testimony and preliminary report of southern california edison … · regarding 2014 expenses for...

Application No.: A.15-01-XXX Exhibit No.: SCE-1 Witnesses: T. Palmisano

E. Avella J. Perez

(U 338-E)

Testimony and Preliminary Report of Southern California Edison Company Regarding 2014 Expenses for San Onofre Nuclear Generating Station (SONGS) Unit Nos. 2&3

Before the

Public Utilities Commission of the State of California Rosemead, California

January 30, 2015

Testimony and Preliminary Report of Southern California Edison Regarding 2014 Expenses for SONGS Unit Nos. 2&3

Table Of Contents

Section Page Witness

-i-

I. INTRODUCTION .............................................................................................1 J. Perez

A. Purpose of Testimony and Summary of Request ...................................1

B. Timing Of SCE’s Preparation Of Preliminary Information ...................1

II. PROCEDURAL BACKGROUND ....................................................................3

III. REASONABLENESS DETERMINATION OF 2014 EXPENSES .................5

IV. OVERVIEW OF SONGS DECOMMISSIONING ORGANIZATION & ACTIVITIES ..................................................................7 T. Palmisano

A. Summary of NRC Decommissioning Phases ........................................7

B. SONGS Workforce And Work Groups And Activities .........................7

1. SONGS Decommissioning Organization ..................................8

a) Decommissioning & Regulatory Affairs .....................10

b) Decommissioning Communications, Strategic Planning, and Analysis .................................12

2. Summary of Decommissioning Organization ..........................12

V. RECONCILIATION OF DECOMMISSIONING EXPENSES TO THE DCE .........................................................................................................13 J. Perez/E. Avella

A. Summary and Reconciliation of 2014 Costs ........................................15

B. Activity Descriptions and Variance Explanations of O&M Expenses ..............................................................................................18

1. License Termination, Decon Pd 2 ............................................18

a) Distributed....................................................................18

(1) Cold and Dark ..................................................18

(2) Decommissioning General Contractor (DGC) ............................................20

(3) Historical Site Assessment (HSA) ...................22


Table Of Contents (Continued)


-ii-

(4) Regulatory Compliance ...................................23

(5) Radioactive Material Disposal .........................25

b) Undistributed................................................................26

(1) Labor ................................................................26

(2) Non-Labor ........................................................27

2. Spent Fuel Management, SNF Pd 2 .........................................28

a) Distributed....................................................................29

(1) Independent Spent Fuel Storage Installation (ISFSI) ...........................................29


(3) Security ............................................................30

b) Undistributed................................................................31

(1) Labor ................................................................31

(2) Non-Labor ........................................................32

3. Site Restoration, SR Pd 1 .........................................................33

a) Distributed....................................................................33

(1) Historical Site Assessment and Characterization Survey – Mesa ......................33

(2) Mesa Site Surrender .........................................34


b) Undistributed................................................................36

(1) Labor ................................................................37

(2) Non-Labor ........................................................37

Attachment A ...................................................................................................................


Table Of Contents (Continued)


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Attachment B ...................................................................................................................

Testimony and Preliminary Report of Southern California Edison Regarding 2014 Expenses for SONGS Unit Nos.

List Of Figures

Figure Page

-iv-

Figure IV-1 SONGS Workforce ..................................................................................................................8

Figure IV-2 SONGS Decommissioning Organization December 2014 ......................................................9

Figure IV-3 SONGS Mesa Site-2013 ........................................................................................................35

Figure IV-4 SONGS Mesa Site – 2014......................................................................................................35

Testimony and Preliminary Report of Southern California Edison Regarding 2014 Expenses for SONGS Unit Nos.

List Of Tables

Table Page

-v-

Table V-1 Preliminary Comparison Of 2014 Recorded And Forecast Expenses To The

DCE (2014 Dollars in Millions, 100% Level) .....................................................................................16

Table V-2 Preliminary Comparison Of 2014 Recorded And Forecast Expenses To The

DCE By Category (2014 Dollars in Millions, 100% Level) ...............................................................17

1

I. 1

INTRODUCTION 2

A. Purpose of Testimony and Summary of Request 3

The purpose of this testimony is to provide preliminary information1 supporting the Application 4

of Southern California Edison Company (SCE) for a reasonableness review of SONGS 2&3 expenses 5

incurred during 2014. In Decision (D.) 14-11-040 (SONGS OII Decision), the Commission directed 6

SCE and San Diego Gas & Electric Company (SDG&E) (collectively referred to as the Utilities) to file, 7

within 60 days of the effective date of that decision, an application for review of 2014 SONGS 2 & 3 8

expenses.2 The Commission subsequently extended the application due date to January 30, 2015. In this 9

Application, SCE respectfully requests the Commission find that 2014 expenses of $221.3 million 10

(2014$, 100% level) for San Onofre Nuclear Generating Station (SONGS) Units No. 2&3 are 11

reasonable. 12

B. Timing Of SCE’s Preparation Of Preliminary Information 13

Given the deadline’s proximity to year-end 2014, SCE is not yet able to provide final, complete 14

cost information and variance explanations redundant, for a reconciliation of those expenses to the 15

SONGS 2&3 decommissioning cost estimate (DCE) submitted in Application (A.) 14-12-007. In 16

particular, SCE did not complete and submit the DCE to the U.S. Nuclear Regulatory Commission 17

(NRC) until September 2014. Therefore, SCE initially was not able to track 2014 expenses to the DCE, 18

and instead tracked those expenses from its general ledger to its 2014 SONGS budget using the 19

company’s SAP accounting system. As explained below in Section V, SCE needed to reconfigure its 20

accounting system to track expenses to the DCE and by the Work Breakdown Structure (WBS)3 created 21

for the decommissioning project. Beginning January 1, 2015, SCE will manage the decommissioning 22

work and tracking of expenses using the Decommissioning Project Cost System (DPCS). SCE is in the 23

process of remapping recorded expenses to the WBS using the new DPCS. SCE anticipates having this 24

1 In this testimony, SCE is providing recorded expenses through October and forecast expenses for November

and December.

2 D.14-11-040, Ordering Paragraph (OP) No. 4.

3 A work breakdown structure is a project management and cost accounting discipline used to track work and its cost in detail.

2

process complete within the next month. SCE will submit by April 1, 2015 an updated exhibit providing 1

final 2014 recorded cost information and variance explanations, as provided in D.14-11-040.4 2

In addition, the Commission has directed SCE to work with SDG&E, Energy Division, and other 3

interested parties concerning the tracking and reporting of decommissioning expenses and variances: 4

SCE shall organize a meeting . . . to work with Energy Division, San Diego Gas & Electric 5 Company and other interested parties to determine how SCE’s cost accounting system for 6 San Onofre Nuclear Generating Station Units 2 and 3 appropriately facilitates tracking 7 decommissioning expenditures by major subprojects within a decommissioning phase, allows 8 for comparison to previously approved estimates of activities, costs, and schedule . . .5 9

With the assistance of Energy Division and SDG&E, SCE will organize and conduct a decommissioning 10

cost accounting workshop for all interested parties, to fulfill this requirement and explain the cost-11

accounting system SCE is utilizing to establish “a more transparent accountable format for cost 12

disclosure by SCE,” as referenced in D.14-12-082.6 SCE will schedule this workshop, and notify parties 13

in A.14-12-007 and/or the docket established for this Application. During the workshop, SCE will 14

explain the DPCS, and how it will be utilized to track costs. 15

Chapter II of this testimony provides the procedural background associated with the 16

Commission’s recent review of SONGS costs. Chapter III addresses issues the Commission should 17

consider in its reasonableness determination for 2014 SONGS 2 & 3 expenses. Chapter IV provides an 18

overview of the SONGS decommissioning organization and activities. Chapter V reconciles 2014 19

expenses to the DCE, providing a summary of 2014 expenses by major project area and an explanation 20

of variances between these expenses and the DCE, based upon information available at this time. 21

4 D.14-11-040, OP No. 4.

5 D.14-12-082, OP No. 5.

6 D.14-12-082, p. 3.

3

II. 1

PROCEDURAL BACKGROUND 2

Pursuant to California Public Utilities Code Section 455.5, the Commission issued an Order 3

Instituting Investigation (OII) on October 25, 2012, initiating a multi-part investigation into the actions 4

and expenses of the Utilities associated with the extended outages at SONGS.7 A year and a half later 5

following the parties’ submissions on various issues, two evidentiary hearings, and other procedural 6

matters, SCE, SDG&E, The Utility Reform Network (TURN), Office of Ratepayer Advocates (ORA), 7

Friends of the Earth (FOE), and California Coalition of Utility Employees (CCUE) (collectively referred 8

to as the Settling Parties), filed and served on April 3, 2014 a Joint Motion for Adoption of Settlement 9

that would resolve all issues in the OII and related proceedings. Later, on September 24, 2014, the 10

Settling Parties submitted an Amended and Restated Settlement Agreement, agreeing to certain 11

modifications requested by the assigned Commissioner and Administrative Law Judges for the OII. On 12

November 25, 2014, the Commission issued D.14-11-040 approving the Amended and Restated 13

Settlement Agreement.8 As noted above, Ordering Paragraph 4 directs SCE to file this Application.9 14

On December 21, 2012, in a separate proceeding (not consolidated with the OII) concerning 15

SONGS decommissioning expenses, SCE and SDG&E filed a joint application for the 2012 Nuclear 16

Decommissioning Cost Triennial Proceeding (NDCTP). On December 22, 2014, the Commission 17

issued D.14-12-082. In the decision, the Commission seeks to establish through further discussions and 18

workshops “a more transparent and accountable format for cost disclosure by SCE when estimating and 19

undertaking decommissioning activities for SONGS 2&3.” Specifically, Ordering Paragraph No. 5 20

directs SCE to organize a meeting, within 60 days of the date the decision is issued,10 to work with 21

Energy Division, SDG&E, and other interested parties to explain SCE’s cost accounting for SONGS 22

2&3 decommissioning expenses.11 Ordering Paragraph No. 6 requires SCE to develop, in consultation 23

7 D.14-11-040.

8 Although issued November 25, 2014, the effective date of D.14-11-040 is November 20, 2014.

9 D.14-11-040, OP No. 4.

10 The workshop needs to be organized by February 20, 2015 unless otherwise directed by the Commission.

11 D.14-12-082, OP No. 5.

4

with the Energy Division and other interested parties, a cost categorization structure for tracking 1

decommissioning expenses, including the ability to compare actual recorded expenses to the most 2

recently submitted DCE.12 3

On December 10, 2014, SCE and SDG&E jointly filed A.14-12-007, which among other things, 4

requests the Commission to approve: (1) the SONGS 2&3 decommissioning cost estimate; (2) SCE’s 5

request to reduce annual contributions to the SONGS 2&3 decommissioning trusts to zero at this time; 6

