HBL-19-007, Decommissioning Funding Report

Decommissioning Funding Report

ML19087A094
Person / Time
Site:	Humboldt Bay
Issue date:	03/28/2019
From:	Welsch J Pacific Gas & Electric Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
HBL-19-007
Download: ML19087A094 (54)

Text

Pacific Gas and Electric Company" March 28, 2019 PG&E Letter HBL-19-007 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-133, DPR-7 Humboldt Bay Power Plant, Unit 3 James M. Welsch Vice President Nuclear Generation and Chief Nuclear Officer Oiablo Canyon Power Plant P.O. Box 56 Avila Beach, CA 93424 805.545.3242 E-Mail: James.Welsch@pge.com 10 CFR 50.75(f) 10 CFR 50.82(a)(8)(v) 10 CFR 50.82(a)(8)(vii)

Decommissioning Funding Report for Humboldt Bay Power Plant, Unit 3

Dear Commissioners and Staff:

Pacific Gas and Electric Company (PG&E) is submitting the decommissioning funding report for Humboldt Bay Power Plant (HBPP), Unit 3, pursuant to the requirements of 10 CFR 50. 75(f), 10 CFR 50.82(a)(8)(v), and 10 CFR 50.82(a)(8)(vii).

Humboldt Bay Unit 3 PG&E has spent $787.6 million on NRC radiological decommissioning activities through December 2018. At the end of calendar year 2018, the market value of the HBPP Unit 3 (220 MWt) decommissioning trust fund was $138.2 million. PG&E estimates that $24.2 million will be needed to complete the NRC radiological scope.

PG&E estimates it will need to collect an additional $73. 7 million over four years, beginning in 2019, based on a site-specific decommissioning cost estimate prepared by PG&E staff and submitted to the California Public Utilities Commission's (CPUC)

Nuclear Decommissioning Cost Triennial Proceeding (NDCTP) on December 13, 2018 for radiological decommissioning, site restoration, and spent fuel management.

The cost estimate in the 2018 NDCTP application is based on actual bids for remaining HBPP civil work scope and includes final site restoration, final site surveys, and spent fuel management costs associated with the delay in the Department of Energy's acceptance of site-stored spent fuel, cost to remediate site radioactivity to resident farmer criteria, and updated remaining decommissioning costs based on actual past HBPP decommissioning data versus industry estimates.

The NRC minimum decommissioning estimate is $464.4 million (2019 dollars) that was calculated pursuant to the requirements specified in 10 CFR 50.75(c), which is based on a minimum 1200 MWt plant that has not started decommissioning activities. HBPP is approximately 97 percent complete with the radiological decommissioning scope of work and has withdrawn funds through 2018 from the

Document Control Desk March 28, 2019 Page 2 PG&E Letter HBL-19-007 HBPP trust resulting in a current market value lower than the NRC minimum estimate.

The HBPP trust has sufficient funds to complete radiological decommissioning.

PG&E is confident that the HBPP trust, with the noted additional contributions, will be sufficient to maintain the spent fuel in an independent spent fuel storage installation (ISFSI) at HBPP until 2033, and fund Non-NRC site restoration activities, based on the December 2018 site-specific decommissioning cost estimate prepared by PG&E staff.

Supporting Cost Estimates Based on a December 2018 site-specific cost estimate prepared by PG&E staff, PG&E estimates that the total HBPP decommissioning costs are approximately

$1,133.3 million (including $787.6 million disbursed from the Trust(s) through December 2018 and $24.2 million future radiological decommissioning costs) for HBPP, Unit 3, in 2019 dollars. These NRC decommissioning costs do not include Non-NRC site restoration ($78.6 million) or spent fuel management until 2033

($242.9 million). To assure that sufficient funds will be available for decommissioning, PG&E established external sinking trust fund accounts for HBPP, Unit 3.

Supporting Enclosures provides decommissioning funding status information in a format suggested by Nuclear Energy Institute (NEI) and the NRC. provides information on the escalation of the required decommissioning funding amounts to 2019 dollars. As required by 10 CFR 50.75(c)(2), and using NUREG-1577, "Standard Review Plan on Power Reactor Licensee Financial Qualifications and Decommissioning Funding Assurance," Revision 1 and NUREG-1307, "Report on Waste Burial Charges," Revision 17, the information includes escalation factors for energy, labor, and waste burial costs. is a cash flow of the total decommissioning of HBPP that identifies the monies for NRC scope (removal of radiological contamination), site restoration (including the non-radiological work), and the spent fuel management. contains the variance of the 2018 forecast of $93.8 million, as submitted in Enclosure 3 of PG&E Letter HBL-18-004, "Decommissioning Funding Report for Humboldt Bay Power Plant, Unit 3," dated March 27, 2018, to the actual expenditures for 2018 of $73.6 million.

\\

Document Control Desk March 28, 2019 Page 3 PG&E Letter HBL-19-007 contains the 2018 Humboldt Bay Power Plant Unit 3 Decommissioning Project Report (DPR) prepared for the 2018 NDCTP filing submitted to the CPUC December 13, 2018. The DPR provides cost estimates for the remaining decommissioning of the nuclear, non-nuclear facilities, and spent fuel management, including operation of the ISFSI in 2018 dollars.

PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this letter.

Should you have any questions, please contact Mr. Philippe Soenen at (805) 459-3701.

Sincerely, J~W~c~~

Vice President Nuclear Generation and Chief Nuclear Officer Enclosures cc:

HBPP Humboldt Distribution cc/enc:

John B. Hickman, NRC Project Manager Scott A. Morris, NRC Region IV Administrator INPO PG&E Letter HBL-19-007 NRC Decommissioning Funding Status Report Humboldt Bay Power Plant - Unit 3 (220 MWt)

PG&E Letter HBL-19-007 NRC Decommissioning Funding Status Report Humboldt Bay Power Plant - Unit 3 (220 MWt)

As provided in 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning March 31, 1999, and annually thereafter, on the status of its decommissioning funding for each reactor that it owns and has already closed.

Note that Items 3, 4, and 8 are data included in PG&E's Nuclear Decommissioning Cost Triennial Proceeding (NDCTP) filed with the California Public Utilities Commission (CPUC) December 13, 2018 which includes radiological decommissioning, site restoration and spent fuel management costs. PG&E does not anticipate a decision on this filing until early 2020.

1. The minimum decommissioning fund estimate, pursuant to 10 CFR 50.75(b) and (c). 1 January 2019 dollars

$ in Millions

$ 464.4 Humboldt Bay Power Plant (HBPP) is a shutdown unit with a Site Specific Cost Study; therefore, the minimum decommissioning fund estimate is based on the Site Specific Cost Study shown in Item 8 of this enclosure.)

2. The amount accumulated at the end of the calendar year preceding the date of the report for items included in 10 CFR 50.75(b) and (c). (Alternatively, the total amount accumulated at the end of the calendar year preceding the date of the report can be reported here if the cover letter transmitting the report provides the total estimate and indicates what portion of that estimate is for items not included in 10 CFR 50.75(b) and (c)).

Market Value (December 2018 dollars)

$ in Millions

$ 138.2

3. A schedule of the annual amounts remaining to be collected; for items in 10 CFR 50.75(b) and (c). (Alternatively, the annual amounts remaining to be collected can include items beyond those required in 10 CFR 50.75(b) and (c) if the cover letter transmitting the report provides a total cost estimate and indicates what portion of that estimate is for items that are not included in 10 CFR 50. 75(b) and (c).

1

• The NRC formulas in section 10 CFR 50. 75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service and reduce residual radioactivity to levels that permit: (1) release of the property for unrestricted use and termination of the license; or (2) release of the property under restricted conditions and termination of the license. The cost of dismantling or demolishing nonradiological systems and structures is not included in the NRC decommissioning cost estimates. The costs of managing and storing spent fuel on site until transfers to Department of Energy are not included in the cost formulas.

Page 1 of 2 PG&E Letter HBL-19-007 Amount remaining Number of years to collect 2019-2022 2019 Annual amount to be collected 2020-2022 Annual amount to be collected

$ in Millions

$ 73.7 4 years

$ 62.360

$ 3.791

4. The assumptions used regarding escalation in decommissioning cost, rates of earnings on decommissioning funds (assumes trust will be gradually converted to a more conservative, all fixed income portfolio over time), and rates of other factors used in funding projections (all values below are from the 2018 NDCTP filing).

Escalation in decommissioning costs Rate of Return 2019 Escalation in decommissioning costs Rate of Return 2020 Escalation in decommissioning costs Rate of Return 2021 Escalation in decommissioning costs Rate of Return 2022-2023 Escalation in decommissioning costs Rate of Return 2024-2033

5. Any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(1)(v).

2.40 percent 2.42 percent 2.43 percent 2.44 percent 2.45 percent None

6. Any modifications to a licensee's current method providing financial assurance occurring since the last submitted report.

None

7. Any material changes to trust agreements.

8. CPUC Submittal in 2019 Dollars in Millions:

Total Project (Decommission 2019)

Scope Excluded from NRC calculations Spent Fuel Management from Licensing to Decommissioning in 2033 NRC Scope Decommissioned and disbursed from Trust(s)

Total NRC Decommissioning Remaining Scope Page 2 of 2 None

$ 1,133.3 78.6 242.9

~

787.6 24.2

2019 Decommissioning Estimate (1 page)

Composite Escalation (1 page)

Development of E Component (6 pages)

Development of L Component (6 pages)

Development of B Component (1 page)

PG&E Letter HBL-19-007

Nuclear Regulatory Commission Estimate of Decommissioning Costs for Boiling Water Reactor (BWR)

In 2019$

January 1986 Estimate Escalated to 1999 Escalated to 2000 Escalated to 2001 Escalated to 2002 Escalated to 2003 Escalated to 2004 Escalated to 2005 Escalated to 2006 Escalated to 2007 Escalated to 2008 Escalated to 2009 Escalated to 201 0 Escalated to 2011 Escalated to 2012 Escalated to 2013 Escalated to 2014 Escalated to 2015 Escalated to 2016 Escalated to 2017 Escalated to 2018 Escalated to 2019 HBPP BWR

($ in millions)

$114.80 (Table 2.1 in NUREG 1307 Rev 15 has 128.9 no value for 1999 Burial)

$400.2 ($360.9 in 2000 Submittal)

$354.1 ($425.3 in 2001 Submittal)

$357.4 ($445.6 in 2002 Submittal)

$373.8 ($430.1 in 2003 Submittal)

$388.0 ($439.6 in 2004 Submittal)

$416.8 ($453.2 in 2005 Submittal)

$519.2 ($494.3 in 2006 Submittal)

$538.3 ($548.6 in 2007 Submittal)

$564.4 ($590.9 in 2008 Submittal)

$574.6 ($573.8 in 2009 Submittal)

$594.5 ($596.6 in 201 0 Submittal)

$626.5 ($619.0 in 2011 Submittal)

$659.9 ($645.4 in 2012 Submittal)

$663.3 ($687.2 in 2013 Submittal)

$666.8 ($714.3 in 2014 Submittal)

$664.2 ($712.0 in 2015 Submittal)

$660.3 ($660.2 in 2016 Submittal)

$438.1 ($438.2 in 2017 Submittal)

$451.9 ($451.9 in 2018 Submittal)

$464.4 January 1986 based on 10 CFR 50.75 (c) Table of minimum amounts BWR based on minimum 1200 MWt = ($104 + (.009xMWt)) million per unit where BWR less than 1200 MWt use P=1200 MWt, HBPP 220 MWt 2019 Decommissioning Estimate Page 1 of 1 PG&E Letter HBL-19-007

Composite Escalation Calculating Overall Escalation Rate BWR Dec-05 Dec-06 Dec-07 Dec-08 Dec-09 Dec-10 Dec-1 1 Dec-12 Dec-13 Dec-14 Dec-15 Dec-16 L (Labor) 2.0600 2.1218 2.1939 2.2536 2.2784 2.3175 2.3711 2.4061 2.4638 2.5235 2.5812 2.6492 E (Energy) 1.9106 1.9808 2.4513 1.8323 2.0402 2.3945 2.7719 2.8265 2.7672 2.2944 1.7442 1.8710 B(Burial) 13.3331 13.8744 14.4164 15.0096 15.6028 16.5439 17.4856 17.4856 17.4856 17.4856 17.4856 8.4126 (1) From NU REG 1307 Revision 17, Report on Waste Burial Charges, Section 2 Summary, Page 7... where A, B, and C are the fractions of the total 1986 dollar costs that are attributable to labor (0.65), energy (0.13), and burial (0.22), respectively, and sum to 1.0.

