2018-09-21 hubbard direct testimony exhibit gh-2 (edwards

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EXHIBIT __ (GH-2) ELECTRONICALLY FILED - 2018 September 24 6:09 PM - SCPSC - Docket # 2017-305-E - Page 1 of 18

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Page 1: 2018-09-21 Hubbard Direct Testimony Exhibit GH-2 (Edwards

EXHIBIT __ (GH-2)

ELECTR

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FILED-2018

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6:09PM

-SCPSC

-Docket#

2017-305-E-Page

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Page 2: 2018-09-21 Hubbard Direct Testimony Exhibit GH-2 (Edwards

SStatus of the V. C. Summer Units 2 & 3 Nuclear Power Plants Presentation to the South Carolina Energy Users Committee Nanette S. Edwards, Deputy Executive Director, ORS May 13, 2016

Exhibit __ (GH-2)Page 1 of 17

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Page 3: 2018-09-21 Hubbard Direct Testimony Exhibit GH-2 (Edwards

ORS TEAM Anthony James, Director Energy Policy, Licensed Prof. Engineer, Master’s in Earth and Environmental Resources

Allyn Powell, Manager for Nuclear Programs, B.S. in Physics, Master of Science in Physics, area of study: nuclear and particle physics. Served as lead staff for the S.C. Governor’s Nuclear Advisory Council.

Gene Soult, Senior Research Analyst, Power Plant Management and Operations Experience (24 years nuclear, 14 years fossil), held Senior Reactor Operator (SRO) credentials at two different nuclear plants.

Jay Jashinsky, Director Audit, Certified Public Accountant

Gary C. Jones, President of Jones Partners, Ltd.

45+ years in the nuclear power industry

32 years with Sargent & Lundy (S&L) in Chicago, Illinois

16 years as an Owner/Senior Vice President of S&L

2 ½ years with the International Atomic Energy Agency (IAEA) in Vienna, Austria

Led the design and engineering on 3 major nuclear power plants

LaSalle County (Commonwealth Edison)

Marble Hill (Public Service Indiana)

Braidwood (Commonwealth Edison)

Provided engineering, design and consulting services to over 50 nuclear power plants in the United States

Professional project experience in Armenia, Canada, China, El Salvador, Finland, Hungary, Mexico, South Korea and Ukraine as well as throughout the United States

Retained by South Carolina Office of Regulatory Staff (ORS) since August 2011

Registered Professional Engineer in Missouri and South Carolina

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Page 4: 2018-09-21 Hubbard Direct Testimony Exhibit GH-2 (Edwards

Why? Updated NRC regulatory environment under 10 CFR 52, which allows for a combined license to both construct and operate a plant

Modular Construction

Certified Design

Success in Asia

Source of non-GHG emitting and diverse power

Engineering, Procurement and Construction (EPC) Contract

Base Load Review Act (BLRA) in South Carolina

2

A Very Good Idea in 2008

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Page 5: 2018-09-21 Hubbard Direct Testimony Exhibit GH-2 (Edwards

NRC regulatory environment not as good as hoped

Combined Construction and Operating License (COL) was delayed

9 months until March 30, 2012

“Build what you license vs. license what you build”

Very strict literal compliance via NRC oversight

License Amendment Requests (LARs)

First plants through the Inspection, Tests, Analyses and Acceptance Criteria (ITAAC) process

Not as much credit for previous experience in China as hoped

Impact of changes from Fukushima accident

3

Experience Since 2008

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Page 6: 2018-09-21 Hubbard Direct Testimony Exhibit GH-2 (Edwards

Modular Construction Fabricators unable to reliably meet schedule and quality requirements

Continuing design changes

Inadequate constructability reviews

Reassignment and de-scoping of fabricators

4

Experience Since 2008

Certified Design Not as complete as anticipated

Lessons learned at Chinese and sister plants

Compliance issues with codes, standards and commitments

SCE&G requested changes

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Page 7: 2018-09-21 Hubbard Direct Testimony Exhibit GH-2 (Edwards

Asian Schedules Could Not Be Duplicated More rigorous regulatory environment

Construction productivity rates lower than planned

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Experience Since 2008

Still a Source of Non-GHG Emitting Power More focus on this issue due to EPA 111d

Diversity in power supply remains important

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Page 8: 2018-09-21 Hubbard Direct Testimony Exhibit GH-2 (Edwards

EPC Contract Multiple Changes in Ownership

Westinghouse/Shaw Stone & Webster

Westinghouse/CB&I Stone & Webster

Westinghouse (with Fluor as a sub-contracted construction manager)

Multiple Amendments

“Change in Law” provision interpretation led to disagreements

Designer vs. Constructor

6

Experience Since 2008

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Page 9: 2018-09-21 Hubbard Direct Testimony Exhibit GH-2 (Edwards

BLRA Remains an Essential Element to Success… Stable environment ensures project financing

Inflation and interest rates have been favorable during construction

Construction has created jobs

3,750 workers on site in March, 800 permanent jobs anticipated

However, Cost and Schedule Changes are Mounting.

5 Filings under the BLRA to delay construction schedules and/or increase project budget

SCE&G’s share of budget additions in 2007 dollars: $1.15 billion

8 Revised Rates filings Cumulative increases under the BLRA estimated to total $1.055 billion

7

Experience Since 2008

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Page 10: 2018-09-21 Hubbard Direct Testimony Exhibit GH-2 (Edwards

Site Overview (Picture from September 2015)

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HLDCooling Tower 2 Alpha

ower 2~Bravo

Turbine Building

Unit 2

Ring 2

Transformer Bays

Ring 1 Unit 3MAB

CV Rings L Heads

sar CV Lower Bowl

Page 11: 2018-09-21 Hubbard Direct Testimony Exhibit GH-2 (Edwards

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Unit 2 CA03

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Page 12: 2018-09-21 Hubbard Direct Testimony Exhibit GH-2 (Edwards

UUnit 3 Nuclear Island

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Unit 3 Nuclear Island & CV Ring 1

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Page 13: 2018-09-21 Hubbard Direct Testimony Exhibit GH-2 (Edwards

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Unit 3 CA20

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Page 14: 2018-09-21 Hubbard Direct Testimony Exhibit GH-2 (Edwards

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SCE&G’s Settlement with the Consortium

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Order ¹2015-661(Prior EPC)

Amended EPC Fixed Price Option

Guaranteed SubstantialCompletion Dates

Unit 2 - June 2019Unit 3 — June 2020

Unit 2 - August 2019Unit 3 — August 2020

Capital Cost $5.247 billion $5.492 billion $6 757 billion

Future Escalation toWestinghouse as 6/30/2015*: $794 million $813 million $19 million»

Total Expected Project Cost $6.827 billion $7.113 billion $7 601 billion

Liquidated Damages $155 million I 100%

$86 million — SCE&G$926 million @ 100%

$509 million — SCE&G$676 million @ 100%

$372 million — SCE&G

Bonuses

Change in Law Language

Capacity PerformanceRelated

Generally defined

Completion — Capacity Performance bonus removed$550 million @ 100% $300 million @ 100%

$303 million — SCE&G $165 million — SCE&G

Explicitly defined — Formal written adoption of a new statute,regulation, requirement, or code or new NRC regulatory

requirement that did not exist as of this amendment

Design Control Document Revision 16 Revision 19

*The Fixed Price Option, regardless of date of acceptance, would fix Project Costs and shift the risk ofescalation (excluding escalation on owner's and transmission costs) to Westinghouse as of June 30, 2015.

Total Gross Escalation recorded as of 6/30/2015 is 5386 million. Under the Fixed Price Option, Total GrossEscalation remaining on the project is estimated to be approximately $ 145 million.

Page 15: 2018-09-21 Hubbard Direct Testimony Exhibit GH-2 (Edwards

PProject Challenges Ongoing ORS Monitoring

Monthly site tours and meetings

Focus on budget/schedule impacts

Information Requests Issued to Company - March 4, 2016

Responses Received – March 24, 2016

Follow Up Information Requests Issued – April 12, 2016

Responses Received – April 22, 2016

Currently evaluating responses

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ORS Activities Related to Settlement

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PProject Challenges

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ORS Website Additions

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Consumers(

Electric Gas(

Energy Office New Nuclear Safety(

Teiecom(

Transportation Water/Sewer

Home

About Us

~m & ~Nw u lear & vC.Summerunits2 and 3

Y.C. Summer Units 2 and 3

News and Publications ORS Fimt Continuin R uest for Records and Information

Related Links ORS 1st Information Re uest October 2015 EPC Amendement

Laws and Guidelines

Media Contact

Contact Us

SCERG Res nses to ORS 1st Information Re uest

ORS Follow-u to SCE6G Res onses

Construction U ate 4-11-16

Revised Rates Dock ets

2-23-16 BLRA Estimated Curnulatwe A roved Increases

as a e

1-15-16 ORS Releases Results of Inde ndent Ana sis on VC Summer Units 2 6 3 under Base LoadRernew Act

ORS Focuses on Contract Amendment

Page 17: 2018-09-21 Hubbard Direct Testimony Exhibit GH-2 (Edwards

PProject Challenges

Transition Between EPC Contract Holders and Construction Management

Modules, Modules, Modules!

Shield Building Air Inlet Tension Ring and Roof Design

Productivity

Mechanical, Electrical and Instrumentation & Controls Installation

Regulatory Compliance

License Amendment Requests (LARs)

ITAAC (873/unit required; 22 on U2 and 19 on U3 verified by NRC)

Start-Up

Operations and Support Staff Readiness

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Project Challenges

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Page 18: 2018-09-21 Hubbard Direct Testimony Exhibit GH-2 (Edwards

CConclusions Recent independent study indicates BLRA methodology reduces costs

Still a diverse and non-GHG source of power

Project faces significant, but not insurmountable, challenges

Unit 3 will need substantial improvement in all areas to meet the date for federal

tax credits

Progress has been made in the general areas of the site and the turbine island

Consolidation under Westinghouse is viewed positively by SCE&G

Addition of Fluor brings experience and challenges

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Conclusions

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