 2001).

[5] We administered the survey to 110 owners. Since then, the ownership 
of some plants has changed and as a result, the total number of owners 
has declined. Our analysis assesses 222 trust funds held by 99 owners. 

[6] GAO/RCED-99-75. 

[7] SAFSTOR involves placing the stabilized and defueled facility in 
storage for a time followed by final decontamination and dismantlement, 
and license termination. 

[8] NRC licenses include all co-owners as co-licensees; in general, one 
owner is authorized to operate the facility while the others are 
authorized only to have an ownership interest. Co-owners generally 
divide costs and output from their power plants by using a 
contractually defined pro rata share standard.

[9] U.S. Nuclear Regulatory Commission, Financial Assurance 
Requirements (Sept. 22, 1998), 63 Fed. Reg. 50465.

[10] U.S. Nuclear Regulatory Commission, Standard Review Plan on Power 
Reactor Licensee Financial Qualifications and Decommissioning Funding 
Assurance, NUREG 1577, Rev. 1, March 1999. 

[11] Under NRC's guidance, co-owners trust funds can be collectively 
evaluated when the lead licensee agrees to coordinate funding 
documentation and reporting for all the co-owners.

[12] Based on 72 owners who provided after-tax rates of return for 
1998, 1999, and 2000. These owners' trust funds accounted for about 71 
percent of the total trust funds in 2000. 

[13] For 2000 (the only year for which we have data on fund 
allocations), on average, owners allocated their funds rather evenly 
between equities and fixed income assets (see app. I for details). 
Investment plans such as pension funds that invested more heavily in 
equities may have earned a greater overall return during this period. 

[14] Some owners whom we estimate are below the benchmark have a parent 
company guarantee or other method to support financial assurance 
obligations. However, we did not evaluate the adequacy of these 
provisions. See app. II, table 4. 

[15] Our analysis simulates that the owners will increase their yearly 
future funding at the assumed after-tax rate of return on the 
investments of the funds, and that once in the fund, these yearly 
contributions will grow at this same rate. See appendix I for a 
discussion of our methodology.

[16] Some of these owners were also making up their shortfalls on other 
plants.

[17] Summary of Decommissioning Trust Funding Status Reports For Power 
Reactors, SECY-01-0197, Nuclear Regulatory Commission, November 5, 
2001. 

[18] One plant--Browns Ferry 1--has a license but is currently not 
operating. 

[19] Requirement is waived if lead owner has agreed to coordinate 
funding documentation and reporting for all co-owners. In such cases, 
the guidance does not require a separate evaluation of each co-owner's 
amortization schedule.

[20] Joint and several liability refers to the legal doctrine, which 
would allow holding all or any one of the co-owners financially 
responsible for the default of any co-owner.

[21] Final Policy Statement on the Restructuring and Economic 
Deregulation of the Electric Utility Industry, 62 Fed. Reg. 44071 (Aug. 
19, 1997). 

[22] Co-owners generally divide costs from their facilities using a 
contractually defined pro rata share.

[23] GAO/RCED-99-75.

[24] We assume that decommissioning will most likely occur within 5 
years of a plant being retired. For simplicity, our model therefore 
decommissions a plant "instantaneously" at 2.5 years after the 40-year 
lifespan. Thus, the present value of decommissioning costs after the 
first year of operation is computed by discounting the estimated future 
costs by 41.5 years (39+2.5). Under our benchmark, the first 
contribution to the fund at the end of the first year should equal 1/
40TH of the present value of the costs, discounted over 41.5 years. At 
the end of the second year of the plant's operation, the trust fund 
(including earnings) would equal 2/40TH of the present value of the 
future costs, discounted back by 40.5 years. Finally, at the end of the 
40TH and final year of operation, the fund would contain 40/40TH of the 
present value of the future costs, discounted back by 2.5 years. At 
"instantaneous" decommissioning, 2.5 years hence, the trust fund 
balance would equal the entire current-dollar decommissioning costs. 

[25] Table 6 includes some trust funds for which we did not have 
contributions data but whose balance adequacy percentage for the 
baseline fell below zero under the pessimistic assumptions.

[26] Forecast as of January 30, 2003. 

[27] To forecast the growth in equities, we used Global Insight's 
forecast for the S&P 500. We assumed that dividends would be 
reinvested. For example, for our baseline scenario, we combined the 
compound annual-average growth rate for the S&P 500 Index with its 
corresponding annual-average dividend yield rate to obtain a total 
growth rate. For U.S. securities, we used the forecast for 30-year 
federal government bonds. For corporate bonds and municipal bonds, we 
used the forecast for Aaa-rated corporate and municipal bonds, 
respectively. For cash, we used the forecast for 6-month U.S. Treasury 
Bills.