BWR Combined Escalation Rate for:

Dec-06 Dec-07 Dec-08 Dec-09 Dec-10 Dec-11 4.6891 4.9163 5.0052 5.1788 5.4573 5.7484 Dec-12 Dec-13 Dec-14 5.7782 5.8080 5.7854 Dec-15 5.7513 Page 1 of 1 Dec-16 Dec-17 3.8159 3.9365 Dec-17 2.7377 2.3555 8.4126 Dec-18 4.0455 Dec-18 Weight (1) 2.8263 0.65 2.4363 0.13 8.5983 0.22 PG&E Letter HBL-19-007

Development of E Component Calculation of Energy Escalation Factor-Reference NUREG-1307, Revision 17, Section 3.2 Using Regional Indices SERIES ID: WPU0573 Light Fuel Oils (as of 02/14/2019) and WPU0543 Industrial Electric Power (as of 02/14/2019)

REBASED TO 1986 = 100 Dec-99 Jan-00 Feb-00 Mar-00 Apr-00 May-00 Jun-00 Jul-00 Aug-00 Sep-00 Oct-00 Nov-00 Dec-00 Jan-01 Feb-01 Mar-01 Apr-01 May-01 Jun-01 Jul-01 Aug-01 Sep-01 Oct-01 Nov-01 Dec-01 Jan-02 Feb-02 Mar-02 Apr-02 May-02 Jun-02 Jul-02 Aug-02 Sep-02 Oct-02 Nov-02 Dec-02 Jan-03 Feb-03 PPI for Fuels &

Related Products (2000 = 100)

(P) =Industrial Electric Power 126.5 126.8 126.7 126.7 126.8 128.6 133.6 136.2 137.4 137.8 134.1 130.9 132.7 136.4 136.4 136.5 135.1 136.2 148.4 149.5 148.9 148.2 143.8 137.3 136.9 136.3 135.4 135.7 135.4 137.9 143.6 144.9 145.0 145.8 140.0 139.5 139.6 140.3 140.6 PPI for Light Fuel Oils (2000=100)

(F) = Light Fuel Oils 72.9 75.3 87.9 89.7 83.1 82.9 86.2 88.7 91.6 110.1 108.6 108.4 100.6 96.1 91.6 83.1 86.2 94.2 90.2 81.3 83.2 93 76.8 70.5 56.6 58.3 59.6 69.1 76.4 75 71.4 75.5 77.9 89.5 95.1 82.8 84.6 95.7 120.4 PPI for Fuels &

PPI for Light Related Products Fuel Oils (2000 = 100)

(2000=100)

(P) =Industrial Energy Power (F) = Light Fuel Oils BWR wt. =

0.54 BWR wt.=

0.46 1.0000 1.0000 1.0024 1.0329 1.0016 1.2058 1.0016 1.2305 1.0024 1.1399 1.0166 1.1372 1.0561 1.1824 1.0767 1.2167 1.0862 1.2565 1.0893 1.5103 1.0601 1.4897 1.0348 1.4870 1.0490 1.3800 1.0783 1.3182 1.0783 1.2565 1.0791 1.1399 1.0680 1.1824 1.0767 1.2922 1.1731 1.2373 1.1818 1.1152 1.1771 1.1413 1.1715 1.2757 1.1368 1.0535 1.0854 0.9671 1.0822 0.7764 1.0775 0.7997 1.0704 0.8176 1.0727 0.9479 1.0704 1.0480 1.0901 1.0288 1.1352 0.9794 1.1455 1.0357 1.1462 1.0686 1.1526 1.2277 1.1067 1.3045 1.1028 1.1358 1.1036 1.1605 1.1091 1.3128 1.1115 1.6516 Page 1 of 6 PG&E Letter HBL-19-007 Energy Escalation Factor (E) forBWR (Humboldt) 1.0000 1.0164 1.0955 1.1069 1.0656 1.0721 1.1142 1.1411 1.1645 1.2830 1.2577 1.2428 1.2013 1.1887 1.1603 1.1070 1.1206 1.1758 1.2026 1.1512 1.1606 1.2195 1.0985 1.0310 0.9415 0.9497 0.9541 1.0153 1.0601 1.0619 1.0635 1.0950 1.1105 1.1871 1.1977 1.1180 1.1297 1.2028 1.3599

Development of E Component Calculation of Energy Escalation Factor-Reference NUREG-1307, Revision 17, Section 3.2 Using Regional Indices SERIES ID: WPU0573 Light Fuel Oils (as of 02/14/2019) and WPU0543 Industrial Electric Power (as of 02/14/2019)

REBASED TO 1986 = 100 PPI for Fuels &

PPI for Light PPI for Fuels &

PPI for Light Related Products Fuel Oils Related Products Fuel Oils (2000 = 100)

(2000=100)

(2000 = 100)

(2000=100)

(P) =Industrial Electric Power (F) = Light Fuel Oils (P) =Industrial Energy Power (F) = Light Fuel Oils BWR wt.=

0.54 BWR wt.=

0.46 Mar-03 143.3 128.9 1.1328 1.7682 Apr-03 144.3 98.3 1.1407 1.3484 May-03 145.1 85.5 1.1470 1.1728 Jun-03 148.3 87.2 1.1723 1.1962 Jul-03 151.6 90.1 1.1984 1.2359 Aug-03 151.3 94.1 1.1960 1.2908 Sep-03 152.0 88.2 1.2016 1.2099 Oct-03 147.4 97.8 1.1652 1.3416 Nov-03 142.7 93.0 1.1281 1.2757 Dec-03 142.9 95.8 1.1296 1.3141 Jan-04 143.1 106.8 1.1312 1.4650 Feb-04 143.1 100.8 1.1312 1.3827 Mar-04 143.1 107.8 1.1312 1.4787 Apr-04 143.1 115.2 1.1312 1.5802 May-04 144.2 116 1.1399 1.5912 Jun-04 152.4 111.5 1.2047 1.5295 Jul-04 152.2 119.3 1.2032 1.6365 Aug-04 154.0 131.1 1.2174 1.7984 Sep-04 154.0 136.8 1.2174 1.8765 Oct-04 145.8 161.7 1.1526 2.2181 Nov-04 144.9 153.6 1.1455 2.1070 Dec-04 146.2 133.8 1.1557 1.8354 Jan-05 148.9 138.5 1.1771 1.8999 Feb-05 148.0 146 1.1700 2.0027 Mar-05 148.1 169.4 1.1708 2.3237 Apr-05 148.7 170.9 1.1755 2.3443 May-05 151.1 165.3 1.1945 2.2675 Jun-05 159.7 180.6 1.2625 2.4774 Jul-05 162.1 186.2 1.2814 2.5542 Aug-05 162.5 194.5 1.2846 2.6680 Sep-05 162.8 209.9 1.2870 2.8793 Oct-05 159.5 252.0 1.2609 3.4568 Nov-05 161.1 199.1 1.2735 2.7311 Dec-05 161.4 193.6 1.2759 2.6557 Jan-06 167.0 191.8 1.3202 2.6310 Feb-06 168.6 190.0 1.3328 2.6063 Mar-06 167.4 199.2 1.3233 2.7325 Apr-06 169.6 221.9 1.3407 3.0439 May-06 170.8 231.4 1.3502 3.1742 Jun-06 181.2 238.1 1.4324 3.2661 Page 2 of 6 PG&E Letter HBL-19-007 Energy Escalation Factor (E) for BWR (Humboldt) 1.4251 1.2363 1.1589 1.1833 1.2157 1.2396 1.2054 1.2463 1.1960 1.2145 1.2848 1.2469 1.2911 1.3378 1.3475 1.3541 1.4025 1.4846 1.5206 1.6427 1.5878 1.4684 1.5096 1.5530 1.7011 1.7131 1.6881 1.8213 1.8669 1.9210 2.0194 2.2710 1.9440 1.9106 1.9231 1.9186 1.9715 2.1242 2.1892 2.2759

Development of E Component Calculation of Energy Escalation Factor-Reference NUREG-1307, Revision 17, Section 3.2 Using Regional Indices SERIES ID: WPU0573 Light Fuel Oils (as of 02/14/2019) and WPU0543 Industrial Electric Power (as of 02/14/2019)

REBASED TO 1986 = 100 PPI for Fuels &

PPI for Light PPI for Fuels &

PPI for Light Related Products Fuel Oils Related Products Fuel Oils (2000 = 100)

(2000=100)

(2000 = 100)

(2000=100)

(P) =Industrial Electric Power (F) = Light Fuel Oils (P) =Industrial Energy Power (F) = Light Fuel Oils BWRwt. =

0.54 BWRwt. =

0.46 Jul-06 181.9 231.6 1.4379 3.1770 Aug-06 180.2 241.4 1.4245 3.3114 Sep-06 181.0 203.1 1.4308 2.7860 Oct-06 171.2 198.1 1.3534 2.7174 Nov-06 167.2 198.2 1.3217 2.7188 Dec-06 167.8 200.4 1.3265 2.7490 Jan-07 171.9 180.0 1.3589 2.4691 Feb-07 175.7 191.5 1.3889 2.6269 Mar-07 172.1 215.1 1.3605 2.9506 Apr-07 173.1 231.8 1.3684 3.1797 May-07 179.2 225.3 1.4166 3.0905 Jun-07 186.7 222.4 1.4759 3.0508 Jul-07 187.0 237.8 1.4783 3.2620 Aug-07 187.6 225.5 1.4830 3.0933 Sep-07 188.4 238.9 1.4893 3.2771 Oct-07 182.7 243.3 1.4443 3.3374 Nov-07 180.3 288.2 1.4253 3.9534 Dec-07 180.0 266.7 1.4229 3.6584 Jan-08 181.9 273.8 1.4379 3.7558 Feb-08 180.0 280.2 1.4229 3.8436 Mar-08 183.1 339.6 1.4474 4.6584 Apr-08 185.2 352.5 1.4640 4.8354 May-08 189.5 384.9 1.4980 5.2798 Jun-08 191.9 410.5 1.5170 5.6310 Jul-08 196.1 423.8 1.5502 5.8134 Aug-08 197.1 343.9 1.5581 4.7174 Sep-08 195.9 335.1 1.5486 4.5967 Oct-08 193.0 279.0 1.5257 3.8272 Nov-08 187.7 218.2 1.4838 2.9931 Dec-08 188.3 163.0 1.4885 2.2359 Jan-09 190.3 159.8 1.5043 2.1920 Feb-09 190.3 145.6 1.5043 1.9973 Mar-09 187.6 136.8 1.4830 1.8765 Apr-09 186.9 159.9 1.4775 2.1934 May-09 190.5 158.6 1.5059 2.1756 Jun-09 193.3 183.7 1.5281 2.5199 Jul-09 196.2 165.2 1.5510 2.2661 Aug-09 194.7 196.1 1.5391 2.6900 Sep-09 194.9 186.6 1.5407 2.5597 Oct-09 189.9 193.3 1.5012 2.6516 Page 3 of 6 PG&E Letter HBL-19-007 Energy Escalation Factor (E) for BWR (Humboldt) 2.2379 2.2925 2.0542 1.9808 1.9644 1.9808 1.8696 1.9584 2.0919 2.2016 2.1866 2.2003 2.2988 2.2237 2.3117 2.3151 2.5882 2.4513 2.5042 2.5364 2.9245 3.0149 3.2377 3.4094 3.5113 3.0114 2.9507 2.5844 2.1781 1.8323 1.8207 1.7311 1.6640 1.8068 1.8140 1.9843 1.8799 2.0685 2.0094 2.0304

Development of E Component Calculation of Energy Escalation Factor-Reference NUREG-1307, Revision 17, Section 3.2 Using Regional Indices SERIES ID: WPU0573 Light Fuel Oils (as of 02/14/2019) and WPU0543 Industrial Electric Power (as of 02/14/2019)

REBASED TO 1986 = 100 PPI for Fuels &

PPI for Light PPI for Fuels &

PPI for Light Related Products Fuel Oils Related Products Fuel Oils (2000 = 100)

(2000=100)

(2000 = 100)

(2000=100)

(P) =Industrial Electric Power (F) = Light Fuel Oils (P) =Industrial Energy Power (F) = Light Fuel Oils BWR wt. =

0.54 BWRwt. =

0.46 Nov-09 186.0 207.8 1.4704 2.8505 Dec-09 186.0 197.5 1.4704 2.7092 Jan-10 186.3 220.7 1.4727 3.0274 Feb-10 186.1 200.2 1.4711 2.7462 Mar-10 189.0 217.0 1.4941 2.9767 Apr-10 188.8 231.5 1.4925 3.1756 May-10 192.0 226.0 1.5178 3.1001 Jun-10 197.8 212.4 1.5636 2.9136 Jul-10 199.8 209.3 1.5794 2.8711 Aug-10 200.8 221.4 1.5874 3.0370 Sep-10 200.0 220.0 1.5810 3.0178 Oct-10 194.6 235.8 1.5383 3.2346 Nov-10 190.9 245.3 1.5091 3.3649 Dec-10 191.4 250.0 1.5130 3.4294 Jan-11 193.1 260.4 1.5265 3.5720 Feb-11 194.4 278.8 1.5368 3.8244 Mar-11 195.0 307.5 1.5415 4.2181 Apr-11 194.1 325.1 1.5344 4.4595 May-11 196.9 315.1 1.5565 4.3224 Jun-11 205.7 316.9 1.6261 4.3471 Jul-11 215.3 311.5 1.7020 4.2730 Aug-11 216.6 296.9 1.7123 4.0727 Sep-11 215.8 306.5 1.7059 4.2044 Oct-11 206.6 299.6 1.6332 4.1097 Nov-11 204.0 322.7 1.6126 4.4266 Dec-11 204.4 301.0 1.6158 4.1289 Jan-12 201.1 308.8 1.5897 4.2359 Feb-12 200.3 316.5 1.5834 4.3416 Mar-12 199.8 330.8 1.5794

• 4.5377 Apr-12 198.1 327.1 1.5660 4.4870 May-12 201.5 315.6 1.5929 4.3292 Jun-12 207.7 284.6 1.6419 3.9040 Jul-12 221.5 287.9 1.7510 3.9492 Aug-12 222.1 313.4 1.7557 4.2990 Sep-12 222.8 330.4 1.7613 4.5322 Oct-12 214.1 334.1 1.6925 4.5830 Nov-12 212.3 311.6 1.6783 4.2743 Dec-12 213.8 303.3 1.6901 4.1605 Jan-13 199.2 303.6 1.5747 4.1646 Feb-13 199.4 327.7 1.5763 4.4952 Page 4 of 6 PG&E Letter HBL-19-007 Energy Escalation Factor (E) for BWR (Humboldt) 2.1052 2.0402 2.1879 2.0577 2.1761 2.2667 2.2457 2.1846 2.1736 2.2542 2.2420 2.3186 2.3628 2.3945 2.4674 2.5891 2.7727 2.8800 2.8288 2.8777 2.8846 2.7981 2.8552 2.7724 2.9071 2.7719 2.8070 2.8522 2.9403 2.9096 2.8516 2.6825 2.7622 2.9257 3.0359 3.0221 2.8725 2.8265 2.7661 2.9190

Development of E Component Calculation of Energy Escalation Factor - Reference NUREG-1307, Revision 17, Section 3.2 Using Regional Indices SERIES ID: WPU0573 Light Fuel Oils (as of 02/14/2019) and WPU0543 Industrial Electric Power (as of 02/14/2019)

RE BASED TO 1986 = 100 PPI for Fuels &

PPI for Light PPI for Fuels &

PPI for Light Related Products Fuel Oils Related Products Fuel Oils (2000 = 100)

(2000=100)

(2000 = 100)

(2000=100)

(P) =Industrial Electric Power (F) = Light Fuel Oils (P) =Industrial Energy Power (F) = Light Fuel Oils BWR wt.=

0.54 BWRwt. =

0.46 Mar-13 199.0 308.7 1.5731 4.2346 Apr-13 198.8 303.9 1.5715 4.1687 May-13 203.5 296.4 1.6087 4.0658 Jun-13 211.9 294.9 1.6751 4.0453 Jul-13 211.4 300.4 1.6711 4.1207 Aug-13 210.4 307.4 1.6632 4.2167 Sep-13 210.3 315.3 1.6625 4.3251 Oct-13 201.2 306.8 1.5905 4.2085 Nov-13 199.0 295.3 1.5731 4.0508 Dec-13 200.5 302.9 1.5850 4.1550 Jan-14 215.1 297.5 1.7004 4.0809 Feb-14 214.4 309.1 1.6949 4.2401 Mar-14 214.8 306.5 1.6980 4.2044 Apr-14 210.8 306.7 1.6664 4.2071 May-14 215.2 304.4 1.7012 4.1756 Jun-14 224.0 296.5 1.7708 4.0672 Jul-14 227.5 295.3 1.7984 4.0508 Aug-14 227.7 293.9 1.8000 4.0316 Sep-14 225.1 291.0 1.7794 3.9918 Oct-14 217.0 271.4 1.7154 3.7229 Nov-14 210.7 260.9 1.6656 3.5789 Dec-14 213.9 218.9 1.6909 3.0027 Jan-15 222.4 173.6 1.7581 2.3813 Feb-15 221.1 184.3 1.7478 2.5281 Mar-15 218.2 185.7 1.7249 2.5473 Apr-15 213.3 178.2 1.6862 2.4444 May-15 217.0 196.6 1.7154 2.6968 Jun-15 237.2 193.4 1.8751 2.6529 Jul-15 237.3 187.0 1.8759 2.5652 Aug-15 236.8 180.4 1.8719 2.4746 Sep-15 234.2 163.1 1.8514 2.2373 Oct-15 218.2 165.3 1.7249 2.2675 Nov-15 213.4 159.7 1.6870 2.1907 Dec-15 214.8 131.1 1.6980 1.7984 Jan-16 205.3 114.4 1.6229 1.5693 Feb-16 204.3 107.7 1.6150 1.4774 Mar-16 204.5 113.8 1.6166 1.5610 Apr-16 202.4 116.8 1.6000 1.6022 May-16 206.3 137.8 1.6308 1.8903 Jun-16 220.4 149.4 1.7423 2.0494 Page 5 of 6 PG&E Letter HBL-19-007 Energy Escalation Factor (E) for BWR (Humboldt) 2.7974 2.7662 2.7390 2.7654 2.7979 2.8378 2.8873 2.7948 2.7128 2.7672 2.7954 2.8657 2.8510 2.8351 2.8394 2.8271 2.8345 2.8265 2.7971 2.6389 2.5457 2.2944 2.0448 2.1068 2.1032 2.0350 2.1669 2.2329 2.1930 2.1492 2.0289 1.9745 1.9187 1.7442 1.5982 1.5517 1.5910 1.6010 1.7502 1.8836

Development of E Component Calculation of Energy Escalation Factor-Reference NUREG-1307, Revision 17, Section 3.2 Using Regional Indices SERIES ID: WPU0573 Light Fuel Oils (as of 02/14/2019) and WPU0543 Industrial Electric Power (as of 02/14/2019)

RE BASED TO 1986 = 100 PPI for Fuels &

PPI for Light PPI for Fuels &

PPI for Light Related Products Fuel Oils Related Products Fuel Oils (2000 = 100)

(2000=100)

(2000 = 100)

(2000=100)

(P) =Industrial Electric Power (F) = Light Fuel Oils (P) =Industrial Energy Power (F) = Light Fuel Oils BWR wt.=

0.54 BWR wt.=

0.46 Jul-16 226.2 152.2 1.7881 2.0878 Aug-16 227.3 143.5 1.7968 1.9684 Sep-16 228.1 155.5 1.8032 2.1331 Oct-16 214.9 153.4 1.6988 2.1043 Nov-16 211.3 152.9 1.6704 2.0974 Dec-16 211.7 153.3 1.6735 2.1029 Jan-17 231.8 158.0 1.8324 2.1674 Feb-17 232.9 159.7 1.8411 2.1907 Mar-17 234.2 158.0 1.8514 2.1674 Apr-17 234.3 157.9 1.8522 2.1660 May-17 237.1 165.3 1.8743 2.2675 Jun-17 251.0 163.1 1.9842 2.2373 Jul-17 253.4 169.1 2.0032 2.3196 Aug-17 251.2 179.0 1.9858 2.4554 Sep-17 249.0 192.5 1.9684 2.6406 Oct-17 238.7 202.9 1.8870 2.7833 Nov-17 236.8 211.2 1.8719 2.8971 Dec-17 237.4 212.7 1.8767 2.9177 Jan-18 243.4 218.0 1.9241 2.9904 Feb-18 245.3 216.6 1.9391 2.9712 Mar-18 241.0 214.0 1.9051 2.9355 Apr-18 237.7 220.5 1.8791 3.0247 May-18 241.3 238.8 1.9075 3.2757 Jun-18 255.2 248.9 2.0174 3.4143 Jul-18 258.8 244.2 2.0458 3.3498 Aug-18 258.7 242.0 2.0451 3.3196 Sep-18 255.4 249.8 2.0190 3.4266 Oct-18 242.6 257.8 1.9178 3.5364 Nov-18 239.2 254.2 1.8909 3.4870 Dec-18 240.2 223.6 1.8988 3.0672 October 2018 through December 2018 are Preliminary Values from PPI Indices Based on Base Year 2000 being the indices values Dec 1999, January 2019 base will be December 2018 Page 6 of 6 PG&E Letter HBL-19-007 Energy Escalation Factor (E) for BWR (Humboldt) 1.9260 1.8758 1.9549 1.8853 1.8668 1.8710 1.9865 2.0019 1.9967 1.9965 2.0552 2.1006 2.1487 2.2018 2.2776 2.2993 2.3435 2.3555 2.4146 2.4139 2.3791 2.4060 2.5369 2.6600 2.6457 2.6314 2.6665 2.6623 2.6251 2.4363

Development of L Component Calculation of Labor Escalation Factor - Reference NUREG-1307, Revision 17, Section 3.1 Using Regional Indices SERIES ID: CIU2010000000240I (as of 02/14/2019)

Note 1: The Base Labor factor was reindexed in December 2005, at which time the index was reset to 100.

Employment Cost lndust West Region Labor Private Industry Escalation (2005=100)

Factor Dec-05 100 2.06000 Jan-06 Feb-06 Mar-06 100.6 2.07236 Apr-06 May-06 Jun-06 101.8 2.09708 Jul-06 Aug-06 Sep-06 102.5 2.11150 Oct-06 Nov-06 Dec-06 103 2.12180 Jan-07 Feb-07 Mar-07 104.2 2.14652 Apr-07 May-07 Jun-07 104.9 2.16094 Jul-07 Aug-07 Sep-07 105.7 2.17742 Oct-07 Nov-07 Dec-07 106.5 2.19390 Jan-08 Feb-08 Mar-08 107.8 2.22068 Page 1 of 6 PG&E Letter HBL-19-007

Development of L Component Calculation of Labor Escalation Factor - Reference NUREG-1307, Revision 17, Section 3.1 Using Regional Indices SERIES ID: CIU2010000000240I (as of 02/14/2019)

Note 1: The Base Labor factor was reindexed in December 2005, at which time the index was reset to 100.

Employment Cost lndust West Region Labor Private Industry Escalation (2005=100)

Factor Dec-05 100 2.06000 Apr-08 May-08 Jun-08 108.4 2.23304 Jul-08 Aug-08 Sep-08 109.3 2.25158 Oct-08 Nov-08 Dec-08 109.4 2.25364 Jan-09 Feb-09 Mar-09 109.9 2.26394 Apr-09 May-09 Jun-09 110 2.26600 Jul-09 Aug-09 Sep-09 110.3 2.27218 Oct-09 Nov-09 Dec-09 110.6 2.27836 Jan-10 Feb-10 Mar-10 111.3 2.29278 Apr-10 May-10 Jun-10 111.7 2.30102 Page 2 of 6 PG&E Letter HBL-19-007

Development of L Component Calculation of Labor Escalation Factor-Reference NUREG-1307, Revision 17, Section 3.1 Using Regional Indices SERIES ID: CIU2010000000240I (as of 02/14/2019)

Note 1: The Base Labor factor was reindexed in December 2005, at which time the index was reset to 100.

Employment Cost lndust West Region Labor Private Industry Escalation (2005=100)

Factor Dec-05 100 2.06000 Jul-10 Aug-10 Sep-10 112.3 2.31338 Oct-10 Nov-10 Dec-10 112.5 2.31750 Jan-11 Feb-11 Mar-11 113.5 2.33810 Apr-11 May-11 Jun-11 114.3 2.35458 Jul-11 Aug-11 Sep-11 114.6 2.36076 Oct-11 Nov-11 Dec-11 115.1 2.37106 Jan-12 Feb-12 Mar-12 115.7 2.38342 Apr-12 May-12 Jun-12 116.3 2.39578 Jul-12 Aug-12 Sep-12 116.8 2.40608 Page 3 of 6 PG&E Letter HBL-19-007

Development of L Component Calculation of Labor Escalation Factor - Reference NUREG-1307, Revision 17, Section 3.1 Using Regional Indices SERIES ID: CIU2010000000240I (as of 02/14/2019)

Note 1: The Base Labor factor was reindexed in December 2005, at which time the index was reset to 100.

Employment Cost lndust West Region Labor Private Industry Escalation (2005=100)

Factor Dec-05 100 2.06000 Oct-12 Nov-12 Dec-12 116.8 2.40608 Jan-13 Feb-13 Mar-13 117.6 2.42256 Apr-13 May-13 Jun-13 118.5 2.44110 Jul-13 Aug-13 Sep-13 119.2 2.45552 Oct-13 Nov-13 Dec-13 119.6 2.46376 Jan-14 Feb-14 Mar-14 120.1 2.47406 Apr-14 May-14 Jun-14 120.9 2.49054 Jul-14 Aug-14 Sep-14 121.9 2.51114 Oct-14 Nov-14 Dec-14 122.5 2.52350 Page 4 of 6 PG&E Letter HBL-19-007

Development of L Component Calculation of Labor Escalation Factor - Reference NUREG-1307, Revision 17, Section 3.1 Using Regional Indices SERIES ID: CIU2010000000240I (as of 02/14/2019)

Note 1: The Base Labor factor was reindexed in December 2005, at which time the index was reset to 100.

Employment Cost lndust West Region Labor Private Industry Escalation (2005=100)

Factor Dec-05 100 2.06000 Jan-15 Feb-15 Mar-15 123.1 2.53586 Apr-15 May-15 Jun-15 123.8 2.55028 Jul-15 Aug-15 Sep-15 124.6 2.56676 Oct-15 Nov-15 Dec-15 125.3 2.58118 Jan-16 Feb-16 Mar-16 126.2 2.59972 Apr-16 May-16 Jun-16 127.2 2.62032 Jul-16 Aug-16 Sep-16 127.9 2.63474 Oct-16 Nov-16 Dec-16 128.6 2.64916 Jan-17 Feb-17 Mar-17 129.9 2.67594 Page 5 of 6 PG&E Letter HBL-19-007

Development of L Component Calculation of Labor Escalation Factor - Reference NUREG-1307, Revision 17, Section 3.1 Using Regional Indices SERIES ID: CIU2010000000240I (as of 02/14/2019)

Note 1: The Base Labor factor was reindexed in December 2005, at which time the index was reset to 100.

Employment Cost lndust West Region Labor Private Industry Escalation (2005=100)

Factor Dec-05 100 2.06000 Apr-17 May-17 Jun-17 131 2.69860 Jul-17 Aug-17 Sep-17 132.3 2.72538 Oct-17 Nov-17 Dec-17 132.9 2.73774 Jan-18 Feb-18 Mar-18 134.6 2.77276 Apr-18 May-18 Jun-18 135.7 2.79542 Jul-18 Aug-18 Sep-18 136.6 2.81396 Oct-18 Nov-18 Dec-18 137.2 2.82632 Page 6 of 6 PG&E Letter HBL-19-007

Development of Burial Escalation Developed from NUREG-1307 Revision 17 Development of B Component Table 2 1 "Values of Bx as a Function of LLW Burial Site and Year(a)" (Values for Generators Located in the Unaffiliated States and those Located in Compact-Affiliated States having no Disposal Facility(c))

Revised to Bx Values for Generic LLW Disposal Site are assumed to be the same as that provided for the Atlantic Compact, 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 for lack of a better alternative at this time Revised to Bx Values for Generic LLW Disposal Site are assumed to be Combination of Compact-Affiliated and Non-Compact Facility for HBPP BWR BWR Burial Costs Restated to 198_6 = 100 1.561 1.0000 1.831 1.1730 2.361 1.5125 9.434 6.0436 9.794 6.2742 10.42 6.6752 10.379 6.6489 13.837 8.8642 13.948 8.9353 16.244 10.4061 16.474 10.5535 16.705 10.7015 17.337 11.1063 17.970 11.5119 19.391 12.4222 20.813 13.3331 21.658 13.8744 22.504 14.4164 23.430 15.0096 24.356 15.6028 25.825 16.5439 27.295 17.4856 27.295 17.4856 27.295 17.4856 27.295 17.4856 27.295 17.4856 13.132 8.4126 13.132 8.4126 13.422 8.5983 Table 2.1 Note (e) Bx values for the generic site are assumed to be the same as that provided for the Atlantic Compact for lack of a better alternative at this time.

Note (f) Effective with NUREG-1307, Revision 8 (Ref.3) an alternative disposal option was introduced in which the bulk of the LLW is assumed to be dis positioned by waste vendors and/or disposed of at a non-compact disposal facility.

Note (g) Effective with NUREG1307, Revision 15, the nomenclature for the two disposal options, referred to as "Direct Disposal" and "Direct Disposal wtth Vendors" in previous revisions of NUREG-1307, is changed to "Compact-Affiliated Disposal Facility Only" and "Combination of Compact-Affiliated and Non-Compact Disposal Facilities" to better describe the options.

Note (h) 2015 The NRG has issued Regulatory Issue Summary 2014-12, "Decommissioning Fund Status Report Calculations Update to Low-Level Waste Burial Charge Information," to inform licensees that they may use low-level waste burial charge data contained in Revision 15 of NUREG-1307, Report on Waste Burial Charges: Changes in Decommissioning Waste Disposal Costs at Low-Level Waste Burial Faciltties, dated January 2013, when preparing their periodic decommissioning fund status report.

Note (i) Effective with NUREG-1307, Revision 16, the CWF in Andrews County, Texas, is also available as a full-service (i.e.,

Class A, B, and C) LLW disposal faciltty for waste generators located in States not affiliated with the Texas Compact. Out-of-compact generators, however, must submit an import petition to the Texas Compact Commission for approval prior to shipping. The State of Texas also limns total non-compact waste disposed at the CWF to 30-percent of licensed capacity and imposes additional fees on LLW disposed of from out-of-compact generators. With the availability of this full-service disposal facility to out-of-compact waste generators and the Clive, Utah disposal facility for any Class A LLW generated in the U.S., the Generic LLW Disposal Site option used in previous versions of NUREG-1307 is replaced with this option, which provides Bx values representing a composite of the disposal rates for these two disposal facilities. These Bx factors are recommended for use for plants that currently have no disposal site available within their designated LLW Compact. Accordingly, given this consideration, licensees may want to set aside additional decommissioning trust funds to avoid significant future shortfalls in funding and potential enforcement actions.

Page 1 of 1 PG&E Letter HBL-19-007

Humboldt Bay Power Plant Decommissioning Cash Flow (1 page)

PG&E Letter HBL-19-007

Year 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 TOTAL

1)

2)

3)

Humboldt Bay Power Plant Decommissioning Cash Flow1 Nomlnal/2019 Dollars SPENT FUEL NRC NON - NRC MANAGEMENT

$1,678,452

$8,663,216

$5,573,757

$344,408

$723,490

$2,281,454

$85,241

$2,736,091

$89,543

$398,012

$994,127

$113,704

$494,838

$2,539,476

$491,070

$1,444,628

$161,506

$1,671,769

$1,073,612

$3,546,617

$4,474,247

$9,240,172

$12,590,383

$28,485,988

$32,901,391

$3,179,956

$56,957,494

$5,734,776

$60,585,531

$5,495,157

$81,577,560

$4,509,009

$93,946,862

$4,668,626

$79,506,972

$5,085,456

$106,846,880

$5,853,718

$106,532,076

$619,888

$5,768,725

$89,781,415

$7,100,443

$7,141,755

$41,848,597

$24,115,759

$7,606,854

$20,058,016

$27,080,374

$21,784,948

$4,184,326

$8,174,848

$0

$9,426,160

$0

$8,693,683

$0

$8,668,586

$0

$8,584,562

$0

$8,584,562

$0

$9,323,038

$0

$8,659,853

$0

$8,622,207

$0

$8,622,207

$0

$8,622,207

$0

$756,460

$7,901,676

$0 4,706,876

$7,898,401

$0

$14,223,213

$1,502,622

$811,820,603

$78,603,013

$242,915,909 Cumulative Decommission TOTAL Estimate

$1,678,452

$1,678,452

$8,663,216

$10,341,668

$5,918,165

$16,259,833

$3,004,944

$19,264,777

$2,821,332

$22,086,109

$487,555

$22,573,664

$1,107,831

$23,681,495

$3,034,314

$26,715,809

$1,935,698

$28,651,507

$1,833,275

$30,484,782

$4,620,229

$35,105,011

$13,714,419

$48,819,430

$41,076,371

$89,895,801

$36,081,347

$125,977,148

$62,692,270

$188,669,418

$66,080,688

$254,750,106

$86,086,569

$340,836,675

$98,615,488

$439,452,163

$84,592,428

$524,044,590

$112,700,598

$636,745,188

$112,920,689

$749,665,877

$104,023,613

$853,689,490

$73,571,210

$927,260,701

$68,923,338

,$996,184,038

$12,359,174

$1,008,543,212

$9,426,160

$1,017,969,372

$8,693,683

$1,026,663,055

$8,668,586

$1,035,331,641

$8,584,562

$1,043,916,202

$8,584,562

$1,052,500,764

$9,323,038

$1,061,823,802

$8,659,853

$1,070,483,655

$8,622,207

$1,019;105,862

$8,622,207

$1,087,728,070

$8,622,207

$1,096,350,277

$8,658,136

$1,105,008,413

$12,605,277

$1,117,613,690

$15,725,834

$1,133,339,524

$1,133,339,524 Cash Flow is based on construction of ISFSI and Fuel removed from HBPP in 2033 (Assumes DOE Used Fuel Repository opens in 2031 allowing for HBPP Fuel to be shipped during 2031-2032 and Final Site Restoration in 2033).

Market Value of Trust as of 12/2018 was $138.2 million, actual expended as of 12/2018 was $927.3 Million Totals may not balance due to rounding.

1 of 1

$927,260,701 Actual PG&E Letter HBL-19-007

$1,065,448,862 Actual + Market Value

Variance of the 2018 Forecast PG&E Letter HBL-19-007 PG&E Letter HBL-19-007 Variance of the 2018 Forecast Estimated Costs:

Forecast of 2018 per PG&E Letter HBL-18-004, Enclosure 3, dated March 27, 2018, in 2018 dollars:

NRC Scope (Radiological)

Non-NRC Scope Spent Fuel Management Actual Costs:

$ 59,209,140

$ 24,368,994

$ 10,176,866 Actual 2018 Incurred Costs, provided in Enclosure 3 of this letter, reflects the actuals for 2018 in nominal dollars.

NRC Scope (Radiological)

Non-NRC Scope Spent Fuel Management Variance: (Favorable)

NRC Scope (Radiologica1)

Non-NRC Scope Spent Fuel Management

$ 41,848,597

$ 24,115,759 7,606,854

$ 17,360,543 253,235 2,570,012 Decommissioning costs were underspent in 2018 primarily due to civil works contractor's delay in invoicing for work performed in 2018. Non-NRC related scope, Final Site Restoration delay in invoicing and scope deferred to 2019. Spent Fuel Management delayed work on infrastructure upgrades and the ISFSI License Renewal project that was planned in 2018.

Page 1 of 1

Pacific Gas and Electric Company Chapter 8 PG&E Letter HBL-19-007 Humboldt Bay Power Plant Unit 3 Updated Nuclear Decommissioning Cost Estimate

PACIFIC GAS AND ELECTRIC COMPANY CHAPTER 8 HUMBOLDT BAY POWER PLANT UNIT 3 UPDATED NUCLEAR DECOMMISSIONING COST ESTIMATE

PACIFIC GAS AND ELECTRIC COMPANY CHAPTER 8 HUMBOLDT BAY POWER PLANT UNIT 3 UPDATED NUCLEAR DECOMMISSIONING COST ESTIMATE TABLE OF CONTENTS A.

Introduction....................................................................................................... 8-1 B.

Summary.......................................................................................................... 8-1 C. NRC License Termination................................................................................ 8-3

1.

Part 50 License Termination Plan.............................................................. 8-3

2.

ISFSI Operations and Demolition............................................................... 8-3 D. Other Agency Approvals................................................................................... 8-4 E.

Estimate by Cost Category............................................................................... 8-7

1.

General Staffing......................................................................................... 8-8

a.

Final Site Restoration/License Termination/FSS Oversight (Overall Project)................................................................................... 8-9

1) Site Management.......................................................................... 8-9

2) Decommissioning Department.................................................... 8-12

3)

Environmental Department.......................................................... 8-12

b.

Site Closure Department (License Termination Survey [Excludes Caisson])........................................................................................... 8-13

2.

Small Value Contracts.............................................................................. 8-13

a.

Small Dollar Vendors......................................................................... 8-13

b.

Specialty Contracts............................................................................ 8-14

c.

Final Site Restoration........................................................................ 8-14

d.

Tools and Equipment......................................................................... 8-15

e.

Residual Remediation/Waste Disposal.............................................. 8-15

f.

Office Facility Rent............................................................................ 8-15

3.

Spent Fuel Management.......................................................................... 8-16

a.

Security (PG&E) Staff Costs.............................................................. 8-16 8-i

PACIFIC GAS AND ELECTRIC COMPANY CHAPTER 8 HUMBOLDT BAY POWER PLANT UNIT 3 UPDATED NUCLEAR DECOMMISSIONING COST ESTIMATE TABLE OF CONTENTS (CONTINUED)

b.

ISFSI Operating and Maintenance Costs.......................................... 8-16

c.

ISFSI Staffing/Engineering Services/Specialty Contracts.................. 8-17

d.

ISFSI Infrastructure Expenses........................................................... 8-17

e.

NRC Fees.......................................................................................... 8-18

f.

ISFSI Removal.................................................................................. 8-18

g.

Transfer to DOE................................................................................ 8-19 F.

Planned Schedule and Activities.................................................................... 8-19 G. Decision Log................................................................................................... 8-22 H. Trust Disbursement Advice Letters................................................................. 8-22 I.

SAFSTOR...................................................................................................... 8-22 J.

Conclusion...................................................................................................... 8-23 8-ii

1 PACIFIC GAS AND ELECTRIC COMPANY 2

CHAPTER 8 3

HUMBOLDT BAY POWER PLANT UNIT 3 UPDATED NUCLEAR 4

DECOMMISSIONING COST ESTIMATE 5

A. Introduction 6

The purpose of this chapter is to provide Pacific Gas and Electric 7

Company's (PG&E) updated estimate of the remaining activities, cost and 8

schedule to complete decommissioning and Nuclear Regulatory Commission 9

(NRC) license termination at Humboldt Bay Power Plant Unit 3 (HBPP). Due to 10 the advanced status of decommissioning and the limited nature of revisions to 11 the approved estimate, the 2018 HBPP Decommissioning Cost Estimate (HBPP 12 DCE) updates, rather than replaces, the 2015 HBPP Decommissioning Project 13 Report (2015 DPR). The HBPP DCE is provided as Chapter 8, Attachment A 14 and the 2015 DPR is provided as Chapter 8, Attachment B.

15 B. Summary 16 The HBPP DCE covers the period from January 2019 through 2033, 17 including: completion of final site restoration (FSR); HBPP radiological 18 decommissioning; termination of the HBPP 10 CFR Part 50 license; 19 management of Spent Nuclear Fuel (SNF)/Greater-Than-Class-C (GTCC) waste 20 in the HBPP Independent Spent Fuel Storage Installation (ISFSI); HBPP ISFSI 21 decommissioning after the SNF/GTCC waste has been moved to an off-site 22 facility; and FSR and termination of the ISFSI 10 Code of Federal Regulations 23 (CFR) Part 72 license.

24 In the 2015 Nuclear Decommissioning Cost Triennial Proceeding (NDCTP),

25 the California Public Utilities Commission (Commission) approved PG&E's 26 HBPP DCE of $1,095.4 million (nominal/2018$).1 During the period 2015 27 through 2018, the Civil Works Contractor (CWC) completed demolition of the 28 majority of remaining structures and infrastructure, and the FSR for the Part 50 29 license is scheduled to be completed in 2019. After more than three decades in 30 Safe Storage (SAFSTOR) and nine years of decontamination and 1

Since HBPP completed a major phase of decommissioning in 2018 and the HBPP Reasonableness Report covers activities through 2018, the HBPP DCE is based on 2018$. Unless otherwise stated, costs herein are in 2018$.

8-1

1 dismantlement, the site is configured and ready for Final Status Survey (FSS),

2 which is also planned to be completed in 2019.

3 In preparation for its 2018 NDCTP, PG&E reviewed its previously-approved 4

estimate, work completed since the 2015 NDCTP and anticipated remaining 5

work, schedule and costs. PG&E has concluded that there is no change from 6

the forecast approved in the 2015 NDCTP, other than: (1) a decrease of 7

$9.0 million due to cost savings of approximately $7 million in Canal 8

Remediation Disposal and $2 million in EPC Services; and (2) an increase of 9

$25.1 million related to the assumption that PG&E will incur an additional three 1 o (3) years of spent fuel management costs based on an assumed delay from 11 2028 to 2031 in DOE commencing pick up of SNF/GTCC waste.2 The updated 12 total HBPP decommissioning cost is $1,111.5 million (nominal/2018$), with a 13 cost to complete as shown in Table 8-1 as of January 1, 2019 of $182.5 million, 14 resulting in an increase of $16.1 million from the forecast approved in the 15 2015 NDCTP.

FIGURE 8-1 NDCTP FILING CASH FLOW COMPARISON NDCTP Filing Cash Flow Comparison 1,400 1,200 1, 62 1, 73 l, 84 I, 01_ j 2l -" ~

~

1.D21 l. JO l, "0 I, 50 28

l. ~.

l, '°l 1.11 10

l.

97 9 9 I 75 l,86 l, 98 l.

~

1,121

!,I l l l, >l...

?

j) 52 1.1<>2 1.12 Nomln I Dollar.

929

//

~

V 9

~

400 200

~/

1/6ie z,1 3 /"

l

/,

...--;-v: 9 6

! )

0 2009 2010 2011 2012 2013 2014 2015 201 6 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 Year Ending

-Actuals 2015 NDCTP Decision

..._ 2018 NDCTP 2

The basis for this assl_!mption is provided in Chapter 6, Section D.

8-2

1 A detailed cost breakdown and comparison to the 2012 and 2015 NDCTP 2

estimates is provided in Table 8-2: HBPP Decommissioning Cost Breakdown.

3 C. NRC License Termination 4

PG&E has two NRG-issued licenses for the HBPP site: one issued under 5

10 CFR Part 50 pertaining to HBPP Unit 3, and the other issued under 10 CFR 6

Part 72 pertaining to the operation of the HBPP ISFSI for the storage of SNF 7

and GTCC waste from the operation of Unit 3.

8

1.

Part 50 License Termination Plan 9

The HBPP Part 50 License Termination Plan (L TP) was approved by the 10 NRC in May 2015 (ADAMS ML15090A339). The L TP includes site 11 characterization data; a description of the remaining dismantling activities; 12 plans for site remediation; procedures for the final radiation survey; and 13 designation of the end use of the HBPP site. It also includes the final survey 14 plan, which identifies the radiological surveys to be performed once the 15 remediation activities are completed. The final survey plan was developed 16 using the guidance provided in the "Multi-Agency Radiation Survey and Site 17 Investigation Manual." Surveys performed under this guidance provide a 18 high degree of confidence that applicable NRC criteria are satisfied.

19 The L TP is an appendix to the Defueled Safety Analysis Report and is 20 required by NRC regulation to be updated and submitted to the NRC every 21 two years. The updated L TP was provided to the NRC in February 2018 22 (ML18066A137).

23 Once the final survey data, final summary report, and license 24 amendment request are submitted to the NRC in 2020, the agency will 25 review and evaluate the information, perform an independent confirmation 26 of radiological site conditions and decide whether the terminal radiation 27 survey and associated documentation demonstrates that the facility 28 complies with radiological release criteria. If so, it will terminate the HBPP 29 10 CFR Part 50 license.

30

2.

ISFSI Operations and Demolition 31 Following the termination of the HBPP 10 CFR Part 50 license, the 32 HBPP ISFSI will continue to be operated under the 10 CFR Part 72 license 33 until all SNF and GTCC waste has been transferred to the Department of 8-3

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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 D.

Energy (DOE). For purposes of developing the HBPP DCE, PG&E assumes that the DOE will commence transferring SNF and GTCC waste casks from the HBPP ISFSI in 2031 and will complete transfer operations in 2032.

Because of delays with the pickup of SNF and GTCC waste from the HBPP ISFSI beyond the current 10 CFR Part 72 license termination date of 2022, PG&E prepared and submitted a License Renewal Application in July 2018. The application requests a forty-year extension, with an expiration date of November 2065.

Terminating the HB ISFSI 10 CFR Part 72 license will require preparation of an ISFSI L TP dismantlement of the ISFSI vault and any necessary remediation. PG&E will perform an FSS and complete FSR. The FSS documentation will be transmitted to the NRC with a License Amendment Request (LAR) for license termination. After the NRC determines that the ISFSI site remediation has been performed in accordance with the ISFSI L TP and the associated documentation demonstrates compliance with the plan, the NRC will terminate the 10 CFR Part 72 license.

Other Agency Approvals While the NRC has the authority to terminate the HBPP 10 CFR Part 50 license, other agencies also have permitting authority over decommissioning activities. Some of these permits will expire unless renewed by PG&E, while other permits or permit requirements will continue in perpetuity. PG&E is consulting with regulatory agencies to terminate permits, where appropriate.

Permit requirements that will remain after decommissioning completes consist of the Coastal Development Permits (CDP) for the ISFSI. The CDP (CDP E-05-001 ), related to the construction of the HBPP ISFSI, includes the following requirements that continue after decommissioning HBPP:

Special Condition 1 - Monitoring Bluff Slopes: No less than every five years, PG&E shall monitor bluff slopes for sliding, ground movement and other motion. No later than June 30 of each subsequent fifth year, PG&E shall submit a report, prepared by a licensed Civil Engineering Geologist, to the California Coastal Commission (CCC), describing the results of the monitoring. If during any five-year period, monitoring shows 8-4

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 any horizontal or vertical movement of the bluff slope or edge of two feet or greater, monitoring and reporting shall then be done on an annual basis, with the report as previously described being submitted no later than June 30 of each year. If during five consecutive annual monitoring periods, movement of the bluff slope and edge totals less than two feet, monitoring and reporting may return to a five-year schedule. PG&E shall notify the CCC Director immediately in the event of slope failure or movement, which may indicate imminent slope failure. If monitoring results for any reporting period indicate slope movement, which may require additional measures to protect the bluffs, PG&E shall submit a CDP application or request for an amendment.

Special Condition 2 - Monitoring Shoreline Erosion: No less than every five years, PG&E shall conduct surveys of the shoreline and lower toe of the bluff of the ISFSI site. Surveys shall be conducted by a licensed Surveyor or Civil Engineer. Each survey shall be performed in the early spring, or as close to that time as is feasible, when the beach level is lowest, and the lower bluff face is most exposed. Each survey shall record the position of the lower toe of the bluff using conventional survey techniques (total station, rod and level, plane table, etc.), differential Global Positioning System, photogrammetry (with current ortho-rectified aerial photographs), by ground Light Detection and Ranging, or other comparable technique. Survey techniques used shall be consistent throughout the survey period or shall allow consistent comparison of yearly data. Survey measurements shall be accurate within 0.5 feet horizontally and 1.0 foot vertically. PG&E shall report the results of each survey to the CCC by June 30 of every fifth year.

Each report shall include narrative and mapped analysis of the survey data, a determination of the average retreat rate for the full survey area and identification of any location(s) where the bluff ctie,nge rate is more than two standard deviations from the average. Bluff change shall be calculated at 50-foot intervals or less, to determine the average retreat, the standard deviation and to identify areas of outlier retreat rates. If monitoring results for any survey indicate the development may be threatened by coastal erosion in less than five years, PG&E shall submit within sixty days of the 8-5

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annual survey report a CDP application or request for an amendment to this permit to relocate the ISFSI or other project components as needed.

3 Special Condition 5 - Public Access:

4 5

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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 a)

PG&E shall execute and have recorded against the parcel governed by the permit a deed restriction in a form and content acceptable to the CCC. The deed restriction shall establish an accessway based on the existing public use trail and shall extend along the shoreline from the western end of the power plant site near King Salmon Road to the rail line on the northern end of the power plant site. The accessway shall be no less than 20 feet wide at any point, as measured landward from the ordinary high-water mark. The deed restriction shall also reflect that this accessway will move with the shoreline; that is, the minimum dimensions of the accessway shall be maintained as the ordinary high-water mark moves due to short-or long-term events such as coastal erosion, sea level rise, or other phenomena.

b)

PG&E shall establish an Access Plan, subject to CCC approval. The plan shall, at minimum, include a legal description of the accessway as recorded on the property deed and a description of improvements that will be made to ensure public access is safely maintained. Measures that will be taken to maintain the accessway in a safe and usable condition to ensure safe pedestrian use shall include providing a level walking surface, regularly inspecting accessway conditions, placing trash receptacles on or near the trail and placing signs at both ends of the accessway that describe the access available and the conditions related to the adjacent ISFSI that may affect access. The design and placement of signs shall be consistent with those developed as part of the Humboldt Bay Trails Feasibility Study.

c)

Changes to Access: If any change to the safety or security measures associated with the ISFSI results in a change to, or limitation on, public access to the shoreline, PG&E shall file a complete application to amend this permit. The application for an amendment shall describe the nature of the change and its effect on public access and shall include proposed measures that would provide at least an equivalent amount of shoreline access on or near the ISFSI site.

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1 Similar requirements are contained in the other CDPs issued for canal 2

remediation and the FSR. HBPP Management will work with the CCC to 3

standardize the language between the CDPs into the ISFSI CDP, so that PG&E 4

may request termination of the non-lSFSI CDPs.

5 PG&E will be required to submit a new CDP or CDP amendment application 6

to the CCC to address decommissioning of the ISFSI and restoration of the 7

ISFSI site. ISFSI decommissioning will likely include removal of ISFSI roads, 8

offices and support facilities. Whether there will be additional permit 9

requirements is not known at this time.

1 o E. Estimate by Cost Category 11 As authorized in prior NDCTPs, PG&E estimates and then tracks costs 12 against specified cost categories; the specified categories are reflected in 13 Table 8-2. With the closure of the Civil Works scope of work, many of these 14 categories are now closed out, and presented for review in Chapter 9. FSR, 15 Residual Remediation/Waste Disposal, Tools & Equipment-Common and 16 Office Facilities Rent were moved from their corresponding blue line cost 17 categories, so the associated cost categories could be closed out.

18 The following cost categories remain open for the completion of HBPP 19 decommissioning:

20 General Staffing costs associated with the overhead staffing costs to 21 support License Termination Survey and FSR/FSS oversight; 22 Small Value Contract costs associated with Small Dollar Vendors, Specialty 23 Contracts, remaining FSR, tools and equipment, Residual Remediation/Waste 24 Disposal and office facility rent; and 25 Spent Fuel Management costs for ISFSI staffing, Operations and 26 Maintenance (O&M); ISFSI Engineering and Specialty Contracts; ISFSI 27 infrastructure expenses; NRC fees; DOE transfer and ISFSI removal after 28 DOE transfer.

8-7

TABLE 8-1 2018 NDCTP COST TO COMPLETE HBPP DECOMMISSIONING Approved 2015 NDCTP Budget Estimate to Complete

$2018 ETC 2019 to ETC 2031-Line 2018 Cost 2030 2033 No.

Category

$2018

$2018 1

General Staffing (Excludes Caisson) 13,170,667 2

Overall Project (CWC Oversite) 3 License Termination/FSS Oversite 9,374,233 4

License Termination Survey (Excludes Caisson) 3,796,433 5

Small Value Contracts 21,070,030 6

Small Dollar Vendors 348,487 7

Specialty Contracts 5,622,074 8

Final Site Restoration 12,131,414 9

Residual Remediation/Waste Disposal 1,087,709 10 Tools & Equipment-Common 883,350 11 Office Facilities Rent 996,996 12 Spent Fuel Management 123,207,562 25,067,582 13 Security (PG&E) 77,905,517 20,208,927 14 ISFSI O&M 7,089,686 1,823,405 15 ISFSI Staffing/Engineering/Specialty Contracts 6,775,459 1,675,381 16 ISFSI Infrastructure Expenses 8,985,741 356,997 17 NRC Fees 3,415,162 1,002,873 18 ISFSI Removal 15,368,552 19 Transfer to DOE 3,667,446 20 Total 157,448,259 25,067,582 Note: These costs include contingency of approximately 16 percent.

1

1.

General Staffing 2

The cost of staffing (labor) is a significant portion of the remaining 3

overall costs of the HBPP decommissioning. Both the cost of direct labor to 4

perform the work and the cost of overhead labor to support the direct labor 5

force contribute to the total labor costs. The ISFSI will continue in operation 6

until the DOE takes custody of the SNF and GTCC waste, which is expected 7

to commence in 2031. The ISFSI staffing costs are included in spent fuel 8

management, and they are not included in the Overall Project staffing.

9 Through proactive planning, PG&E has done an excellent job of 10 managing the total workforce. During the period 2012 through 2018, the 11 General Staffing personnel focused efforts on self-performance and civil 12 work scopes of work. After FSR is complete, the General Staffing focus will 8-8

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3 4

5 6

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 be on FSS and license termination support activities. The estimated remaining cost for General Staffing is $13.17 million.

a.

Final Site Restoration/License Termination/FSS Oversight (Overall Project)

The staffing for FSR/License Termination/FSS Oversight continues through 2019 and ends in 2020. The Staffing Plan ramps down the latter part of 2020, with the final submittal of FSS documents to the NRC. During closeout of the project in 2020, the staffing plan is at a minimum headcount as PG&E submits the 10 CFR Part 50 License Termination Request, completes invoice processing, and transmits documents to the Records Management System (RMS).

The staffing for FSR/License Termination/FSS Oversight includes Fixed Overhead. These are the costs incurred for maintaining staff who are assigned to Management, Safety, Facility Maintenance, Licensing Support, Procurement and Finance roles and responsibilities. Fixed Overhead is job functions that are needed regardless of the status and progress of the decommissioning. It also includes direct and discrete labor, which are staffing costs for personnel who directly support schedule progress, such as engineered plans, development of work packages, permits and maintenance of the programs required by regulation, license or the company, in order to ensure that the FSS is accomplished safely and efficiently. Site Management Department The FSR/License Termination/FSS Oversight staff is distributed within the following departments:

Site Management (Director)

Decommissioning Environmental Site Closure

1) Site Management To ensure project success, PG&E recruited a highly-experienced and specialized group of managers with solid management skills, strong technical skills, industry-specific knowledge and the desire to see the project succeed through the 8-9

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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 critical phases. The low attrition rate, strong participation in professional and industry forums and proven ability to solve unexpected problems has validated the selections. The combination of PG&E and contractor personnel with specialized skill sets has proven to be very cost-effective. Industry evaluations, audits, NRC inspections, project safety achievements and project accomplishments attest to the team's ability to manage the project within the project parameters. This strategy was used throughout the decommissioning process and will continue through the completion of FSS. Refer to 2015 DPR, Section 3.3.1.1.2 for details on PG&E Management strategy for Site Management staffing.

The current management organization continues to be well-suited to manage and oversee the completion of the FSS and the ultimate termination of the 10 CFR Part 50 license. Based on the status to-date and the schedule going forward, HBPP Management plans to reduce direct reports as their specific specialties warrant.

The RP Manager was released in 2017, with any residual responsibilities being managed by the Site Closure Manager. The Deputy Director was released in 2017, with any residual responsibilities being managed by the Environmental Manager. The Decommissioning Manager was released in 2017. Any of the Decommissioning Manager's residual responsibilities are being managed by the remaining site leaders, Site Closure, Environmental and Business Analysis.

The following are key staff positions in the Director's organization:

HB Senior Director/Plant Manager-Nuclear The HB Senior Director/Plant Manager-Nuclear (Director) has the responsibility for oversight of the entire decommissioning and site restoration, including safety of employees, implementation of work processes, disposal of wastes and control of the budgets to accomplish the entire project. The Director works collaboratively with a wide variety of other groups to safely and efficiently execute the mission. These groups include a mix of internal stakeholders, 8-10

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 such as Site Closure, Safety, Security and Quality Verification, as well as external stakeholders, such as interested state and federal regulators, other utilities preparing to decommission facilities and local community groups, such as the Community Advisory Board.

Decommissioning Business Analysis Supervisor The duties and responsibilities of the Decommissioning Business Analysis Supervisor relate to the day-to-day activities of the Finance, Litigation and Project Controls groups; manages the Corrective Action Program; oversight of remaining self-perform work field activities; and oversight of the contractors and contracts for the FSS. This position is primarily responsible for the Cost and Schedule baselines and managing the line-of-business interests for PG&E previously performed by the Decommissioning Manager.

Site Closure Manager The Site Closure Manager supervises the License Termination Survey staff, manages site training and regulatory affairs matters previously performed by the Decommissioning Manager. He also assumed Radiological Program management duties previously performed by the RP Manager.

Engineering Manager The Engineering Manager is provided by Diablo Canyon Power Plant (DCPP) and is available to the Director to address any decommissioning matters involving engineering issues.

Environmental Manager The Environmental Manager supervises the Environmental organization and responsibilities for decommissioning management performed previously by the Deputy Director and the Decommissioning Manager.

HBPP Trust Fund Consultant-Expert The HBPP Trust Fund Consultant-Expert is the PG&E Subject Matter Expert (SME) for the Nuclear Decommissioning Trust Fund, performing reviews and submitting back-up documentation for trust fund expenditures. This position also provides data to comply with NRC funding assurance requirements.

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6 7

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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 DOE Litigation Specialist The DOE Litigation Specialist is responsible for the preparation of PG&E claims against the DOE as part of the Settlement Agreement. Under the Settlement Agreement, annual DOE claims are prepared and submitted for reimbursement.

2) Decommissioning Department The Decommissioning Department is responsible for performing cost and budget control, procurement and warehouse functions.

Decommissioning is also tasked with oversight, identification and control of the execution of project transition and work. The Decommissioning Department structure is depicted in Attachment C.

The Decommissioning Department is the central group responsible for planning, executing and tracking progress and funding for the decommissioning of HBPP Unit 3. To effectively execute its assigned missions, the makeup of the Decommissioning Department has changed over time, with changes to the workload and to the remaining work to oversee. The downward trend is expected to continue through the completion of the decommissioning project closeout.

3) Environmental Department The Environmental Department (depicted in Attachment D) is responsible for implementing the environmental and safety procedures and programs; and interfacing with agencies on permitting, as well as stakeholders who have concerns about areas of cultural, paleontological and biological significance at the site and surrounding areas.

The Environmental Department activities will continue through the FSS and project closeout of the Voluntary Cleanup Agreement between PG&E and the California Department of Toxic Substance Control, as well as the processing of any waste generated from FSS and termination of the decommissioning permits.

8-12

b. Site Closure Department (License Termination Survey [Excludes 2

Caisson])

3 The Site Closure Department staff is responsible for license 4

termination activities, such as O&M of the Count Room, maintaining and 5

submitting updates to the HBPP L TP, performing and documenting the 6

FSS, coordinating with NRC oversight, and generating reports to the 7

NRC and State of California regulators.

8 To support FSS, Site Closure Department staff assigned as 9

Radiation Protection (RP) Technicians implement the programmatic and 10 procedural requirements established to satisfy 10 CFR Part 20, Unit 3 11 Technical Specifications, and 10 CFR Part 19. The RP Technicians 12 also contribute to the implementation of Radiological Environmental 13 Monitoring Program (REMP) and compliance with 40 CFR Part 190.

14 As the FSS-required data is collected and reduced and documents 15 transmitted to the NRC, the staffing for the Site Closure Department will 16 decrease accordingly.

17

2.

Small Value Contracts 18 Small Value Contracts categories include:

19 Small Dollar Vendors 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Specialty Contracts Final Site Restoration Tools and Equipment Residual Remediation/Waste Disposal Office Facility Rent The remaining cost to complete for this category is estimated to be

$21.1 million.

a.

Small Dollar Vendors Small Dollar Vendors are associated with contracts for providing HBPP site maintenance and FSS support field labor, as well as supporting SWWPP mitigation. Small Dollar Vendors also includes the collection of recurring costs that are expected to continue through the completion of FSS. These include:

Circuit Leasing and Internet Services 8-13

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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33

b.

Computer Software and Hardware Employee Training, Travel and Meal Expense Electric Power Research Institute Membership Mitigation and Monitoring Implementation Office Supplies Printer Rental and Maintenance Support Shuttle Services Water and Sewer Services Decommissioning Plant Coalition Representation Landscape and Site Maintenance Printing and Document Shredding Services Department of Public Health Fees State Water Resource Control Fees Specialty Contracts Specialty Contracts are issued for specific skills or services not performed by HBPP staff. They include various elements, such as permitting fees, environmental contracts, NRC fees and other miscellaneous specialty consultations.

Services covered in this category include NDCTP SME, Oak Ridge Associated Universities SME, FSS support services, relocation services, biological monitoring and reporting services, chemical analysis sampling services, hazardous waste disposal, Care Onsite Services, legal representation and support, Oracle P6 system software and services, other support and training, NRC interface, permitting and permitting assistance and other necessary services to support the FSS and license termination on an ongoing basis.

c.

Final Site Restoration FSR includes remaining demolition, removal of remaining equipment, excavation, grading, drainage, wetland construction, ground cover (vegetation and other surfacing), installation of fencing, installation and construction of new components and repairs to existing features of the HBPP site (including roadways) to configure the site for future industrial use.

8-14

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5 6

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 FSR costs were initially included In the Civil Works Scope. Other than completion of FSR, the Civil Works Scope has been completed. To enable PG&E to close out Civil Works, PG&E has moved FSR costs to the Small Value Contracts category. This work scope is being performed by the ewe and is scheduled to be completed in 2019. The remaining costs for FSR are $12.1 million.

d. Tools and Equipment The tools and equipment required to support completion of FSS are associated with RP Tools and Equipment. Typical tools and equipment purchased to support RP and FSS work include consumables (polyethylene sheeting, sample containers, general office supplies and items to assist in contamination control); Personal Protective Equipment (PPE); contamination detection instrumentation; fire extinguishers; eyewash stations; first aid kits; blood-borne pathogen kits; and other specially-customized materials. Also included is replacement of radiation monitoring instruments and detectors.

e.

Residual Remediation/Waste Disposal During FSS, there is a possibility that licensed material that is greater than the values established in the H BPP L TP, or hazardous materials not previously identified, will be discovered. This material will need to be removed and isolated for ultimate disposal.

Waste Disposal also includes the costs associated with the disposal of non-releasable tools and equipment or radioactive and hazardous materials from FSS. Waste generation from FSS is expected to be minimal and to fall into one of the following categories:

Noncompliant Waste Low-Level Radioactive Waste

f.

Office Facility Rent To facilitate Caisson removal, PG&E arranged with the College of the Redwoods to lease vacant office space on the campus. PG&E was able to relocate support staff from the decommissioning site to the College of the Redwoods as the staff was systematically displaced onsite. Upon completion of FSR, the only personnel who will physically 8-15

remain at the HBPP decommissioning site are the Site Closure 2

Department staff assigned to the Count Room and the ISFSI staff. All 3

other FSS support staff are located at the College of the Redwoods.

4 The costs associated with use of the College of the Redwoods 5

property as office space was included in the 2015 in the DCPP in the 6

category titled Common Site Support - Caissons and Canals. Since this 7

scope of work has been completed, for the 2018 NDCTP filing, the 8

ongoing costs associated with the College of the Redwoods space rent 9

is included under Small Value Contracts.

1 o

3.

Spent Fuel Management 11 The O&M of an ISFSI includes a multitude of activities to ensure the 12 SNF and GTCC waste is stored in a manner to protect public health and 13 safety. The 2015 DPR, Section 3.3.1.8 provides a detailed discussion 14 related to the cost basis for Spent Fuel Management.

15 Since PG&E assumes a delay in transfer of SNF and GTCC waste by 16 the DOE From 2028 to 2031, the current estimate includes an additional 17

$25.1 million in forecast spent fuel management costs. These costs are 18 comprised primarily of:

19 Security staffing 20 O&M 21 22 23 24 25 26 27 28 29 30 31 32 ISFSI Specialist/Engineering/Specialty Contracts Infrastructure improvements ISFSI FSR NRC fees

a.

Security (PG&E) Staff Costs The HB ISFSI staffing includes a Security element to provide 24-hour surveillance of the SNF to comply with NRC security regulations and the HB Emergency Plan and ISFSI Physical Security Plan.

b.

ISFSI Operating and Maintenance Costs ISFSI O&M functions include effective and efficient ongoing management, safety and compliance necessary to meet NRC requirements.

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Overhead costs to maintain the HB ISFSI include: PPE; physical, auditory, and psychological testing for Fitness-for-Duty requirements; uniform supplies; arms and ammunition; radio and cellular equipment and service; specialty training; office supplies; and facility services and maintenance.

c.

ISFSI Staffing/Engineering Services/Specialty Contracts HB ISFSI non-Security related support is provided by a number of sources, including DCPP organizations, ISFSI specialists and vendors.

The DCPP organizations provide support in areas of Engineering, Human Resources, Procurement, Quality Verification, Records Management, and Regulatory Affairs.

The ISFSI Specialists within the ISFSI organization perform Administrative services, Emergency Planning, Training and are the liaisons with the DCPP support organizations.

Vendors provide infrastructure support as engineering services (through DCPP organizations) and specialty contracts for scope of work activities not provided by DCPP staff or HB ISFSI specialists.

d.

ISFSI Infrastructure Expenses ISFSI Infrastructure Expenses includes those costs associated with maintaining compliance with the regulatory requirements associated with the storage of SNF and GTCC wastes at the ISFSI and the ultimate removal of the HB ISFSI. Ongoing projects identified in the 2015 HBPP DPR include:

Building 6 Conversion to Onsite ISFSI Weapons Training Facility The Building 6 Conversion to On-Site ISFSI Weapons Training Facility has not yet been implemented due to the unavailability of Building 6 for the conversion. The building to be converted was occupied by personnel involved with the decommissioning. The conversion is scheduled to be completed in 2019.

Care Onsite The establishment of a Care Onsite for the ISFSI has not yet been implemented due to the unavailability of Building 6. The establishment of the Care Onsite facility will be completed after the Count Room 8-17

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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 (Building 13) is converted to offices for the HB ISFSI staff (scheduled in 2020).

Building 13 Retrofit Upgrade for ISFSI The retrofit of Building 13 (Count Room) to support the ISFSI as offices has not yet been implemented due to the unavailability of the building. The Count Room was occupied by personnel involved with the FSS. Building 13 retrofit is scheduled to be converted to offices for the HB ISFSI staff after the completion of FSS in 2020.

lnfoQual Program Migration to Mylearning The migration to the lnfoQual Program training database is in progress and is expected to be completed in 2019.

e.

NRC Fees 10 CFR Part 171 "Annual Fees for Reactor Licenses and Fuel Cycle Licenses and Material Licenses, including Holders of Certificates of Compliance, _Registrations, and Quality Assurance Program Approvals and Government Agencies Licensed by the NRC" establishes the authority for the collection of annual fees from those who possess a license issued under 10 CFR Part 40, 10 CFR Part 50, 10 CFR Part 52, 10 CFR Part 70, or 10 CFR Part 72. Additionally, there are costs associated with periodic NRC inspections conducted by the NRC Region IV.

HBPP license fees are split between Decommissioning, FSS and the HB ISFSI through the termination of the 10 CFR Part 50 license.

With the termination of the 10 CFR Part 50 license, the license fees associated with the HB ISFSI will be solely associated with the 1 O CFR Part 72 license, until the 10 CFR Part 72 license termination after the SNF and GTCC waste are removed from the ISFSI and the completion of the ISFSI FSS.

f.

ISFSI Removal Approximately two years before DOE is scheduled to remove the SNF and GTCC waste, PG&E will prepare and submit an ISFSI L TP for NRC approval. After the last SNF/GTCC waste cask is accepted by the DOE carrier, PG&E can request an exemption from the NRC of the 8-18

1 10 CFR Part 72 requirements and commence the decommissioning of 2

the HB ISFSI site.

3 The decommissioning and ISFSI site restoration will include 4

demolition of the buildings and the ISFSI Vault, FSR of the ISFSI site 5

and the building areas, and implementing the ISFSI L TP with FSS of the 6

ISFSI site and building areas. After the ISFSI FSS documentation is 7

reviewed and accepted by the NRC, PG&E will request termination of 8

the 10 CFR Part 72 license.

9

g. Transfer to DOE 10 PG&E assumes the DOE will begin taking the SNF and GTCC 11 waste packages in 2031. Once the DOE provides its schedule for 12 accepting the SNF and GTCC waste packages, PG&E will begin the 13 planning processes necessary to facilitate the transfer to the DOE.

14 There are five SNF casks and one GTCC waste cask to be transported 15 and removal is expected to take a little over a year (one cask in 2031 16 and five casks in 2032).

17 The planning phase for SNF and GTCC waste transfer is expected 18 to take six months to a year of effort prior to the transport to the DOE.

19 The 2015 DPR, Section 3.3.1.8.6 provides details related to planning 20 and facilitating the transfer of the SNF and GTCC waste to DOE 21 custody.

22 Once the DOE carrier has accepted the SNF or GTCC waste 23 shipment, it becomes the property-of the DOE and PG&E's 24 responsibilities for the SNF or GTCC waste is terminated.

25 F. Planned Schedule and Activities 26 Almost all of the decommissioning physical work was complete in 2018, with 27 FSR scheduled to complete in 2019. Despite innumerable challenges and risks, 28 PG&E has successfully maintained its decommissioning schedule.

29 In 2019, HBPP's Site Closure Department will complete FSS and will be 30 generating the last area reports and summary report to be submitted to the 31 NRC. In 2020, the LAR to terminate the license will be sent to the NRC and the 32 transmittal of FSS records will be processed to the RMS.

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1 In addition to FSS and FSS records closure, HBPP Site Closure will perform 2

administrative closeout during this 24-month period. Like many other aspects of 3

HBPP decommissioning, the administrative closeout will also be yet another 4

first-of-its-kind experience for both HBPP Management and the state of 5

California. PG&E will transfer control and stewardship of the HBPP site area 6

to the non-nuclear Humboldt Bay Generating Station (HBGS). As such, 7

the administrative closeout is anticipated to bring its own set of challenges 8

for PG&E.

9 HBPP Management will need to perform a number of activities. It is 1 o important to note that closure of the following activities and the retention of the 11 records thereof, must each adhere to its own unique and separate standards set 12 forth by federal regulations, California regulations, local regulations, nuclear 13 industry standards, PG&E's nuclear insurer, PG&E standards, PG&E's 14 commitments to the community and to the community's expectations. To meet 15 the administrative closeout needs, HBPP Management is planning to retain a 16 mixture of management-and clerical-level personnel who have experience with 17 the HBPP decommissioning and can accomplish the residual work. Anticipated 18 work during the two-year administrative period includes:

19 Work Package Closeout - Work packages will be verified to be complete 20 and accurate. The records will then be entered in the RMS for retention and 21 archiving, in accordance with the applicable regulations and requirements.

22 Radiological Records - All radiological records, such as surveys, radiation 23 work permits and dosimetry records must be verified complete and transmitted 24 to the RMS.

25 Industrial Hygiene and Environmental Sampling - All Industrial Hygiene and 26 Environmental Sampling and records will be verified complete and accurate, 27 then transferred to the RMS.

28 SNF and GTCC Waste Records - PG&E shall verify that all the records for 29 SNF, GTCC waste and associated packaging are complete per DOE standards 30 and retrievable. This is a long-term preparation for PG&E, as DOE standards 31 require specific documentation prior to acceptance of the SNF or GTCC 32 waste package.

8-20

1 Corrective Action Program - Incomplete SAP Notifications and outstanding 2

Corrective Actions from the project will be brought to closure or if required, 3

transferred to ISFSI or other intra-company organizations.

4 Procedure Termination or Transfer - HBPP procedures will be processed for 5

termination or transferred to HBGS.

6 Disposition of Permits - The disposition of the various agency permits 7

includes taking no action for permits that were never used, allowing permits 8

with sunset dates to expire and working with respective agencies to combine 9

requirements and apply those requirements to permits that will continue 10 past FSS.

11 Asset Recovery-HBPP Management will have to determine the processes 12 to evaluate the remaining tools, equipment, office equipment, office furniture and 13 supplies. The remaining assets will be sold, salvaged, scrapped or disposed.

14 Final As-Built Drawings - The CWC will prepare the final drawings and 15 applicable topography records, indicating the status of the site with the best 16 available information at the end of the project. The final drawings include 17 depictions of above-ground and below-grade piping, utilities, residual structures, 18 active monitoring systems and abandoned systems.

19 License Termination Support-HBPP Management will prepare for license 20 termination inspections and respond to Requests for Additional Information, 21 as required.

22 Preparation for NDCTP - HBPP Management will begin preparation for the 23 2021 NDCTP filing.

24 Residual Workload from All Applicable Stakeholders - There are a number 25 of unknowns associated with stakeholder expectations. HBPP Management has 26 made the utmost effort to maintain transparency about the status of project 27 execution and to keep open lines of communications with local regulatory bodies 28 and stakeholders. The amount and level of communication is expected to 29 diminish after site restoration is complete. However, local stakeholders will 30 continue to have an interest in the site for as long as SNF and GTCC waste is in 31 temporary storage at the ISFSI.

32 From 2021 onward, HBPP Site Management will be focused on ISFSI 33 Management. During this period, the ISFSI site will be managed by the DCPP 34 Nuclear Security and Emergency Services Department, until DOE removes the 8-21

1 SNF and GTCC waste. The removal of the SNF and the GTCC waste casks is 2

planned to commence in 2031, followed by the ISFSI decommissioning, ISFSI 3

FSS and license termination scheduled for 2033.

4 G. Decision Log 5

Commission Decision D.14-02-024 specified that PG&E maintain an 6

ongoing Decision Log to track its decision-making activities relative to HBPP 7

nuclear decommissioning activities. Items requiring documentation in that log 8

include decisions having the potential to affect any cost category by more than 9

10 percent, either positively or negatively. There have been no such decisions 10 made since the 2015 DPR.

11 H. Trust Disbursement Advice Letters 12 PG&E will continue to file annual Trust Disbursement advice letters for 13 HBPP which includes the information required by prior NDCTP decisions.

14 PG&E's most recent advice letter, Advice Letter 5239-E, was approved by the 15 Energy Division effective March 30, 2018.

16 I.

SAFSTOR 17 SAFSTOR was the initial form of decommissioning selected by PG&E for 18 HBPP. The NRC regulatory requirements for SAFSTOR include routine and 19 specific radiological surveys, training and qualification of RP personnel 20 performing surveys, routine reporting to the NRC, maintenance of the 21 Radiological Effluent and REMP, and implementation of a radiation safety 22 program to comply with 10 CFR Part 20 regulations and applicable NRC 23 guidance documents. PG&E has recovered SAFSTOR expenses through a 24 separate revenue requirement updated in each NDCTP.

25 When PG&E decided to commence the active decontamination and 26 dismantlement phase of decommissioning, the SAFSTOR regulatory 27 requirements continued to be maintained by the RP Department. In the 2015 28 NDCTP filing, annual revenue requirements for SAFSTOR were adopted for 29 2017-2019; the Commission approved revenue requirement for SAFSTOR for 30 2019 is $4.4 million (nominal$). Termination of the 10 CFR Part 50 license will 31 terminate the need to maintain SAFSTOR regulatory requirements, and PG&E 32 proposes to cease collecting funds for SAFSTOR in 2020. Since the 2019 8-22

1 annual revenue requirement has already been adopted, this DCE includes no 2

SAFSTOR estimate.

3 J.

Conclusion 4

PG&E requests that the Commission adopt the decommissioning cost 5

estimate for HBPP as set forth in this chapter.

8-23

li<'.truc J,trminJtion/Y-~50-.~r.*&ht lkense TerminationSUl\\-ev(hcludesCaisson)

• RemillnderolPbntSyst,ms/PG&ECMIWorlaSUpport OimtLabor(PG&Eal'ldContractor) liquidRildwasteSystem Tools& Equipment FSSTools & Equ:pm~r.l OISil!owedScope(SelsmlcUP5rades)

"Spedlk ProJertCosu RtaclorVem1Remova11 TurbineBldg. Demolition(Contractor)

~riJI S, teRc:.1on1,on OthtrServ'.ces/ LetterofCredit DinllowedScope!SeismicUpgrades)

"WuttOlspoul Labor(PachgingandHandling}

Third Party Disposal Sitts WasteHandfog8111ding(Contracto1)

Disa11owedScope(StismicUpgrades)

SmallOollarVendor1 Specialty Contracts fooh&E~~er.t SpentFuelMana1ement Secooty (PG&E)

ISfSIStaffing/ Engineering /SptcialtyContracts ISfSJlnfrastructurebpenses Transfer to DOE Field\\Vork(CivilWo,ksContmt)

Project Staffing WasteD!sposal LlcenselermlnatlonSIJl"\\'tV Tools and Supplies Other Specialty Contracts Removal(CM1WorksContract}

Disposal ReslJuJI R~ mt"Jlll on/\\'.'J~t~ [h:r,o:.il

• eommoo Site Support -Caiuonair\\d ca.nab RelocationofTrailerGtv GrolK"ldwaterTrtatment5ystemOperation

'fPC SeMm(lndudln1 QuaityTn1ninf:)

Subtotiluiison /carul /GWTS TOTAL2015*20l0 Total Including spend priorto2012N0CTP

• o osedout Blue Unl'S

l. Bud1rt lndudet Conlbi&ericv l. Reado, Wml Remov.il/us * <red11 of $736 In columl'I H TABLE 8-2 HBPP DECOMMISSIONING COST BREAKDOWN 6,5-lllS-O 7,671,86!1 9.. JH,13~

12,695,241 16,508,6]9 17,1-43,713 13,347,279 3,796,03 17,143,713 17,1-0,713 59,998,149 48,431,565 48,581,707 48,376,707 48,376,707 43,748,081 4,628,626 34,634,453 35,007,658 35,1 2-4,9-45

~.919,944 34,919,944 ll,lll,080 2,696,86-4 7,127,430 4,282,ni 4,282,774 4,282,77-4 4,282,774

,282,774 18,236,266

!OJ)l,55-l 10,457,339 9,573,989 883J5-0 10,457,339 7,642,227 1,931,762 883,350 (6Jl,Jl0J IBallSOI i!oJJIOI (S33,35-0)

(S8l,3:0J (400,000)

(400,000)

(400,000)

(-I00,000)

(400,000) 3,246,534 4,935,540 4,935,540 4,935,540 4,935,SCO 4,935,540 98,596,847 10l,780,6J7 106,841,555 107,578,702 107,578,702 29,002,996 78,575,706 15,896,279 16,956.917 17,003,018 16,983,379 16~8lJJ9 16,984,115

)736) 14,370,353 12,118,881 12,118,881 12,118,881 12,118,881 12,118,881 80,152,232 75,024,()60 78.(W8,337 78,669,240 78,669,240 78,669,240 66,718,122 69,817,635 72,-478,394 75,950,216 75,950,216 75,950,216 1,612,093 1,992,-479 2,168,191 2,227,6-45 2,127,6-45 2,227,645 11,822,016 37,253,566 40,-412,905 28,281,-491 12,131,4U 40,412,905 40,412,905

\\l l.'12J0J6) 1)7,25),5£&)

(2l4,23 l,4911 f40Jl1.90SJ 3,213,946 3,401,752 491.379 491.379 91,3 7 9 (119,lll) lll8,68l)

(192,798)

(192,798)

(100,000)

(92,798) 76,347,441 86,825,016 90,801,787 90,765,193 90,765,193 50,041,157 40,724,016 19,679,147 13,()95,21 13,188,720 ll,11U86 13,114,586 13,114,586 51~20.&IO 69,991,255 73,874,727 73,912,267 73,912.267 33,188,231 40,724.036 2,747,654 3,765,430 3,765,430 3,765.430 3,765,430 3,765,430 (17,090)

(27,090)

(27,090)

(27,090)

(27,090) 47,690,392 77,575,353 81,979,921 60,909,891 81,979,920 21,575,949 11,052,452 49,351,520 10,885,349 4,669,502 4,787,410 4,438,923 348,487 4,787,410 2,680,883 1,758,0-40 348,487 24,983.026 33.010.318 33,811,551 2s,1s9.4n 5,622.074 33,811,551 18,895,065 9,294,412 5,622,07 11,SV.016 37,251.SUi 40.Ul905 12.131,4U 41),412,905 9CJ973 1.0S7.709 1.037,709 1,037,709 l,lJ37,7oc.!

996,996 996.996 151,425,840 165,201,692 41,994,130 123,207,562 165,201,692 14,279,397 27,714,733 25,067,582 51,546,006 101,820,420 111.078,664 33, 173,1 7 77,905,517 111,078,664 11,235,555 21,937,592 77,905,517 20,208,927 8,505,931 9,863,067 10,634,509 3,544,823 7,089,686 10,634,509 1,632,172 1,912,651 7,089,686 1,823,.<<)5 3,224,018 9,103,600 9,742,63 2,967,003 6,775,59 9,742,463 1,089,192 1.877,811 6,ns,459 1,675,381 10,()96.960 10,875,464 1,889,723 8,9 85,71 10,875,464 77,231 1,811,492 8,985,741 356,997 3,166,980 3,496.605 J,83.1,595 419,433 3,415,162 3,83',595 245,246 174,187 3,415,162 1,002,873 2,155,6-U 13,712.201 15.368,552 15,368,552 15,368,552 15,368,552 JJll.787 3,667,446 3,667,446 3,667,'46 3,667.-'46 459,614,695 591,186,932 619,431,070 462,478,363 157,448,259 619,926,622 230,015,943 190,833,650 199,077,028 25,067,582 202,326,010 141,871,637 151,125,624 lSl,010,115 151,010,llS 151,010,llS 120,595,389 86,383,087 90,599,420 89,807,911 89,807,911 89,807,911 llA6l,2'4 17,643,186 18,869,164 13,231,648 13,231,648 13,231,6-48 JJ,966,818 2lJll.03' 26,205,862 35,092,897 15,091,897 35.092,897 6,548,881 4,189,348 4,486,368 5,398,254 5,398,254 SJ98,l54 lA65J51 1,253,037 1,301,563 763,662 763,662 763,662 7,l86Jl7 9,089,943 9,663,248 6,715,743 6,715,743 6,715,743 480,514 1,338,207 1,425,435 1,498,091 1,498,091 1,498,091 6,429,029 864.504 92S,740 227,505 227,SOS 227,505 376,784 6,887,232 7,312,073 4,990,147 4,990,147 4,990,147 51,284,882 51,716,975 54,243,720 47,049,798 47,049,798 47,049,798 lS,649JSl 40.061,lll 41.37U75

.ffl,474,305 40,474,305 40,H4,305 l5,6ll,Sl9 12,560,726 13,957,053 6,575,493 6,575,493 6,575,493 (l.087.709) 6,021,784 4,804,455 4,865,608 4,821,953 4,821,953 2,391,776 2,430,176 l,208J79 2,720,298 l.86M99 1,816,903 996~96 1,816,903 996,996 (90S,57!)

(9~(,.9%)

(:hu,9Sfi)

(9:,(.,9%)

!'i9699ul J,ol0,620 2,684,10-I 2.692,355 2,698,699 2,698,699 lJ91,776 306,921 792,786 305,626 306,350 306,110 306.350 306,150 10,469,693 10,980,931 8,850,788 8,850,788 8,850,788 3,924,982 9,651,929 10,117,403

),5]8,]56 7,Sl8J56 7,538,356 723,172,353 800,049,692 840,6.:6,952 674,2.11,017 157,448,259 Bll,659,275 232,.407,720, E=

199,ffl,021 _

IIIID!:DIIIID!:DIIIIE!!!!IIIEl!:.l!!!l--lllllll!!mm 977,922,454 1,054,799,193 1,095,397,053 928,961,118 157,448,259 1,086,409,376 -

4!6,151,309 400,1~,677 ~~

,:.it,i03tzoiiEs,~.~~>T**~~* *t -*tit" :':~1'~:00"'.':ssii TolalSpend/Fore,asl 1,1 11,476,958

• c1ostd0UtCostCatrco,ySavlncs (1,917,677)

Additlona1Funding Requestedfor2031*2033 (TotalSpend/Forecast*ApprovedBudget) 8-24 16,079,901