(3) an advice letter process for authorizing disbursements from the trusts; and (4) an annual 7

reasonableness review process for the expenses incurred for SONGS 2&3 decommissioning activities 8

completed during each year. If approved, this process will allow for more frequent review of 9

decommissioning activity costs. SCE will utilize the DCE submitted in A.14-12-007 to identify and 10

explain cost variances between 2014 recorded expenses and the DCE. 11

12 D.14-12-082, OP No. 6.

5

III. 1

REASONABLENESS DETERMINATION OF 2014 EXPENSES 2

The decommissioning of SONGS is an extremely complex undertaking involving several 3

discrete major activities and thousands of sub-activities. Evaluating the reasonableness of 4

decommissioning expenses without considering how the overall expenses compare to the overall 5

estimate, ignores the nature of estimates and overall project expenses. There will always be some 6

variances between estimated and recorded expenses for each discrete activity within a project. SCE 7

expects the costs of many activities in the DCE to match very closely what is estimated in the DCE. It is 8

important for the Commission to recognize, however, that some estimates in the DCE pertain to 9

activities and associated costs that, by their nature, could vary significantly from what is currently 10

estimated. Therefore, for a project of this scope, SCE reasonably expects to be able to utilize savings 11

from underruns (along with contingency) for certain activities, to offset expenses for other activities that 12

are more than estimated. As required by the Commission, SCE will provide adequate evidence that the 13

decisions it makes in the decommissioning of SONGS are prudent and in the ratepayers’ interest. 14

Prudence of an activity for which recorded expenses exceed the corresponding estimate should be 15

judged on the basis of the decisions made for that activity and its impact on the overall project, not 16

solely on activity-by-activity review and the fact that the expenses incurred for a certain discrete activity 17

exceeded the estimate for that activity. 18

In D.03-10-015, the Commission adopted criteria for determining the completion of 19

decommissioning work: 20

A decontamination and dismantling activity is complete if: (1) the activity has been 21 completed in its entirety, or (2) the activity has eliminated a specifically identifiable 22 decommissioning liability. 23

Decommissioning liability is eliminated when material is removed from the SONGS site. 24 For Independent Spent Fuel Storage Installation (ISFSI) design, licensing, and construction 25 work, completed work satisfied a defined regulatory activity or construction milestone. 26 (A.02-03-039, Exhibit SCE-1, p. 13).13 27

13 D.03-10-015, p. 34.

6

SCE anticipates that the Commission generally will apply the same criteria for completed work 1

on the SONGS 2&3 decommissioning project. SCE recommends that the Commission adopt these 2

standards and policies for future reasonableness reviews. 3

The Commission, however, has directed SCE to report 2014 SONGS 2&3 expenses for 4

Commission review at this time, even though certain activities have not been completed. SCE 5

recommends that the reasonableness of 2014 recorded expenses be evaluated based on the sum of all 6

expenses incurred for activities versus the sum of all 2014 estimated expenses (including contingency) 7

for those activities, and ensuring the decommissioning trusts are sufficiently funded for remaining 8

estimated expenses. SCE presents information and variances discussions for the 2014 activities in this 9

supporting testimony. 10

7

IV. 1

OVERVIEW OF SONGS DECOMMISSIONING ORGANIZATION & ACTIVITIES 2

A. Summary of NRC Decommissioning Phases 3

The decommissioning of commercial nuclear power plants in California is principally regulated 4

by the U.S. Nuclear Regulatory Commission (NRC), with cost oversight by the California Public 5

Utilities Commission (Commission). SCE is following the NRC’s Regulatory Guide 1.184 6

“Decommissioning of Nuclear Power Reactors” to decommission SONGS. This guide identifies three 7

phases for decommissioning. The first phase involves decommissioning initial activities, which start on 8

the date of permanent cessation of operations and continues until the licensee either places the power 9

reactor into storage mode or begins major decommissioning activities. The second phase encompasses 10

the major decommissioning activities (i.e., decontamination and dismantling). The third phase consists 11

of the remaining activities required to terminate the facility licenses. 12

B. SONGS Workforce And Work Groups And Activities 13

During 2014, SONGS was in the first phase of the decommissioning process and, as prudent, 14

aligned its work groups and support to the planned work. This resulted in a workforce of 433 SCE 15

employees as of December 31, 2014, which SCE determined was reasonable based on its review of other 16

decommissioning facilities and technical requirements for SONGS. See Figure IV-1 depicting the 17

workforce reductions from June 2013 through December 2014. 18

8

Figure IV-1 SONGS Workforce14

SCE will continue to manage the SONGS workforce throughout the decommissioning project to 1

ensure alignment with the scheduled activities and regulatory requirements. 2

1. SONGS Decommissioning Organization 3

As a result of workforce reductions made, SCE restructured the work groups at SONGS. 4

The SONGS nuclear organization is now known as the SONGS Decommissioning Organization, which 5

has responsibility over all plant activities and decommissioning. The organizational chart in Figure IV-2 6

below depicts the structure of the Decommissioning Organization as of December 2014. A brief 7

discussion of each group and their respective areas of responsibility in 2014 is provided. 8

14 Excludes temporary utility employees, utility employees on leave of absence, and contract workers.

9

Figure IV-2 SONGS Decommissioning Organization

December 2014

In 2014, the SONGS workforce performed a number of initial decommissioning 1

activities, which included maintaining certain original plant systems to meet existing license 2

requirements and ensure safe possession of spent nuclear fuel. Some plant systems that SCE continues 3

to maintain to meet these requirements include: (1) spent fuel pool systems; (2) radiation monitoring 4

system equipment; (3) electrical distribution systems; (4) HVAC systems; and (5) Independent Spent 5

Fuel Storage Installation (ISFSI). SCE must continue to maintain the originally installed Unit 2 and 3 6

spent fuel pool cooling and ancillary systems in order to keep the spent fuel covered with enough water 7

to keep the fuel at the appropriate temperature and limit the radiological dose. After SCE completes the 8

“islanding” of the Unit 2 and 3 spent fuel pools, which are independent cooling systems, and meets 9

related NRC requirements, the spent fuel pool cooling systems will be retired. As SCE completes 10

decommissioning activities, and receives NRC approval of its permanently defueled technical 11

specifications, additional systems will be retired and the maintenance requirements will be reduced. 12

SCE is also required to meet NRC-specified emergency planning requirements under its current 13

licensing basis. The current SONGS workforce is also required to meet the Emergency Response 14

10

Organization (ERO) staffing, security, and other requirements. SCE has submitted a license amendment 1

request with the NRC to approve an updated Emergency Plan (E-Plan) for SONGS to be consistent with 2

a permanently defueled facility and is awaiting NRC’s approval. When approved, the updated E-Plan 3

will allow SCE to reduce the number of emergency response organization positions at SONGS and to 4

reduce the associated expenses commensurate with the reduced risk level at SONGS. 5

The SONGS Decommissioning Organization that performed this and other 6

decommissioning work is headed by a Vice President for SONGS Decommissioning, who has overall 7

responsibility for SONGS decommissioning activities, including state and federal regulatory affairs, 8

external communications with stakeholders, and strategic planning and analysis. As discussed in further 9

detail below, these activities and the associated costs were reasonable, as the work was necessary to 10

comply with existing technical specifications; prepare the facility for decommissioning; ensure the 11

health and safety of the workers and the public; retire plant systems to minimize or eliminate 12

unnecessary costs; and keep the public and stakeholders informed on decommissioning progress. 13

a) Decommissioning & Regulatory Affairs 14

The Decommissioning and Regulatory Affairs group consisted of five sub-groups 15

that worked together to perform decommissioning work during 2014: 16

1. The Decommissioning Initial Activities (DIA)15 group was responsible for the 17

initial post-shutdown analysis and planning effort required to transition 18

SONGS from an operating facility to decommissioning. This group 19

developed and issued a 20-year project plan that specifies and coordinates the 20

major activities and initiatives necessary to decommission the plant. This 21

group was also responsible for negotiating contracts with specialty vendors for 22

various tasks and projects necessary to prepare the facility for 23

decommissioning. 24

15 SCE now refers to this group as the Decommissioning and Dismantling Team (DDT).

11

2. The Engineering group, which includes the Civil, Mechanical, and 1

Electrical/I&C Design engineering programs, was responsible for conducting 2

engineering analyses, preparing scope documents, and providing technical 3

expertise to support DIA. This group also evaluated plant systems to 4

determine the timing for system retirement and developed a design change 5

process. 6

3. The Oversight and Nuclear Safety Concerns group provided quality control 7

and audit functions so that all work associated with the storage of nuclear fuel 8

was performed safely and correctly, and documented accurately. This group 9

also includes the SONGS nuclear safety concerns program. 10

4. The Regulatory and Emergency Preparedness group was responsible for 11

evaluating plant requirements for a defueled facility. This allowed the group 12

to determine what changes were needed to the SONGS licensing basis so that 13

the plant would remain in regulatory compliance. This group also 14

implemented the SONGS emergency plan for protecting the health and safety 15

of workers and the public in the event of a radiological emergency. 16

5. The Shutdown Plant Manager Group included the Operations, Radiological 17

Control and Chemistry, Security, Maintenance and Work Control, and Safety, 18

Human Performance, and Performance Improvement groups, as described 19

below: 20

The Operations group was responsible for operating and inspecting the 21

remaining-in service plant equipment, they isolated and drained retired 22

systems, worked with the Maintenance and Engineering groups to remove 23

plant hazards, and provided support to implement regulatory changes and 24

plant design changes. 25

The Radiological Control and Chemistry group ensured compliance with 26

regulations governing radiation exposure control in addition to 27

12

maintaining chemistry control of systems supporting the spent fuel pools. 1

This group also supported the removal of hazardous waste from the site 2

and was responsible for packaging and shipping the waste in accordance 3

with federal, state, and county regulations. 4

The Security group provided protection for SONGS in accordance with 5

NRC regulations (10 C.F.R. § 73 and 10 C.F.R. § 50.54) and SONGS 6

policy. 7

The Maintenance and Work Control group planned and performed the 8

required maintenance and surveillance testing of SONGS’ mechanical and 9

electrical equipment, instrumentation and controls, and protective devices. 10

This group also supported the removal of hazardous materials from retired 11

systems, and implemented the retirement of designated systems. 12

The Safety, Human Performance, and Performance Improvement group 13

monitored and provided oversight and direction on industrial safety 14

measures, safety performance, human performance issues, and identified 15

areas for improvement. This group then planned and implemented the 16

identified improvements. 17

b) Decommissioning Communications, Strategic Planning, and Analysis 18

This group provided support to the decommissioning project by overseeing public 19

relations and community outreach projects such as coordinating the Community Engagement Panel 20

(CEP) meetings, conducting plant tours, and preparing presentations for industry groups and public 21

officials pertaining to the SONGS decommissioning project. This group also provided support for long 22

term planning and analysis for the decommissioning of SONGS. 23

2. Summary of Decommissioning Organization 24

Each of these groups worked to initiate, assemble, plan, engineer, and implement several 25

projects and activities during 2014. For purposes of this testimony, all of these groups together are 26

referred to as the Decommissioning Team (DT). 27

13

V. 1

RECONCILIATION OF DECOMMISSIONING EXPENSES TO THE DCE 2

The 2014 recorded expenses are $44.3 million below the estimated costs for the activities 3

performed in 2014 as included in the DCE. Accordingly, the 2014 expenses should be deemed 4

reasonable. 5

As discussed earlier, the Commission, in D.14-11-040, ordered SCE to file this Application 6

within 60 days of the effective date of the decision to “. . . recover costs for 2014 operations and 7

maintenance and non-operations and maintenance expenses . . . .” Because this Application is being 8

filed in January 2015, SCE has not yet finalized accounting of all of the recorded expenses in 2014. As 9

noted above, SCE is providing recorded expenses through October, and forecast expenses for November 10

and December.16 11

SCE has grouped the decommissioning activities into Work Breakdown Structure (WBS) 12

elements for the purpose of tracking the cost and schedule performance of each activity from inception 13

through completion. (See Attachment A). SCE discusses below the variances between 2014 expenses 14

and the DCE by major project area. Beginning January 1, 2015, SCE will manage the decommissioning 15

work using the Decommissioning Project Cost System (DPCS). All decommissioning expenses 16

incurred will be charged directly to the DCE WBS structure in DPCS. Decommissioning expenses 17

recorded while the DCE WBS was being created (i.e., prior to January 1, 2015), were recorded to 18

SONGS’ previous cost structure of O&M expense and Capital accounts. SCE is currently mapping each 19

of these expenses to the proper WBS activity. In addition, prior to finalizing the DCE and implementing 20

DPCS, SCE utility employees generally either recorded their labor hours to the base O&M expense 21

accounts for their divisions, or to the accounts for specific activities that were capital projects. This 22

practice was also applied to contract labor. As a result, undistributed labor includes a portion of labor 23

dollars that were incurred to support specific distributed cost activities. Undistributed costs, which are 24

sometimes referred to as collateral costs, are typically time-dependent expenses such as utility and 25

16 For certain types of costs, year-end forecasts included some recorded expenses past October 2014.

14

decommissioning general contractor staff, property taxes, insurance, regulatory fees and permits, energy 1

costs, and security staff.17 Distributed expenses are activity specific and include planning and 2

preparation expenses as well as expenses for decontamination, packaging, disposal, and removal of 3

major components and systems.18 As part of the finalization of 2014 expenses, SCE will map these 4

expenses to the appropriate DCE WBS activities. SCE will provide the final mapping in an updated 5

exhibit that will be filed by April 1, 2015. 6

As explained in A.14-12-007, Exhibit SCE-01, the DCE used in this cost reconciliation was 7

developed for the purpose of being used as the basis for an executable decommissioning plan and 8

schedule, and included the evaluation of various alternative sequences and schedules for the 9

decommissioning work to achieve the decommissioning core principles and fundamental values of 10

safety, stewardship, and engagement.19 SCE, however, was not compelled to perform each 11

decommissioning activity precisely in accordance with the schedule assumed in the DCE. As SCE 12

commenced the actual planning and performance of certain decommissioning activities, SCE 13

encountered circumstances that required it to deviate from the DCE schedule. These real-time business 14

needs have required, and will continue to require, SCE to perform some activities earlier or later than 15

assumed in the DCE schedule. As a result, some activities that were estimated to be performed in 2013 16

or 2014 were performed in whole or part in a different year, or were rescheduled until 2015 or later. 17

SCE describes several instances of such timing changes in the variance explanations below. 18

Deviations in the timing of activity performance from the DCE did not necessarily result in 19

changes to the overall estimated cost for any particular activity. For some activities, the incurred costs 20

were, or are expected to be, very close to the estimated costs. For others, SCE incurred higher of lower 21

costs than estimated in the DCE. For still others, SCE did not complete activities that were estimated to 22

17 2014 Decommissioning Cost Analysis of the San Onofre Nuclear Generating Station Units 2 & 3

(“DCE”), page 12.

18 Id. For example, expenses for the segmentation, packaging, and disposal of the reactor internal components are distributed costs.

19 A.14-12-007, Exhibit SCE-01, page 8.

15

have been completed in 2014, and the total cost will not be known until the activity is completed in 2015 1

or later. SCE, therefore, also describes such circumstances in the variance explanations below. 2

3

A. Summary and Reconciliation of 2014 Costs 4

Table V-1 and Table V-2 below provide the summary of the 2014 expenses for SONGS in

comparison to the DCE.20 A description of the forecast variances is provided below and further detail of

lower level variances is provided in Attachment A. The forecast variances explained in this testimony

are against the estimated amount for 2014 expenses provided in Attachment B. The variances reported

in this testimony may change when final, recorded expenses for November and December are included.

For example, some variances currently forecasted as being less than estimated in the DCE, may

ultimately be more than estimated, and vice versa, when final, recorded costs are included. Therefore,

SCE will provide greater detail regarding the variances between recorded costs and the DCE in SCE’s

updated exhibit on April 1, 2015.

20 SCE and SDG&E jointly filed A.14-12-007 requesting the Commission to find the DCE reasonable. The

decommissioning activities described in this testimony section, such as the Cold & Dark (C&D) activities and selection of the Decommissioning General Contractor (DGC), are described in further detail in the supporting testimony, Exhibit SCE-1, for A.14-12-007.

16

Table V-1

Preliminary Comparison Of 2014 Recorded And Forecast Expenses To The DCE

(2014 Dollars in Millions, 100% Level)

17

Table V-2

Preliminary Comparison Of 2014 Recorded And Forecast Expenses To The DCE By

Category


Account Category DCERecorded/ Forecast Variance

Distributed Cold and Dark 45.6$ 18.9$ 26.7$ Distributed Decommissioning General Contractor 0.5 1.9 (1.4) Distributed Historical Site Assessment 8.8 2.6 6.2 Distributed Regulatory Compliance 6.6 1.9 4.7 Distributed Radioactive Material Disposal 20.6 11.2 9.4

82.1$ 36.5$ 45.6$ Undistributed Labor 50.4 60.9 (10.5) Undistributed Non-Labor 26.3 14.6 11.7

76.7$ 75.5$ 1.2$ 158.8$ 112.0$ 46.8$

Distributed ISFSI 13.5$ 18.8$ (5.3)$ Distributed Regulatory Compliance 0.3 0.3 - Distributed Security 3.6 6.0 (2.4)

17.4$ 25.1$ (7.7)$ Undistributed Labor 47.3 52.6 (5.3) Undistributed Non-Labor 11.0 8.4 2.6

58.3$ 61.0$ (2.7)$ 75.7$ 86.1$ (10.4)$

Distributed Historical Site Assessment - Mesa Site 0.6$ 1.4$ (0.8)$ Distributed Mesa Site 0.3 3.3 (3.0) Distributed Regulatory Compliance 17.7 5.1 12.6

18.6$ 9.8$ 8.8$ Undistributed Labor - - - Undistributed Non-Labor 12.5 13.4 (0.9)

12.5$ 13.4$ (0.9)$ 31.1$ 23.2$ 7.9$

265.6$ 221.3$ 44.3$

Subtotal Distributed

Subtotal UndistributedTotal Site Restoration

Grand Total

2014

License Termination, Decon Pd 2

Spent Fuel Management, SNF Pd 2

Site Restoration, SR Pd 1


Subtotal UndistributedTotal License Termination


Subtotal UndistributedTotal Spent Fuel Management

18

B. Activity Descriptions and Variance Explanations of O&M Expenses 1

1. License Termination, Decon Pd 2 2

During 2014, SCE incurred21 License Termination-related expenses of $112.0 million. 22 3

The estimated cost for this period, as defined in DCE Decon Period 2, was $158.8 million.23 This 4

resulted in a variance of $46.8 million. A substantial amount of this variance occurred due to the fact 5

that work that was estimated to occur in 2014 by the DCE is now scheduled to be performed in 2015. 6

SCE explains this variance in further detail in the sections below. Consistent with the DCE, Decon Pd 2 7

expenses are summarized in terms of distributed expenses and undistributed costs. 8

a) Distributed 9

(1) Cold and Dark 10

(a) Description 11

One of the first planned SONGS 2&3 decommissioning activities 12

was to transition the plant to a Cold and Dark (C&D) condition. C&D refers to the condition of the 13

plant in which most of the electrical equipment is de-energized and mechanical systems are 14

depressurized and drained. There is a minimal set of systems and components that must remain 15

operational during C&D in accordance with license conditions and to support spent fuel pool cooling. 16

Plant personnel identified the systems and components that are needed to place SONGS in a C&D 17

condition, and developed the engineering modification packages that, when implemented, will ensure 18

the new configuration supports C&D. 19

This work included extensive engineering analyses to define the 20

required scope; update, modify and/or develop complex calculations; and update, modify or develop 21

required engineering drawings for the following: 1) Power Ring/Distribution System, 2) Command 22

Center, 3) Health Physics Checkpoint/Chemistry Lab, 4) Fire Detection and Suppression Systems, 5) 23

21 2014 incurred expenses described in this testimony include actual and forecasted expenditures.

22 See Attachment A, line 65.

23 Id.

19

HVAC (various buildings), 6) Spent Fuel Pool Islands, 7) Rad, Non-Rad, and Salt Water Dilution 1

Pumps, 8) Spent Fuel Pool Make-up, and 9) Telecommunications. The C&D work is necessary to 2

prepare the plant for major decommissioning activities, including ensuring the safety of workers during 3

decommissioning. 4

(b) Variance Explanation 5

In the DCE, the total estimated cost for C&D projects in 2014 was 6

$45.6 million.24 SCE incurred $18.9 million25 during 2014, or $26.7 million less than estimated.26 The 7

DCE, however, included estimated expenses for both the design and implementation of C&D projects. 8

The estimated cost for C&D project design work in 2014 was $13.7 million.27 SCE incurred $13.2 9

million28 for C&D design work during 2014, or $0.5 million less than estimated. In addition, the 10

estimated cost for the spent fuel pool support system was $4.1 million,29 and SCE incurred $4.2 11

million.30 12

The remaining estimated cost for C&D project implementation 13

work in 2014 was $27.8 million.31 SCE incurred $1.5 million32 for C&D project implementation, or 14

$26.3 million less than estimated.33 This variance occurred because most of the C&D project 15

implementation work was rescheduled to 2015 so that SCE could complete final engineering plans for 16

the project. The estimate for the project was initially based on a conceptual design. SCE prudently 17

chose to complete further engineering and design work prior to entering the procurement and 18


25 Id.

26 Id.

27 See Attachment A, lines 8, 9, and 10 ($12.3 + $0.8 + $0.6 = $13.7).


29 See Attachment A, lines 1 and 2 ($3.3 + $0.8 = $4.1).


31 See Attachment A, lines 3, 4, 5, 6, and 7 ($23.0 + $1.1 + $0.5 + $0.1 + $3.1 = $27.8).



20

construction (i.e., implementation) phases. This effort provides greater certainty in planning the project 1

scope and schedule, and keeping overall costs within the estimate. 2

(2) Decommissioning General Contractor (DGC)34 3

(a) Description 4

SCE plans to utilize a DGC, a highly qualified vendor to perform the 5

decommissioning and dismantling activities of the project and to outsource any additional support 6

required to achieve predictable cost and schedule results. Under this approach, SCE would retain its 7

responsibility as the licensee and its obligations to state and federal regulators, and the DGC would be 8

responsible for the implementation of the Project Execution Plan (PEP).35 SCE would monitor the 9

DGC’s progress and cash flows, holding the DGC accountable to established and defined metrics, which 10

demonstrate that actual progress is aligned with the expenditures. The DGC provides a number of 11

benefits, which SCE explained in its supporting testimony for A.14-12-007. Briefly, engaging an 12

experienced decommissioning general contractor or DGC provides the following potential advantages: 13

Enhanced Oversight – Engaging a DGC will allow SCE to deal directly with one 14

decommissioning contractor responsible for all major decommissioning activities, rather than multiple 15

contractors responsible for various, potentially overlapping aspects of decommissioning. This should 16

streamline decommissioning activities and provide greater schedule and cost control. In addition, 17

engaging a DGC – rather than self-performing some tasks – provides the advantage of allowing SCE, as 18

the lead NRC license holder, to focus on exercising oversight and ensuring compliance with NRC 19

regulations and other state and federal environmental requirements. 20

Cost Control – The DGC contract will provide a fixed price, with any scope and 21

cost changes being subject to the terms and conditions of the DGC contract. When completing 22

decommissioning activities under a fixed-priced DGC contract, the DGC will have a strong commitment 23

34 In A.14-12-082, SCE referred to the Decommissioning General Contractor (DGC) as the Decommissioning

Operations Contractor (DOC). SCE will use the term DGC going forward, as this term better describes the contractor’s role.

35 The Project Execution Plan for SONGS decommissioning will be developed after the DGC is retained.

21

to adhering to the planned decommissioning schedule, as it will share the economic risks of schedule 1

and cost overruns. This potentially offers greater assurance of controlling decommissioning costs for 2

the benefit of customers, who will receive refunds of any unspent decommissioning funds. 3

Greater Expertise –The use of a DGC will utilize an organization whose core 4

business and competencies are focused on cost-effectively implementing and managing large industrial 5

projects similar in scope to decommissioning. The DGC will be able to use its staff for various 6

decommissioning activities and take advantage of the economies of scale provided by its internal 7

organization and capabilities. Engaging a DGC will avoid the need for SCE to hire new employees and 8

retrain remaining site personnel, which will save time and costs. 9

Advantages available from lessons learned – In addition, SCE and the selected 10

DGC will be able to optimize SONGS decommissioning by applying lessons learned from prior DGC 11

contracts. 12


The DCE estimated that expenses associated with selecting the 14

DGC would be approximately $0.5 million36 in 2014. SCE incurred $1.9 million37 in 2014, or $1.4 15

million more than estimated.38 The DCE did not fully include costs for the process that SCE is 16

undertaking to select the DGC, as SCE incurred expenses in 2014 to retain CH2M Hill as a consultant to 17

study the feasibility of using a DGC; develop a DGC project charter, strategic assessment and plan, and 18

a project execution and sourcing plan; prepare an SCE sourcing document and a request for information 19

(RFI); review RFI responses to select pre-qualified bidders; and begin preparing a request for proposal 20

(RFP). SCE prudently engaged the consultant and incurred additional expenses for these purposes, in 21

order to obtain independent, expert advice from a vendor with substantial experience in the nuclear 22

industry and decommissioning. The consultant will help SCE establish project controls that will allow 23


37 Id.

38 Id.

22

SCE to implement lessons learned from other DGCs, and better assure a fair, transparent, and rigorous 1

procurement process for the DGC, and ultimately a well-developed DGC contract capable of being 2

implemented. For example, one lesson learned from prior DGCs concerned the importance of engaging 3

pre-qualified bidders on site during the RFP process, so that the bidders would have better access to site 4

information necessary to improve the competitive-bidding process and the quality of bids. To address 5

this lesson learned and enhance the RFP process for the DGC, SCE installed temporary trailers that 6

would allow each of the pre-qualified bidders to have access to the site during the first few months of 7

2015 while formulating their bids. SCE anticipates that the DGC contract will be awarded during the 8

first quarter of 2016, in anticipation of commencing physical decontamination and dismantling work 9

shortly thereafter. 10

(3) Historical Site Assessment (HSA) 11

(a) Description 12

The HSA identifies potential sources of contamination and 13

radionuclides of concern; differentiates impacted and non-impacted areas; assesses the likelihood of 14

contaminant migration; and provides input to characterization surveys, remediation, final status surveys, 15

and license termination plans. The HSA also determines the nature and extent of contamination, and the 16

radionuclide mix for each surveyed area. It also establishes background reference areas, provides an 17

initial site model used to develop contamination guideline levels, and optimizes surveys, so that 18

collected data may be used in the final status survey and design. These initial assessments, which are 19

required and necessary decommissioning activities, also will aid the final status survey, which must be 20

completed to confirm regulatory compliance with license termination requirements. 21


The DCE estimated the cost to perform the HSA in 2014 would be 23

$8.8 million.39 SCE incurred $2.6 million40 in 2014, or $6.2 million less than estimated.41 This variance 24 39 See Attachment A, line 16.

40 Id.

41 Id.

23

occurred because SCE partially completed the HSA in 2014 because certain plant areas were 1

inaccessible. Because the DCE did not include any costs for HSA work in 2015, the expenses SCE will 2

incur to continue this work in 2015 will offset this variance. 3

(4) Regulatory Compliance 4

(a) Description 5

SCE is required to comply with all federal regulations applicable to 6

the safe storage of nuclear fuel on site until the fuel is removed to a permanent repository by the DOE. 7

Additionally, many portions of the federal regulations governing nuclear facilities apply only to plant 8

operations, and are no longer applicable after the facility is permanently retired. Upon the permanent 9

retirement of SONGS 2 & 3, SCE needed to reassess which portions of these federal regulations 10

continue to apply to SONGS. Based on SCE’s reassessments, SCE revised many of its programs and 11

procedures to be consistent with the now-applicable portions of these regulations, and submitted them to 12

the NRC for review and approval. These programs included, but are not limited to, the SONGS 2 & 3 13

Permanently Defueled Technical Specifications (PDTS), the SONGS Permanently Defueled Emergency 14

Plan (PDEP),42 and the Certified Fuel Handler Program, as discussed further below. 15

Technical specifications (or “tech specs”) define safety limits for 16

key parameters that are established to protect the integrity of physical barriers against the uncontrolled 17

release of radioactivity. They contain Limiting Conditions for Operation (LCOs) that establish the 18

minimum performance levels for reactor operating configurations. Technical specifications have 19

surveillance requirements for testing and inspections that are unique to the type of reactor at the facility. 20

Upon the announcement of permanent cessation of operations at SONGS, DT began working on 21

modifying the technical specifications that were required during operations to tech specs for a 22

permanently defueled facility and the subsequent license amendment request (LAR) to revise the facility 23

operating license to incorporate the PDTS. These activities were necessary and reasonable in light of 24

the fact that SONGS is a permanently shutdown facility. 25

42 See, e.g., 10 C.F.R. Part 50, Appendix E “Emergency Planning and Preparedness for Production and

Utilization Facilities.”

24

The PDEP provides the transition from an emergency plan for an 1

operating nuclear facility to an emergency plan for a permanently defueled facility. The PDEP provides 2

the scope of how SONGS will respond to potential radiological emergencies at the station and how 3

SONGS will coordinate a response with off-site federal agencies and county organizations, considering 4

SONGS’ permanently shut down and defueled status. 5

Pursuant to NRC regulation, upon permanent removal of fuel from 6

the SONGS 2 & 3 reactor vessels, the 10 C.F.R. Part 50 license no longer authorizes reactor operation or 7

placement or retention of fuel in the reactor vessels. As a result, licensed reactor operators are no longer 8

required to support plant operating activities. Instead, approval of a Certified Fuel Handler training and 9

retraining program was needed to facilitate activities associated with decommissioning and the 10

management and handling of irradiated fuel. The NRC approved the SONGS Certified Fuel Handler 11

Qualification training and retraining program on September 30, 2014. Again, SCE’s activities to 12

establish this program are also reasonable given the status of SONGS. 13

In addition, SCE was required to develop an updated DCE and a 14

PSDAR for submittal to the NRC. The site specific DCE is a “bottoms up” estimate and addresses the 15

expenses associated with onsite wet spent fuel storage and dry spent fuel storage as well as the eventual 16

transfer of spent fuel to the DOE; radiological decontamination and termination of the 10 C.F.R. Part 50 17

license; and final site restoration, including all costs required to terminate the site easements granted by 18

the U.S. Department of the Navy and the California State Lands Commission, and any costs associated 19

with compliance with other State of California laws and regulations. The PSDAR provides a high-level 20

summary of decommissioning plans and includes the DCE and Environmental Report (ER). On 21

December 27, 2014, the 90 day public comment period expired and SCE is permitted to perform major 22

decommissioning activities under NRC regulations, pending SCE’s obtaining all required environmental 23

permits. SCE’s work to complete these required submissions was necessary and reasonable to meet 24

NRC requirements and to plan for decommissioning. 25

25


The estimated cost in the DCE for these regulatory compliance 2

activities in 2014 was $6.6 million.43 SCE incurred $1.9 million,44 or $4.7 million less than estimated.45 3

The primary reason for this variance was that many of the expenses were recorded as undistributed labor 4

expenses as discussed above. In SCE’s updated reconciliation of 2014 decommissioning costs, to be 5

submitted to the Commission by April 1, 2015, SCE will assign the appropriate portion of the 6

undistributed labor expenses to these activities. 7

(5) Radioactive Material Disposal 8

(a) Description 9

SCE used many tools and equipment in radioactive areas of the 10

plant to perform and support online maintenance activities and refueling outages. SCE also accumulated 11

quantities of radioactive resins, mixed wastes, and other legacy radioactive materials during plant 12

operations. These materials did not require the demolition of any buildings or structures in order to be 13

prepared for disposal. Beginning shortly after SONGS 2 & 3 were permanently retired, on June 7, 2013, 14

and continuing into 2014, SCE surveyed, packaged, and shipped many of these types of materials to 15

licensed disposal facilities for Class A, B, and C Low-Level Radioactive Waste (LLRW). These 16

activities were necessary and reasonable to dispose radioactive materials in a safe and responsible 17

manner. 18


The estimated cost for this activity during 2014 was $20.6 20

million.46 SCE incurred $11.2 million,47 or $9.4 million less than estimated.48 SCE was able to dispose 21


44 Id.

45 Id.


47 Id.

48 Id.

26

of the materials for a lower cost than estimated in the DCE because SCE was able to successfully 1

employ volume reduction techniques that were not assumed in the DCE and obtain lower LLRW 2

disposal rates than were assumed in the DCE. 3

b) Undistributed 4

Undistributed license termination expenses are labor and non-labor expenses that 5

were not allocated to specific license termination activities. In the DCE, the estimated undistributed 6

expenses associated with Decon Period 2 were $76.7 million49 in 2014. SCE incurred $75.5 million50 7

for these types of expenses in 2014, or $1.2 million less than estimated.51 8

(1) Labor 9

(a) Description 10

Subsequent to the permanent retirement of the units, SCE 11

evaluated the functions that would continue to be required to support the transition from plant operations 12

to decommissioning. By December 2014, SCE reduced SONGS labor force to 433 utility workers. In 13

addition to the SCE labor costs, undistributed labor also includes the contract labor expenses for staff 14

augmentation. The total labor expenses were allocated between License Termination and Spent Fuel 15

Management based on the split assumed in the DCE. License Termination labor also included the 16

expenses for the Decommissioning Advisor (DA).52 As discussed above, the current workforce is 17

required to perform the decommissioning activities, and maintain the remaining plant systems needed to 18

meet current license requirements. 19


50 Id.

51 Id.

52 The SONGS Decommissioning Advisor is a subject matter expert in decommissioning, decontamination and dismantlement (D&D), engineering, licensing, and regulatory affairs. The DA is knowledgeable in environmental issues, spent fuel storage, project management, and low level waste management, and is capable of supporting both the preparation and the review of regulatory submittals.

27


In the DCE, the estimated staffing cost for this period was $50.4 2

million.53 SCE incurred $60.9 million,54 or $10.5 million more than estimated.55 This variance occurred 3

in part because some labor expenses incurred to support distributed cost activities were initially recorded 4

as undistributed labor expenses as discussed above. These expenses will be reallocated in SCE’s 5

updated exhibit that will be submitted to the Commission by April 1, 2015. In addition, SCE exceeded 6

the estimated cost for the DA because DA resources were used to perform third party independent 7

review functions that were not included in the DCE. SCE reasonably incurred these additional expenses 8

to ensure SCE’s decommissioning plans and activities were vetted by an independent expert with 9

decommissioning experience. This allowed SCE to prepare high-quality submissions to the NRC and 10

successfully implement other decommissioning activities. In addition, SCE engaged the DA to obtain 11

independent, expert reviews and information as necessary to respond to questions from external 12

stakeholders, upholding a core decommissioning value of community engagement. Similar to utility 13

labor, therefore, some of these expenses will also be reallocated to specific distributed activities. 14

(2) Non-Labor 15

(a) Description 16

In 2014, SCE incurred non-labor expenses necessary to support the 17

work being performed at the plant. Some non-labor expenses corresponded exclusively to License 18

Termination, consistent with their estimated expenses in the DCE. Non-labor expenses applicable only 19

to License Termination in 2014 included association fees and expenses, CEP costs, environmental 20

permits and fees, non-process computer costs, telecommunications costs, and workers’ compensation 21

insurance. Other non-labor expenses were allocated among the License Termination, Spent Fuel 22

Management, and Site Restoration cost categories, consistent with their estimated expenses in the DCE. 23


54 Id.

55 Id.

28

Non-labor expenses partially allocated to License Termination in 2014 included utility staff Health 1

Physics (HP) (i.e., Radiation Protection) supplies, security-related expenses, NRC spent fuel fees, dry 2

active waste disposal, materials and services, energy, utilities, site lease and easement expenses, and 3

insurance. 4


The estimated cost in the DCE was $26.3 million,56 for these 6

License Termination non-labor items. SCE incurred $14.6 million57 or $11.7 million less than 7

estimated.58 Recorded expenses have been split between accounts based on the allocation percentages 8

assumed in the DCE. 9

SCE underran the DCE License Termination non-labor amount due 10

to various reductions to non-labor expenses that were unanticipated at the time the DCE was prepared. 11

SCE cancelled association memberships for INPO and the USA STARS Alliance nuclear industry 12

groups. CEP incurred expenses were below estimated levels as the panel was ramping up in the 13

beginning of 2014, and therefore the incurred expenses associated with travel, speakers, and hosting 14

events was lower than estimated. SCE underran estimated insurance expenses because SCE received a 15

$3 million59 dividend from NEIL, the nuclear property insurer. 16

In addition, SCE performed less work in radiological areas, and 17

therefore, incurred lower than estimated expenses for HP supplies during 2014. SCE also incurred 18

lower energy expenses than estimated in 2014 because the DCE assumed SCE would be charged higher 19

retail rates. However, the incurred expenses were based on lower wholesale rates. 20

2. Spent Fuel Management, SNF Pd 2 21

Spent Fuel Management expenses are incurred to support the safe storage of spent 22

nuclear fuel at the SONGS site until it is accepted for permanent disposal by the DOE. In the DCE, the 23

56 Id.


58 Id.

59 Portions of the NEIL dividend are included in the totals shown on Attachment A, lines 47 and 93.

29

expenses related to spent fuel management throughout 2014 were defined in SNF Period 2. The 1

estimated cost in this category was $75.7 million.60 SCE incurred61 $86.1 million,62 or $10.4 million 2

more than estimated.63 These expenses may also be summarized in terms of distributed and 3

undistributed costs, consistent with the DCE. 4

a) Distributed 5

(1) Independent Spent Fuel Storage Installation (ISFSI) 6

(a) Description 7

Due to the earlier-than-planned retirement of SONGS, DT 8

developed a plan and conducted initial engineering activities to identify the scope and requirements for 9

off-loading the remaining 2668 irradiated fuel assemblies from the spent fuel pools to the ISFSI by 10

2019. This acceleration required DT to evaluate a variety of locations for ISFSI expansion and conduct a 11

thorough evaluation of available systems that could be used at SONGS. Based on a rating scale that 12

included evaluating the technical qualities and costs of the systems, the required NRC license 13

amendments, local and state permits, environmental impacts, and system maintenance, one technology 14

and location was considered the optimum choice – the Holtec system in the current ISFSI site location, 15

which would be expanded.64 SCE elected to change vendors because the overall spent fuel storage cost 16

would be reduced, while maintaining the same level of performance and safety. 17

The distributed spent fuel management expenses include the cost 18

to store spent fuel both in wet storage in the spent fuel pools and in dry storage in the ISFSI; and the cost 19

to expand onsite dry storage capacity and to transfer the fuel that remains in wet storage to dry storage. 20


61 As noted previously, 2014 incurred expenses include actual and forecasts.


63 Id.

64 The system currently in use at SONGS is an AREVA system, which is a horizontal, above ground dry storage system. The Holtec system is a vertical below ground system. SONGS is planning to manage both systems until the DOE accepts transfer of the used fuel.

30


During 2014, SCE incurred $18.8 million65 for ISFSI activities 2

compared to an estimated cost of $13.5 million,66 or $5.3 million more than estimated.67 This variance 3

occurred due to the initial milestone payment to Holtec, the new vendor. 4


(a) Description 6

The regulatory compliance activities associated with spent fuel 7

management includes post-Fukushima spent fuel pool modifications, the spent fuel pool decay heat 8

analysis, the spent fuel pool zirconium fire/shine analysis, and the development of the SONGS Irradiated 9

Fuel Management Plan (IFMP).68 10


SCE incurred $0.3 million69 in expenses associated with 12

Regulatory Compliance relative to an estimated cost of $0.3 million70 resulting in zero variance. 13

(3) Security 14

(a) Description 15

SCE activities that support the security of the SONGS 2&3 spent 16

fuel include the NRC cyber security program, in accordance with 10 C.F.R. § 73.54, and the SONGS 17

Security Shutdown Strategy. 18

65 See Attachment A,, line 72.

66 Id.

67 Id.

68 The IFMP provides the NRC with a description of the program by which SCE intends to manage and provide funding for the management of the irradiated fuel following the permanent cessation of operation of the reactor until SCE transfers title to and possession of the fuel to the DOE.



31


SCE incurred $6.0 million71 in expenses associated with the NRC 2

cyber security program for SONGS and for the SONGS Security Shutdown Strategy in 2014 relative to 3

an estimated cost of $3.6 million,72 or $2.4 million more than estimated.73 This variance occurred 4

because a portion of the SONGS Security Strategy work that was estimated to occur in 2013 was 5

performed in 2014. As a result, the increased expenses incurred in 2014 partially offset an underspend 6

relative to estimated Spent Fuel Management security expenses in 2013.74 7

b) Undistributed 8

Undistributed spent fuel management expenses are labor and non-labor expenses 9

that are not allocated to specific spent fuel management activities. In the DCE, the estimated 10

undistributed expenses associated with SNF Period 2 were $47.3 million75 in 2014. SCE incurred $52.6 11

million76 for these types of costs, or $5.3 million more than estimated.77 12

(1) Labor 13

(a) Description: 14

Subsequent to the permanent retirement of the units, SCE 15

evaluated functions that would continue to be required to support the transition to decommissioning. 16

The total labor expenses were allocated between License Termination and Spent Fuel Management 17

based on the split assumed in the DCE as discussed above. 18


72 Id.

73 Id.

74 In 2013, SCE incurred $4.7 million in security expenses associated with Spent Fuel Management relative to an estimated cost of $10.3 million, or $5.6 million less than estimated.


76 Id.

77 Id.

32

(b) Variance Explanation: 1

In the DCE, the estimated staffing cost for this period was $47.3 2

million.78 SCE incurred $52.6 million,79 or $5.3 million more than estimated.80 This variance occurred 3

in part because some labor expenses that should have been allocated to distributed cost activities were 4

initially recorded as undistributed labor expenses as discussed above. These expenses will be 5

reallocated in SCE’s updated exhibit that will be submitted to the Commission by April 1, 2015. 6

(2) Non-Labor 7

(a) Description 8

In 2014, SCE incurred non-labor expenses necessary to support the 9

work being performed at the plant. Some non-labor expenses corresponded exclusively to Spent Fuel 10

Management activities, consistent with their estimated expenses in the DCE. Non-labor expenses 11

applicable only to Spent Fuel Management in 2014 included emergency preparedness fees, personal 12

computer costs, and spent fuel maintenance costs. Other non-labor expenses were allocated among the 13

License Termination, Spent Fuel Management, and Site Restoration cost categories, consistent with their 14

estimated expenses in the DCE. Non-labor expenses partially allocated to Spent Fuel Management in 15

2014 included utility staff HP supplies, security-related expenses, NRC spent fuel fees, dry active waste 16

disposal, materials and services, energy, utilities, and insurance fees. 17


The estimated cost was $11.0 million,81 for these non-labor items. 19

SCE incurred $8.4 million82 or $2.6 million less than estimated.83 Incurred expenses have been split 20

between accounts based on the allocation percentages assumed in the DCE. In addition, as noted above, 21


79 Id.

80 Id.

81 Id.


83 Id.

33

SCE performed less work in radiological areas, and therefore, incurred lower than estimated expenses 1

for HP supplies during 2014. SCE also incurred lower energy expenses than estimated in 2014. 2

3. Site Restoration, SR Pd 1 3

Site Restoration expenses are for all activities required, in addition to license termination 4

and spent fuel management activities, to complete its obligation to decommission both the onshore and 5

offshore portions of the SONGS facility, terminate the site easements and leases, and return the site to 6

the landowners. In addition to site lease and easement related payments, the expenses to terminate the 7

pre-existing nuclear fuel purchase and fabrication contracts, as well as utility worker severance 8

payments and performance incentive (results sharing) program payments are included in this category. 9

The estimated cost for site restoration activities for 2014 was $31.1 million.84 SCE 10

incurred85 $23.2 million86 dollars, or $7.9 million less than estimated.87 11

a) Distributed 12

The distributed site restoration expenses incurred during 2014 included the 13

expenses for the Historical Site Assessment and Characterization Survey for the SONGS Mesa site, the 14

expenses to prepare to surrender the SONGS Mesa site to the U.S. Department of the Navy (Navy), and 15

regulatory compliance costs. 16

(1) Historical Site Assessment and Characterization Survey – Mesa 17

(a) Description 18

The SONGS site consists of the plant site and the Mesa site. The 19

Mesa site is on the east side of the I-5 freeway and housed major equipment and buildings such as the 20

warehouse and office facilities. The Mesa site assessment and characterization survey mirrors the HSA 21

for the plant site as described above and identifies potential sources of contamination and radionuclides 22


85 As noted previously, 2014 incurred expenses include actual and forecasted expenditures


87 Id.

34

of concern; differentiates impacted and non-impacted areas; assesses the likelihood of contaminant 1

migration; and provides input to characterization surveys, remediation, and final status surveys. 2


The DCE estimated that the cost to perform the Mesa site 4

assessment and characterization survey during 2014 would be $0.6 million.88 SCE incurred $1.4 5

million89 in 2014, or $0.8 million more than estimated.90 This variance occurred because much of the 6

work was accelerated from 2015 to support the Mesa Site surrender project discussed below. 7

(2) Mesa Site Surrender 8

(a) Description 9

During 2014, a significant amount of work was performed to 10

return the land and selected buildings at the Mesa site back to the Navy. Several meetings between SCE 11

and the Navy were conducted to negotiate the surrender plan of the Mesa site and to identify the 12

buildings and/or structures that would remain at the site, at the Navy’s request. In parallel, SCE 13

successfully demolished 30 buildings, structures, and containers, and removed appurtenant landscaping. 14

These activities and associated costs are reasonable as they will result in future savings. Specifically, by 15

terminating some of the Mesa leases and surrendering portions of the Mesa site to the Navy earlier than 16

estimated, SCE will avoid future lease payment and other site-maintenance costs. Figure V-3 and 17

Figure V-4 below provide a comparison of the Mesa facility in 2013 to November 2014: 18


89 Id.

90 Id.

35

Figure V-3 SONGS Mesa Site-2013

Figure V-4 SONGS Mesa Site – 2014

36


The DCE estimated that the cost to perform the Mesa Site 2

Surrender during 2014 would be $0.3 million.91 SCE incurred $3.3 million92 in 2014, or $3.0 million 3

more than estimated.93 This variance occurred because work was performed earlier than estimated in the 4

DCE. The DCE included most of the Mesa Site Surrender expenses in 2016. 5


(a) Description 7

Prior to the permanent retirement of SONGS 2&3, SCE had 8

executed several contracts for the purchase of uranium and the fabrication of new fuel assemblies for use 9

in future fuel cycles. Following the decision to permanently retire SONGS, SCE used, and continue to 10

use, its best efforts to sell the uranium and to avoid incurring fabrication expenses for fuel assemblies 11

that it would no longer need. These activities were reasonable to reduce unnecessary expenses. 12


The DCE estimated $17.7 million94 for nuclear fuel contract 14

termination expenses during 2014. SCE incurred $5.1 million,95 or $12.6 million96 less than estimated. 15

However, because SCE expended $10.6 million for nuclear fuel contract termination expenses during 16

2013, relative to an estimate of $0 in 2013, SCE incurred approximately $2 million less than the 17

estimated expense for the June 7, 2013 through December 31, 2014 period. 18

b) Undistributed 19

Undistributed site restoration costs are non-labor expenses that are not assigned to 20

site restoration activities. In the DCE, the estimated undistributed expenses associated with SR Period 1 21


92 Id.

93 Id.


95 Id.

96 Id.

37

during 2014 were $12.5 million.97 SCE incurred $13.4 million98 for these types of costs, or $0.9 million 1

more than estimated.99 2

(1) Labor 3

No labor expenses were estimated or incurred for site restoration activities 4

during 2014. 5

(2) Non-Labor 6

(a) Description: 7

SCE incurred Site Restoration non-labor expenses in 2014 for 8

severance and results sharing and for a portion of the site lease and easement expenses. The remaining 9

portion of the site lease and easement expense was allocated to License Termination. Severance 10

expenses incurred were related to SONGS’ continuing workforce reductions. The site lease and 11

easement expenses are the contractual amounts that SCE is required to pay the Navy. 12


The estimated undistributed expenses associated with SR Period 1 14

during 2014 were $12.5 million.100 SCE incurred $13.4 million101 for this category, or $0.9 million 15

more than estimated.102 $12.1 million103 of the $13.4 million104 was for separation payments to severed 16

utility workers. The remaining $1.3 million105 was incurred because the easement expenses for the plant 17

site were underestimated by $0.8 million106 in the DCE. 18


98 Id.

99 Id.


101 Id.

102 Id.




106 Id.

Attachment A

Attachment A

Southern California Edison

SONGS Decommissioning

Preliminary Comparison Of 2014

Recorded And Forecasted Costs To The DCE By WBS


Category D/U Phase WBS

DCE

No. Description

2014

Decommissioning

Cost Estimate

2014

Actual/Forecast

Forecasted 2014

Variance

1 Cold and Dark D LT WD2-1.1.1.01.01 2.26 Install Spent Fuel Pool System Modifications - Unit 2 3.3$ 4.2$ (0.9)$

2 Cold and Dark D LT WD4-1.1.6.01.02.02 2.23 Design Spent Fuel Pool Support System Modifications 0.8 - 0.8

3 Cold and Dark D LT WD4-1.1.1.01.21.01 2.19 Implement Cold and Dark (Repower Site) 23.0 1.5 21.5

4 Cold and Dark D LT WD4-1.1.1.01.21.02 2.29 Implement Control Room Modifications (Command Center Relocation) 1.1 - 1.1

5 Cold and Dark D LT WD4-1.1.1.01.21.03 2.30 Implement Spent Fuel Pool Security Modifications 0.5 - 0.5

6 Cold and Dark D LT WD4-1.1.1.01.22.02 2.31 Transition Project Modifications 0.1 - 0.1

7 Cold and Dark D LT WD4-1.1.2.01.21.01 2.21 Drain and De-Energize Non-Essential Systems (DEC Process) 3.1 - 3.1

8 Cold and Dark D LT WD4-1.1.6.01.02.01 2.18 Planning and Design For Cold and Dark 12.3 13.2 (0.9)

9 Cold and Dark D LT WD4-1.1.6.01.02.03 2.24 Design Control Room Relocation 0.8 - 0.8

10 Cold and Dark D LT WD4-1.1.6.01.02.04 2.25 Design Spent Fuel Security System Modifications 0.6 - 0.6

11 Cold and Dark Total 45.6$ 18.9$ 26.7$

12

13 DGC Prep D LT WD4-1.1.5.01.21 2.22 Select Decommissioning General Contractor (DGC) 0.5 1.9 (1.4)

14 DGC Prep Total 0.5$ 1.9$ (1.4)$

15

16 H S A D LT WD4-1.1.6.01.01 2.17 Historical Site Assessment/Site Charac. 8.8 2.6 6.2

17 H S A Total 8.8$ 2.6$ 6.2$

18

19 REG Comp D LT WD4-1.1.7.01.01.01 2.01 Develop Certified Fuel Handler Program 0.1 - 0.1

20 REG Comp D LT WD4-1.1.7.01.01.02 2.02 Prepare Post-Shutdown QA Plan 0.4 - 0.4

21 REG Comp D LT WD4-1.1.7.01.01.03 2.03 Prepare Post-Shutdown Security Plan 0.4 - 0.4

22 REG Comp D LT WD4-1.1.7.01.01.04 2.04 Prepare Post-Shutdown Fire Protection Plan 0.4 - 0.4

23 REG Comp D LT WD4-1.1.7.01.01.05 2.05 Prepare Defueled Radiation Protection Manual 0.4 - 0.4

24 REG Comp D LT WD4-1.1.7.01.01.06 2.06 Prepare Preliminary Defueled Technical Specifications (Complete) 0.2 0.1 0.1

25 REG Comp D LT WD4-1.1.7.01.01.07 2.07 Prepare Defueled Safety Analysis Report (DSAR) 1.3 0.7 0.6

26 REG Comp D LT WD4-1.1.7.01.01.08.01 2.09 Prepare Post-Shutdown Emergency Preparedness Plan 0.7 - 0.7

27 REG Comp D LT WD4-1.1.7.01.01.09.01 2.11 Prepare Post-Shutdown Decommissioning Activities Report (PSDAR) 0.7 - 0.7

28 REG Comp D LT WD4-1.1.7.01.01.09.02 2.12 Post-Shutdown Decommissioning Activities Report (PSDAR) - NRC Review 0.1 - 0.1

29 REG Comp D LT WD4-1.1.7.01.01.09.03 2.13 Respond to NRC Questions on PSDAR - - -

30 REG Comp D LT WD4-1.1.7.01.01.10.01 2.14 Prepare Decommissioning Cost Estimate (DCE) 1.8 1.1 0.7

31 REG Comp D LT WD4-1.1.7.01.01.10.02 2.15 Decommissioning Cost Estimate (DCE) - NRC Review 0.1 - 0.1

32 REG Comp Total 6.6$ 1.9$ 4.7$

33

34 RAM D LT WD4-1.1.8.01.02 2.16 Disposition of Legacy Wastes (2014) 20.6 11.2 9.4

35 RAM Total 20.6$ 11.2$ 9.4$

36

37 Distributed Subtotal $ 82.1 $ 36.5 $ 45.6 1 Of 4

A-1

Attachment A







DCE

No. Description

2014

Decommissioning

Cost Estimate

2014

Actual/Forecast

Forecasted 2014

Variance

38

39 LABOR U LT WD4-1.2.1.01.01 1.01 Labor License Termination Reporting 47.2 56.7 (9.5)

40 LABOR U LT WD4-1.2.1.01.01.10 1.03 Security Guard Force 1.7 1.9 (0.2)

41 LABOR U LT WD4-1.2.2.01.01.09 1.13 Craft Worker Training (moved to DIA/DDT Labor) 0.2 - 0.2

42 LABOR U LT WD4-1.2.2.01.01.22 1.25 Decom Advisor (moved to DIA/DDT Labor) 1.3 2.3 (1.0)

43 LABOR Total $ 50.4 $ 60.9 $ (10.5)

44

45 NON-LBR U LT WD4-1.2.2.01.01.01 1.02 Utility Staff Health Physics Supplies 1.5 0.1 1.4

46 NON-LBR U LT WD4-1.2.2.01.01.02 1.04 Security Related Expenses 0.1 0.1 -

47 NON-LBR U LT WD4-1.2.2.01.01.03 1.05 Insurance 3.7 1.4 2.3

48 NON-LBR U LT WD4-1.2.2.01.01.04 1.06 Site Lease and Easement Expenses 0.4 0.8 (0.4)

49 NON-LBR U LT WD4-1.2.2.01.01.05 1.07 NRC Spent Fuel Fees 2.0 0.4 1.6

50 NON-LBR U LT WD4-1.2.2.01.01.06 1.08 Materials and Services 2.7 6.6 (3.9)

51 NON-LBR U LT WD4-1.2.2.01.01.07 1.09 DAW Disposal 0.2 0.4 (0.2)

52 NON-LBR U LT WD4-1.2.2.01.01.08 1.10 Energy 5.3 2.0 3.3

53 NON-LBR U LT WD4-1.2.2.01.01.10 1.14 Insurance - Workers Compensation 0.2 0.2 -

54 NON-LBR U LT WD4-1.2.2.01.01.11 1.15 Community Engagement Panel 2.9 1.0 1.9

55 NON-LBR U LT WD4-1.2.2.01.01.12 1.16 Property Tax 2.0 - 2.0

56 NON-LBR U LT WD4-1.2.2.01.01.13 1.17 Association Fees and Expenses 2.0 0.5 1.5

57 NON-LBR U LT WD4-1.2.2.01.01.14 1.18 Utilities (Water, gas, phone) 0.6 0.1 0.5

58 NON-LBR U LT WD4-1.2.2.01.01.16 1.20 Non-Process Computers 0.1 (0.1) 0.2

59 NON-LBR U LT WD4-1.2.2.01.01.17 1.21 Telecommunications 0.1 - 0.1

60 NON-LBR U LT WD4-1.2.2.01.01.20 1.24 Environmental Permits and Fees 2.5 1.1 1.4

61 NON-LBR Total $ 26.3 $ 14.6 $ 11.7

62

63 Undistributed Subtotal $ 76.7 $ 75.5 $ 1.2

64

65 License Termination Total $ 158.8 $ 112.0 $ 46.8

66

67

68 ISFSI D SFM WD2-2.1.2.02.01 8.10 Purchase and Fabrication of Spent Fuel Canisters - Unit 2 4.7 9.4 (4.7)

69 ISFSI D SFM WD3-2.1.2.02.01 8.11 Purchase and Fabrication of Spent Fuel Canisters - Unit 3 4.8 9.4 (4.6)

70 ISFSI D SFM WD4-2.1.1.01.02.02 8.07 ISFSI Pad Study 0.1 - 0.1

71 ISFSI D SFM WD4-2.1.1.01.02.03 8.08 Design ISFSI Expansion 3.9 - 3.9

72 ISFSI Total 13.5$ 18.8$ (5.3)$

73

74 REG Comp D SFM WD2-2.1.1.02.11 7.03 Post Fukushima Modifications - U2 - - -

75 REG Comp D SFM WD4-2.1.1.01.01.01 8.02 Decay Heat Analysis 0.1 0.2 (0.1) 2 Of 4

A-2

Attachment A







DCE

No. Description

2014

Decommissioning

Cost Estimate

2014

Actual/Forecast

Forecasted 2014

Variance

76 REG Comp D SFM WD4-2.1.1.01.01.02 8.03 Zirconium Fire/ Shine Analysis 0.1 0.1 -

77 REG Comp D SFM WD4-2.1.1.03.01.01 8.05 Prepare Irradiated Fuel Management Plan & NRC Review 0.1 - 0.1

78 REG Comp Total $ 0.3 $ 0.3 $ -

79

80 Security D SFM WD4-2.1.1.02.01.02 7.05 Cyber Security Mods - 0.5 (0.5)

81 Security D SFM WD4-2.1.1.02.01.03 8.01 Security Shutdown Strategy (2014 Actuals) 3.6 5.5 (1.9)

82 Security Total 3.6$ 6.0$ (2.4)$

83

84 Distributed Subtotal $ 17.4 $ 25.1 $ (7.7)

85

86 LABOR U SFM WD4-2.2.1.01.01 2.01 Labor Spent Fuel Management Reporting 20.9 24.7 (3.8)

87 LABOR U SFM WD4-2.2.1.01.01.10 2.04 Security Guard Force 25.9 27.9 (2.0)

88 LABOR U SFM WD4-2.2.2.01.01.09 2.15 Craft Worker Training (moved to DIA/DDT Labor) 0.5 - 0.5

89 LABOR Total $ 47.3 $ 52.6 $ (5.3)

90

91 NON-LBR U SFM WD4-2.2.2.01.01.01 2.02 Utility Staff Health Physics Supplies 1.5 0.1 1.4

92 NON-LBR U SFM WD4-2.2.2.01.01.02 2.05 Security Related Expenses 0.3 0.6 (0.3)

93 NON-LBR U SFM WD4-2.2.2.01.01.03 2.06 Insurance 1.0 0.4 0.6

94 NON-LBR U SFM WD4-2.2.2.01.01.05 2.08 NRC Spent Fuel Fees 0.3 - 0.3

95 NON-LBR U SFM WD4-2.2.2.01.01.06 2.11 Materials and Services 1.3 3.3 (2.0)

96 NON-LBR U SFM WD4-2.2.2.01.01.07 2.12 DAW Disposal 0.1 0.1 -

97 NON-LBR U SFM WD4-2.2.2.01.01.08 2.13 Energy 0.9 0.3 0.6

98 NON-LBR U SFM WD4-2.2.2.01.01.14 2.18 Utilities (Water, gas, phone) 0.8 0.2 0.6

99 NON-LBR U SFM WD4-2.2.2.01.01.18 2.22 Personal Computers - - -

100 NON-LBR U SFM WD4-2.2.2.01.01.23 2.09 Emergency Preparedness Fees 4.3 3.4 0.9

101 NON-LBR U SFM WD4-2.2.2.01.01.24 2.10 Spent Fuel Maintenance 0.5 - 0.5

102 NON-LBR Total $ 11.0 $ 8.4 $ 2.6

103

104 Undistributed Subtotal $ 58.3 $ 61.0 $ (2.7)

105

106 SFM Total $ 75.7 $ 86.1 $ (10.4)

107

108

109 H S A - Mesa D SR WD4-3.1.1.01.21 14.01 Mesa Site Phase I and II Site Assessment 0.1 - 0.1

110 H S A - Mesa D SR WD4-3.1.1.01.22 14.03 Mesa Site Characterization Survey 0.5 1.4 (0.9)

111 H S A - Mesa Total $ 0.6 $ 1.4 $ (0.8)

112

113 MESA D SR WD4-3.1.1.03.01.01 14.02 Disposition Hazardous Waste from Mesa Site 0.3 0.5 (0.2) 3 Of 4

A-3

Attachment A







DCE

No. Description

2014

Decommissioning

Cost Estimate

2014

Actual/Forecast

Forecasted 2014

Variance

114 MESA D SR WD4-3.1.1.04.01 15.09 Demolish Mesa Buildings - 2.8 (2.8)

115 MESA Total $ 0.3 $ 3.3 $ (3.0)

116

117 REG Comp D SR WD4-3.4.1.01.01 14.04 Fuel Contract Termination 17.7 5.1 12.6

118 REG Comp Total $ 17.7 $ 5.1 $ 12.6

119

120 Distributed Subtotal $ 18.6 $ 9.8 $ 8.8

121

122 NON-LBR U SR WD4-3.2.2.01.01.04 3.05 Site Lease and Easement Expenses 0.5 1.3 (0.8)

123 NON-LBR U SR WD4-3.2.2.01.01.30 3.11 Severance & Results Sharing 12.0 12.1 (0.1)

124 NON-LBR Total $ 12.5 $ 13.4 $ (0.9)

125

126 Distributed Subtotal 12.5$ 13.4$ (0.9)$

127

128 SR Total 31.1$ 23.2$ 7.9$

129

130 Grand Total 265.6$ 221.3$ 44.3$

Notes:

(1) 2014 amounts are based in part on forecasted costs and are subject to change.

4 Of 4A-4

Attachment B

ATTACHMENT B



DCE Annual Cash Flows By Period

(2014 Dollars In Thousands, 100% Level)

Period No. Period Description Start End 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026

License Termination

Decon Pd 1 Transition to Decommissioning 6/7/2013 12/31/2013 52,315$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$

Decon Pd 2 Decommissioning Planning and Site

Modifications

1/1/2014 6/30/2015 - 158,762 82,378 - - - - - - - - - - -

Decon Pd 3 Decommissioning Preparations and

Reactor Internals Segmentation

6/30/2015 6/1/2019 - - 60,914 115,992 152,534 133,868 75,700 - - - - - - -

Decon Pd 4 Plant Systems and Large Component

Removal

6/1/2019 9/24/2022 - - - - - - 129,149 306,354 273,172 95,830 - - - -

Decon Pd 5 Building Decontamination 9/24/2022 7/13/2024 - - - - - - - - - 94,268 272,787 62,051 - -

Decon Pd 6 License Termination During Demolition 7/13/2024 12/24/2032 - - - - - - - - - - - 2,753 5,844 5,844

LT Total 52,315$ 158,762$ 143,292$ 115,992$ 152,534$ 133,868$ 204,849$ 306,354$ 273,172$ 190,098$ 272,787$ 64,804$ 5,844$ 5,844$

Spent Fuel Management

SNF Pd 1 Spent Fuel Management Transition 6/7/2013 12/31/2013 129,997$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$

SNF Pd 2 Spent Fuel Transfer to Dry Storage 1/1/2014 6/1/2019 - 75,875 218,332 123,713 123,713 123,713 51,477 - - - - - - -

SNF Pd 3 Dry Storage During Decommissioning -

Units 1, 2 and 3

6/1/2019 12/5/2031 - - - - - - 5,751 9,817 9,817 9,817 9,817 9,817 9,817 9,817

SNF Pd 4 Dry Storage Only - Units 1, 2 and 3 12/5/2031 12/31/2035 - - - - - - - - - - - - - -

SNF Pd 5 Dry Storage Only - Units 2 and 3 12/31/2035 12/31/2049 - - - - - - - - - - - - - -

SNF D&D Pd 1 ISFSI License Termination 12/31/2049 5/6/2050 - - - - - - - - - - - - - -

SNF D&D Pd 2 ISFSI Demolition 5/6/2050 9/8/2051 - - - - - - - - - - - - - -

SNF Total 129,997$ 75,875$ 218,332$ 123,713$ 123,713$ 123,713$ 57,229$ 9,817$ 9,817$ 9,817$ 9,817$ 9,817$ 9,817$ 9,817$

Site Restoration

SR Pd 1 Transition to Site Restoration 6/7/2013 6/30/2015 98,134$ 31,059$ 1,297$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$

SR Pd 2 Building Demolition During

Decommissioning

6/30/2015 7/11/2017 - - 15,532 28,957 5,756 - - - - - - - - -

SR Pd 3 Subsurface Demolition Engineering and

Permitting

10/1/2019 7/13/2024 - - - - - - 27,447 2,171 611 4,394 1,547 1,742 - -

SR Pd 4 Building Demolition to 3 Feet Below

Grade

7/13/2024 10/14/2028 - - - - - - - - - - - 51,885 85,275 41,088

SR Pd 5 Subgrade Structure Removal Below - 3

Feet

10/14/2028 12/5/2031 - - - - - - - - - - - - - -

SR Pd 6 Final Site Restoration and Lease

Termination

5/6/2050 12/15/2051 - - - - - - - - - - - - - -

SR Total 98,134$ 31,059$ 16,829$ 28,957$ 5,756$ 27,447$ 2,171$ 611$ 4,394$ 1,547$ 53,627$ 85,275$ 41,088$

Grand Total 280,445$ 265,696$ 378,453$ 268,662$ 282,003$ 257,581$ 289,524$ 318,342$ 283,600$ 204,309$ 284,151$ 128,247$ 100,936$ 56,749$

Page 1 Of 3 B-1

ATTACHMENT B





Period No. Period Description Start End

License Termination

Decon Pd 1 Transition to Decommissioning 6/7/2013 12/31/2013


Modifications

1/1/2014 6/30/2015



6/30/2015 6/1/2019


Removal

6/1/2019 9/24/2022

Decon Pd 5 Building Decontamination 9/24/2022 7/13/2024

Decon Pd 6 License Termination During Demolition 7/13/2024 12/24/2032

LT Total


SNF Pd 1 Spent Fuel Management Transition 6/7/2013 12/31/2013

SNF Pd 2 Spent Fuel Transfer to Dry Storage 1/1/2014 6/1/2019


Units 1, 2 and 3

6/1/2019 12/5/2031

SNF Pd 4 Dry Storage Only - Units 1, 2 and 3 12/5/2031 12/31/2035

SNF Pd 5 Dry Storage Only - Units 2 and 3 12/31/2035 12/31/2049

SNF D&D Pd 1 ISFSI License Termination 12/31/2049 5/6/2050

SNF D&D Pd 2 ISFSI Demolition 5/6/2050 9/8/2051

SNF Total

Site Restoration

SR Pd 1 Transition to Site Restoration 6/7/2013 6/30/2015


Decommissioning

6/30/2015 7/11/2017


Permitting

10/1/2019 7/13/2024


Grade

7/13/2024 10/14/2028


Feet

10/14/2028 12/5/2031


Termination

5/6/2050 12/15/2051

SR Total

Grand Total

2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040

-$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$

- - - - - - - - - - - - - -

- - - - - - - - - - - - - -

- - - - - - - - - - - - - -

- - - - - - - - - - - - - -

5,844 5,844 5,844 5,844 4,111 4,244 - - - - - - - -

5,844$ 5,844$ 5,844$ 5,844$ 4,111$ 4,244$

-$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$

- - - - - - - - - - - - - -

9,817 9,817 9,817 9,817 9,111 - - - - - - - - -

- - - - 1,066 14,428 14,428 14,428 14,415 - - - - -

- - - - - - - - 42 15,330 15,330 15,330 15,330 15,330

- - - - - - - - - - - - - -

- - - - - - - - - - - - - -

9,817$ 9,817$ 9,817$ 9,817$ 10,177$ 14,428$ 14,428$ 14,428$ 14,457$ 15,330$ 15,330$ 15,330$ 15,330$ 15,330$

-$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$

- - - - - - - - - - - - - -

- - - - - - - - - - - - - -

48,317 32,501 - - - - - - - - - - - -

- 20,132 184,194 188,539 48,682 - - - - - - - - -

- - - - - - - - - - - - - -

48,317$ 52,633$ 184,194$ 188,539$ 48,682$

63,978$ 68,294$ 199,854$ 204,200$ 62,970$ 18,672$ 14,428$ 14,428$ 14,457$ 15,330$ 15,330$ 15,330$ 15,330$ 15,330$

Page 2 Of 3 B-2

ATTACHMENT B





Period No. Period Description Start End

License Termination

Decon Pd 1 Transition to Decommissioning 6/7/2013 12/31/2013


Modifications

1/1/2014 6/30/2015



6/30/2015 6/1/2019


Removal

6/1/2019 9/24/2022

Decon Pd 5 Building Decontamination 9/24/2022 7/13/2024

Decon Pd 6 License Termination During Demolition 7/13/2024 12/24/2032

LT Total


SNF Pd 1 Spent Fuel Management Transition 6/7/2013 12/31/2013

SNF Pd 2 Spent Fuel Transfer to Dry Storage 1/1/2014 6/1/2019


Units 1, 2 and 3

6/1/2019 12/5/2031

SNF Pd 4 Dry Storage Only - Units 1, 2 and 3 12/5/2031 12/31/2035

SNF Pd 5 Dry Storage Only - Units 2 and 3 12/31/2035 12/31/2049

SNF D&D Pd 1 ISFSI License Termination 12/31/2049 5/6/2050

SNF D&D Pd 2 ISFSI Demolition 5/6/2050 9/8/2051

SNF Total

Site Restoration

SR Pd 1 Transition to Site Restoration 6/7/2013 6/30/2015


Decommissioning

6/30/2015 7/11/2017


Permitting

10/1/2019 7/13/2024


Grade

7/13/2024 10/14/2028


Feet

10/14/2028 12/5/2031


Termination

5/6/2050 12/15/2051

SR Total

Grand Total

2041 2042 2043 2044 2045 2046 2047 2048 2049 2050 2051 2052 Grand Total

-$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 52,315$

- - - - - - - - - - - - 241,140

- - - - - - - - - - - - 539,009

- - - - - - - - - - - - 804,504

- - - - - - - - - - - - 429,106

- - - - - - - - - - - - 46,171

2,112,246$

-$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 129,997$

- - - - - - - - - - - - 716,822

- - - - - - - - - - - - 122,849

- - - - - - - - - - - - 58,765

15,330 15,330 15,330 15,330 15,330 15,330 15,330 15,330 15,317 - - - 214,653

- - - - - - - - 17 2,503 - - 2,520

- - - - - - - - - 17,445 13,145 - 30,590

15,330$ 15,330$ 15,330$ 15,330$ 15,330$ 15,330$ 15,330$ 15,330$ 15,334$ 19,948$ 13,145$ 1,276,196$

-$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 130,489$

- - - - - - - - - - - - 50,245

- - - - - - - - - - - - 37,912

- - - - - - - - - - - - 259,066

- - - - - - - - - - - - 441,547

- - - - - - - - - 43,297 57,494 2,755 103,545

43,297$ 57,494$ 2,755$ 1,022,804$

15,330$ 15,330$ 15,330$ 15,330$ 15,330$ 15,330$ 15,330$ 15,330$ 15,334$ 63,245$ 70,639$ 2,755$ 4,411,246$

Page 3 Of 3 B-3

testimony and preliminary report of southern california edison … · regarding 2014 expenses for...

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