[28] Using rate of return data provided by 84 owners, we calculated a 
weighted-average difference between their pretax and after-tax rates of 
return for each fund and year over 1997-2001, weighted by the relative 
size of their funds. We then calculated the simple mean of the weighted 
average differences for each year to obtain an overall weighted average 
difference of about 0.87 of a percentage point. 

[29] The 4.60 percent cost-escalation rate is fund-weighted average 
based on the owners' assumptions about future nominal-dollar cost-
escalation, as reported in their 2001 biennial reports.

[30] To calculate a cost-adjusted real rate-of-return for the 
pessimistic and optimistic scenarios, we formed proportionality ratios. 
For pessimistic, 3.36% / 3.15% = x% / 1.02%; therefore, x = 1.09%. For 
optimistic, 3.43% / 3.15% = y% /1.02%; therefore, y = 1.11%. 

[31] For pessimistic, 6.40% - x% = 1.09%; therefore, x = 5.31%. For 
optimistic, 5.58% - y% = 1.11%; therefore, y = 4.47%.

[32] To test this simplifying assumption in the looking-backward 
analysis, we assessed the impact of assuming that one-fifth of 
decommissioning occurred over each of the 5 years. The result was 
virtually identical to that obtained when we assumed that all 
decommissioning occurred at 2.5 years after shutdown. 

[33] The 16 plants are: Arkansas Nuclear Unit 1; Calvert Cliffs Units 1 
and 2; Hatch Units 1 and 2; North Anna Units 1 and 2; Oconee Units 1, 
2, and 3; Peach Bottom Units 2 and 3; Surry Units 1 and 2; and Turkey 
Point Units 3 and 4.

[34] The 14 plants are: Catawba Units 1 and 2; Dresden Units 2 and 3; 
Fort Calhoun; Ginna; McGuire Units 1 and 2; Quad Cities Units 1 and 2; 
Robinson 2; St. Lucie Units 1 and 2; and Summer. The other 8 plants 
are: Arkansas Nuclear Unit 2; Browns Ferry Units 1, 2, and 3; Cook, 
D.C. Units 1 and 2; and Farley Units 1 and 2. 

[35] This expectation is in contrast to conditions reported in our 1999 
report, when the market for electricity appeared much weaker. In that 
report, we assumed in the baseline scenario that 6 plants would be 
prematurely retired during 1998 to 2002.

GAO's Mission:

The General Accounting Office, the investigative arm of Congress, 
exists to support Congress in meeting its constitutional 
responsibilities and to help improve the performance and accountability 
of the federal government for the American people. GAO examines the use 
of public funds; evaluates federal programs and policies; and provides 
analyses, recommendations, and other assistance to help Congress make 
informed oversight, policy, and funding decisions. GAO's commitment to 
good government is reflected in its core values of accountability, 
integrity, and reliability.

Obtaining Copies of GAO Reports and Testimony:

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through the Internet. GAO's Web site ( www.gao.gov ) contains 
abstracts and full-text files of current reports and testimony and an 
expanding archive of older products. The Web site features a search 
engine to help you locate documents using key words and phrases. You 
can print these documents in their entirety, including charts and other 
graphics.

Each day, GAO issues a list of newly released reports, testimony, and 
correspondence. GAO posts this list, known as "Today's Reports," on its 
Web site daily. The list contains links to the full-text document 
files. To have GAO e-mail this list to you every afternoon, go to 
www.gao.gov and select "Subscribe to e-mail alerts" under the "Order 
GAO Products" heading.

Order by Mail or Phone:

The first copy of each printed report is free. Additional copies are $2 
each. A check or money order should be made out to the Superintendent 
of Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 
more copies mailed to a single address are discounted 25 percent. 
Orders should be sent to:

U.S. General Accounting Office

441 G Street NW,

Room LM Washington,

D.C. 20548:

To order by Phone: 	

	Voice: (202) 512-6000:

	TDD: (202) 512-2537:

	Fax: (202) 512-6061:

To Report Fraud, Waste, and Abuse in Federal Programs:

Contact:

Web site: www.gao.gov/fraudnet/fraudnet.htm E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470:

Public Affairs:

Jeff Nelligan, managing director, NelliganJ@gao.gov (202) 512-4800 U.S.

General Accounting Office, 441 G Street NW, Room 7149 Washington, D.C.

20548: