ML19311C711

Public Watchdogs - NRC 2.206 Petition Exhibits 1-38, Part 11

ML19311C711
Person / Time
Site:	San Onofre
Issue date:	09/23/2014
From:	Public Watchdogs
To:	Division of Decommissioning, Uranium Recovery and Waste Programs
Cruz Z
Shared Package
ML19311C699	List: ML19311C700 ML19311C701 ML19311C702 ML19311C703 ML19311C704 ML19311C705 ML19311C706 ML19311C707 ML19311C708 ML19311C710 ML19311C711 ML19311C713 ML19311C714 ML19311C715 ML19311C716 ML19311C717 ML19311C718 ML19311C720 ML19311C721 ML19311C722 ML19311C723 ML19311C724 ML19311C725 ML19311C726 ML19311C727 ML19311C728 ML19311C729 ML19311C730 ML19311C731 ML19311C732 ML19311C733 ML19311C734 ML19311C735 ML19311C736 ML19311C737 ML19311C738 ML19311C739 ML19311C740
References
Download: ML19311C711 (136)

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• GTCC Disposal - Under the DOE Standard Contract, the DOE is obligated to accept 2 and dispose of spent nuclear fuel and high level waste. The courts have 3 determined that GTCC is high level waste, which DOE is obligated to accept and 4 dispose of under the DOE Standard Contract, but have stated that that does not mean 5 that the government will have to bear the cost of GTCC waste disposal alone.

6 The courts have not provided a disposal cost.35 7

• Cyber Security Modifications - Under 10 C.F.R. § 73.54, SCE was required to 8 develop a cyber security plan that addressed eight milestones to ensure certain digital 9 assets, such as computer and communication systems and networks, are secure and 10 protected.

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• California Environmental Quality Act (CEQA) - Under CEQA, the CSLC, as lead 12 agency, is required to evaluate the SONGS decommissioning project and prepare an 13 Environmental Impact Report (EIR) in response to SCEs application to modify and 14 extend the existing CSLC lease regarding the offshore conduits. The CEQA process 15 began in 2015. The CSLC is expected to certify the EIR in late of 2018. The CCC is 16 then expected to review an application for a CDP for SONGS decommissioning based 17 on the EIR, as well as its own additional analysis. The CCC is expected to consider 18 SCEs CDP application by the end of 2018. Following the receipt of the CDP, 19 physical decommissioning of the plant can proceed.

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• Mesa Site Turnover - SCEs Mesa lease from the Navy consists of five parcels.36 21 Parcel 5 is on the west side of U.S. Interstate Highway 5 (I-5) and includes a security 22 station to control access to Parcels 6 and 7. Parcels 6 and 7 are located on the east 23 side of I-5 and along with Parcel 5 comprise the area known as the Mesa site. Parcels 24 8 and 9 include a parking lot and lay-down area on the west side of I-5 and abut the 25 SONGS site. SCE currently estimates that Parcels 5, 6, and 7 will be returned to the 35 Yankee Atomic Electric Co. v. U.S., 536 F.3d 1268, 1278 (Fed. Cir. 2008).

36 See Appendix E for map of the parcel locations.

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1 Navy in 2021, and Parcels 8 & 9 will be retained until the end of decommissioning.

2 As part of the process to return Parcels 5, 6, and 7 to the Navy, SCE must first assess 3 the property and remediate SONGS-caused contamination to the extent necessary to 4 obtain No Further Action Letters from the California Department of Toxic 5 Substances Control (DTSC) indicating the property is available for unrestricted use.37 6

• Substructure Removal Contractor Procurement - In 2044, SCE will begin efforts to 7 procure a contractor for the removal of SONGS substructures and placement of 8 permanent backfill. Because the dewatering, shoring, excavation, removal, and 9 backfilling of the substructures will be a very large and specialized work scope, SCE 10 will incur the cost to undertake a competitive procurement process to identify and 11 select a specialty vendor to perform this work.

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• Coastal Development Permit Extensions - SCE holds a CDP for the storage of 13 SONGS 2&3 spent fuel in the Areva ISFSI system until November 2022, and a 14 separate CDP to store SONGS 2&3 spent fuel in the Holtec ISFSI system until 2035.

15 Therefore, the 2017 DCE assumes SCE will need to obtain CDP extensions from the 16 CCC for the Areva and Holtec ISFSI systems prior to the expiration of the permits in 17 2022 and 2035, respectively.

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• ISFSI Coastal Development Permit (CDP) Settlement - In August 2017, SCE reached 19 a settlement agreement with parties who challenged the CDP, wherein SCE agreed to 20 incur up to $4.3 million (100% share, 2014 $) on commercially reasonable efforts to 21 identify an offsite location for SONGS spent fuel storage.

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• Future DCE Updates - Under the Decommissioning Act, SCE is required to 23 periodically revise the DCEs to include descriptions of changes in regulation, 24 technology, and economics affecting the estimate of costs; and of additions and 37 On April 24, 2017, the DTSC issued a No Further Action Letter for Parcel 5. The efforts to assess and remediate contamination for Parcels 6 and 7 are ongoing. SCE continues to hold Parcel 5 because it provides access to Parcels 6 and 7.

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1 deletions to nuclear facilities.38 SCE submits such DCE updates to the Commission 2 in NDCTP proceedings.

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• North Industrial Area (NIA) Sump Modifications - The NIA sump (located on the 4 site formerly occupied by SONGS 1) currently discharges to the SONGS 2&3 5 dilution water system. The SONGS 2&3 dilution water system will be retired by 6 SDS, and therefore the discharge pathway for the NIA sump will need to be modified.

7 The estimated costs for the Other Distributed Projects category are shown in Table IV-4 8 below:

Table IV-4 Reconciliation of 2017 DCE to 2014 DCE Other Distributed Projects (100% Share, Millions of 2014 $)

2017 DCE 2014 DCE Total Total Description (2014 $) (2014 $) Variance 1 Other Projects 2 GTCC Disposal $ 40.7 $ 50.6 $ (9.9) 3 Cyber Security Modifications 9.4 1.9 7.5 4 CEQA 7.9 2.7 5.2 5 Mesa Site Turnover 20.3 17.8 2.6 6 Previously Included Project Subtotal $ 78.3 $ 72.9 $ 5.4 7

8 Substructure Removal Contractor Procurement $ 7.0 $ - $ 7.0 9 Coastal Development Permit Extensions 5.2 - 5.2 10 ISFSI CDP Settlement 4.3 - 4.3 11 DCE Update 3.7 - 3.7 12 NIA Sump Modifications 1.1 - 1.1 13 New Projects Subtotal $ 21.3 $ - $ 21.3 14 Other Projects Total $ 99.6 $ 72.9 $ 26.7 9 The total estimated cost for these Other Distributed Projects in the 2017 DCE is 10 $99.6 million (100% share, 2014 $). The estimated cost for such Other Distributed Projects in the 2014 11 DCE was $72.9 million (100% share, 2014 $). Thus, the 2017 DCE includes a $26.7 million increase 12 for the Other Distributed Projects category.

38 Pub. Utilities Code § 8326.

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1 After the development of the 2014 DCE, SCE determined that the cost to complete 2 several of its Other Distributed Project work scopes would be different than estimated in 2014. For 3 example, in the 2014 DCE SCE estimated that the disposal cost for GTCC waste would be $50.6 million 4 (100% share, 2014 $) based on the highest published disposal rates for Class C low level radioactive 5 waste (LLRW). In the 2017 DCE, however, SCE assumed that the disposal cost for a canister of GTCC 6 waste would be comparable to the disposal cost for a canister of spent fuel. This resulted in an estimated 7 GTCC disposal cost in the 2017 DCE of $40.7 million39 (100% share, 2014 $), a decrease of $9.9 8 million.

9 With respect to Cyber Security-related work, the 2014 DCE included $1.9 million (100%

10 share, 2014 $) and assumed the work would be completed in 2013. At that time, SCE believed that after 11 SCE submitted the certifications of permanently ceased operations for SONGS 2&3, SCE would no 12 longer be subject to the cyber security requirements of 10 C.F.R. § 73.54. However, SCE subsequently 13 determined that the SONGS Cyber Security Plan was still required because it was described in the 14 Physical Security Plan License Condition for SONGS 2&3. Other decommissioning plants had sought 15 an exemption from the cyber security requirements, but the NRC had not yet approved those requests.

16 It was prudent for SCE to wait for the NRC to review these requests and provide further guidance prior 17 to SCE submitting an exemption request so as to avoid any protracted delays in the NRCs review 18 process. In the meantime, SCE was obligated to comply with the requirements related to performing 19 cyber security assessments, but not the more costly implementation aspects of the requirements.

20 When the NRC indicated a willingness to grant such exemption requests, SCE submitted a License 21 Amendment Request (LAR) to the NRC in June 2017, wherein SCE requested removal of the 22 requirement to fully implement the SONGS Cyber Security Plan. At the end of 2017, the NRC granted 23 approval for SONGS to remove the cyber security license condition, thus waiving the implementation 24 requirements. Prior to the NRCs granting of the exemption, SCE had expended $9.4 million40 (100%

39 See 2017 DCE, Appendix C, Table 2, line 188.

40 See 2017 DCE, Appendix C, Table 2, line 191.

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1 share, 2014 $) to implement cyber security assessments. SCE included this recorded amount in the 2017 2 DCE, resulting in a $7.5 million increase over the amount estimated in the 2014 DCE.

3 With respect to the CEQA project, the 2017 DCE forecast $7.9 million41 (100% share, 4 2014 $). The 2014 DCE forecasted this major project at $2.7 million (100% share, 2014 $), resulting in 5 an increase of $5.2 million. The increase occurred because the time and effort required to complete this 6 activity were greater than assumed during the development of the 2014 DCE. Specifically, SCE 7 originally anticipated the CEQA review would be completed in approximately one year. Given the 8 complexity of and varied interests (Navy, local communities, environmental advocates) that must be 9 considered, SCE now anticipates that it will be nearly a four-year effort. SCE underestimated the level 10 of effort necessary to complete the CEQA review, resulting in the variance. This activity is required in 11 order to begin D&D.

12 With respect to Mesa Site Turnover project, the 2017 DCE forecast $20.3 million42 13 (100% share, 2014 $). The 2014 DCE forecasted this major project at $17.8 million (100% share, 2014 14 $), resulting in an increase of $2.6 million. The increase occurred because the time and effort required 15 to complete this activity were greater than assumed during the development of the 2014 DCE.

16 Specifically, SCE originally expected to return the property to the Navy in 2017 with limited 17 environmental characterization. Subsequently, the Navy imposed stringent remediation standards for 18 the property requiring more extensive characterization and remediation, so turnover is now expected to 19 occur in 2021. SCE must comply with the Navys requirements.

20 The remaining Other Distributed Projects were not included in the 2014 DCE because 21 their scopes emerged after the 2014 DCE was developed. SCE estimated their costs as follows:

22 Substructure Removal Contractor Procurement - The 2017 DCE includes costs of 23 $7.0 million43 (100% share, 2014 $) for a competitive bidding process to select a substructure removal 24 contractor, including the development of a Request for Proposal, proposal evaluation, and contract 41 See 2017 DCE, Appendix C, Table 2, line 184.

42 See 2017 DCE, Appendix C, Table 2, line 178.

43 See 2017 DCE, Appendix C, Table 2, line 190.

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1 award. The estimate is approximately one-half the cost to procure a DGC for the major D&D work 2 because the scope of this effort is nearly half the scope of the DGC D&D work.

3 Coastal Development Permit (CDP) Extensions - The 2017 DCE includes costs of 4 $5.2 million44 (100% share, 2014 $) for SCE to obtain extensions for the Areva and Holtec CDPs.

5 SCE holds a CDP to construct and operate the Areva ISFSI to store SONGS 2&3 spent fuel until 6 November 2022, and a separate CDP to construct and operate the Holtec ISFSI to store SONGS 2&3 7 spent fuel until 2035. The 2017 DCE assumes SCE will need to obtain CDP extensions from the CCC 8 for the Areva and Holtec ISFSI systems prior to the expiration of the permits in 2022 and 2035, 9 respectively. SCE considered the recorded costs from past CDP applications and the complexities of the 10 anticipated issues that will require evaluation in these two CDP extensions to estimate the cost to obtain 11 these two CDP extensions.

12 ISFSI CDP Settlement - As part of the ISFSI CDP Settlement, SCE agreed to incur up to 13 $4.0 million (100% share, nominal $) on commercially reasonable efforts to identify an offsite location 14 for SONGS spent fuel storage. SCE also included $0.3 million (100% share, nominal $) for SCE 15 outside counsel legal costs to reach the settlement.45 SCE also included $0.8 million (100% share, 16 nominal $) for attorneys fees to plaintiffs counsel, as agreed to in the settlement.46 This $5.1 million 17 (100% share, nominal $) increase was unforeseeable at the time the 2014 DCE was developed.

18 This cost category was shared between SONGS 1 and SONGS 2&3. The amount allocated to SONGS 19 2&3 is $4.3 million (100% share, 2014 $). The settlement allowed SCE to proceed with transferring 20 fuel to the ISFSI. It is also reasonable for SCE to explore offsite locations for the storage of spent fuel.

21 Future DCE Updates - SCE assumes a cost of $3.7 million47 (100% share, 2014 $) to 22 develop future DCE Updates because SCE now assumes that it will use a third-party vendor to develop 44 See 2017 DCE, Appendix C, Table 2, line 167.

45 Given the ongoing analyses and the current uncertainty regarding the potential location and requirements for an acceptable alternative spent fuel storage site, the estimated cost to re-locate the SONGS 2&3 spent fuel to an alternative site are speculative and have not been included in the 2017 DCE.

46 Under the California Civil Procedure Code, a prevailing plaintiff in a mandamus proceeding is entitled to seek recovery of attorneys fees. See Cal. Civ. Proc. Code § 1021.5.

47 See 2017 DCE, Appendix C, Table 2, line 182.

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1 the DCE Updates instead of preparing them in-house at an average cost of approximately $0.3 million 2 (100% share, 2014 $) per update. Under the Decommissioning Act, SCE is required to periodically 3 revise the DCEs and submit them to the Commission.

4 NIA Sump Modifications - The North Industrial Area (NIA) sump currently discharges 5 to the SONGS 2&3 dilution water system. Because SDS will remove the dilution water system, the 6 discharge path for the NIA sump must be modified. SCE provided an estimated cost of $1.1 million48 7 (100% share, 2014 $) for this work scope.

8 Relative to the 2014 DCE, the cost increases for Other Distributed Projects described 9 above are partially offset by the lower estimated cost to dispose of GTCC waste, and result in a net 10 increase of $26.7 million (100% share, 2014 $). The Commission should find the increased estimated 11 costs for the Other Distributed Projects reasonable because each of these projects is required to fulfill an 12 unavoidable regulatory requirement or a contractual obligation.

13 7. Greater Than Class C (GTCC) Waste Storage 14 In the 2017 DCE, SCE assumes that it will be required to license and purchase ten new 15 canisters for storing and disposing of GTCC waste from SONGS 2&3 D&D activities and will use two 16 existing Areva canisters for storing GTCC waste from the spent fuel pools. In contrast, SCE assumed in 17 the 2014 DCE that it would use the ten Areva canisters that were originally fabricated for storing and 18 disposing spent fuel from SONGS 2&3. SCE made this change because, although the ten Areva 19 canisters are licensed for storing and transporting spent fuel, they are not licensed for transporting 20 GTCC waste.49 Although the radiological and physical characteristics of spent fuel would seem to 21 bound those of GTCC waste, SCE determined that the canisters may only be used for their intended (and 22 licensed) purpose, and that they would need to be re-licensed before they could be used to store and 23 transport GTCC waste. Because most of the GTCC waste generated at SONGS 2&3 will come from the 24 reactor vessel internals segmentation project, which is scheduled near the beginning of D&D activities, 25 and the time required to re-license the Areva canisters is uncertain, SCE determined that it would be 48 See 2017 DCE, Appendix C, Table 2, line 192.

49 The canisters can be used to store GTCC waste as long as the canister does not need to be modified. For these ten canisters, the canisters would need to be modified to store the GTCC from D&D activities.

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1 imprudent to risk an unknown delay to the D&D schedule by allowing it to be constrained by an effort 2 to re-license the Areva canisters. SCE determined that it would instead be more prudent to avoid such 3 schedule uncertainties by obtaining ten new canisters that would already be licensed to store and 4 transport GTCC waste.

5 The estimated cost for GTCC storage in the 2017 DCE is $26.6 million (100% share, 6 2014 $). The 2014 DCE did not include any costs for GTCC storage. This resulted in a cost increase of 7 $26.6 million50 (100% share, 2014 $). Nevertheless, the Commission should find this estimated cost 8 increase reasonable because it will reduce the risk of substantially greater costs due to potential project 9 delays resulting from a delay to re-license the Areva canisters for GTCC waste storage and disposal.

10 8. Plant Easement/Lease Renewals 11 SCE uses the land upon which the SONGS site is located pursuant to a grant of easement 12 executed with the Navy in 1964. This easement expires in 2024. The Navy has informed SCE that the 13 existing easement will not be renewed because the terms are outdated; therefore, a new real estate 14 authorization will be negotiated. SCE anticipates that the new real estate authorization will: (1) modify 15 land boundaries to exclude roads used by the public, exclude lands within the current easements that 16 SCE does not use, include Parcels 8 and 9, and include lands that SCE occupies that are not within the 17 current easements; and (2) include pricing that is consistent with the current fair market rental value of 18 the property. The Navy will be required to perform a limited-scope NEPA review to issue this new real 19 estate authorization. The public interest in the Navys decision, mostly due to on-site spent fuel storage, 20 may impact the extent of the Navys NEPA review effort.

21 Due to the uncertainty of how long the spent nuclear fuel would be on-site and the 22 potential for relocation of the ISFSI in 2035, the 2017 DCE conservatively assumes that SCE will have 23 to negotiate real estate authorizations with the Navy two additional times. Therefore, the next real estate 24 authorization will expire in 2035, requiring SCE to seek a renewal. It is assumed the terms and site use 25 will remain the same, and that the term will also be 10 years. Thus, the cost for this effort is estimated 26 to be less than for the previous negotiation. This effort will also require a limited-scope NEPA review.

50 See 2017 DCE, Appendix C, Table 2, line 169.

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1 When the real estate authorization needs to be renewed again in 2045, SCE will request 2 the Navy to specify the final site restoration and substructure removal requirements. SCE currently 3 plans to commence this effort in 2040, such that the real estate authorization renewal and final site 4 restoration and substructure removal requirements would be in place by 2045. This would facilitate 5 performing the Substructure Removal civil works project during 2046-2049; and ISFSI 6 decommissioning, NRC license termination, and final site restoration during 2050-2051. Because this 7 real estate authorization renewal will identify the conditions under which the land will be returned to the 8 Navy, the Navy will be required to perform a more robust NEPA review.

9 In the 2017 DCE, the estimated cost for Plant Easement/Lease Renewals is $27.1 10 million51 (100% share, 2014 $). In the 2014 DCE, the estimated cost was $1.4 million (100% share, 11 2014 $). This results in an increase of $25.7 million. The 2017 DCE includes costs for SCE labor, 12 contract support, Navy costs (such as consultations/review hours), surveys and mapping for three 13 distinct real estate authorizations and three corresponding NEPA reviews. At the time the 2014 DCE 14 was developed, discussions between SCE and the Navy had not yet progressed to that point that the need 15 for three such updates to the Navy real estate authorization and three NEPA reviews was identified.

16 Because each of these updates to the Navy real estate authorization and any 17 corresponding NEPA reviews will be required: (1) for SCE to fulfill the Navys requirements for 18 ongoing use of the SONGS site until SCE is ready to relinquish the land; (2) for the Navy to 19 appropriately analyze and identify the final site restoration requirements; and (3) for SCE to implement 20 the site restoration requirements to the satisfaction of the Navy, these Plant Easement/Lease Renewal 21 costs are necessary decommissioning costs. SCE based the estimate on its recent history negotiating real 22 estate matters with the Navy, as well as the costs incurred to date for SONGS real estate authorizations.

23 Recent history with the Navy regarding the Mesa lease and the switchyard indicates that SCEs 24 negotiations with the Navy will involve a lengthy and more complex undertaking than assumed in the 25 2014 DCE. The Commission, therefore, should find that these estimated costs are reasonable.

51 See 2017 DCE, Appendix C, Table 2, lines 185-187.

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1 9. Offshore Conduits Removal 2 The 2017 DCE includes an estimated cost to perform the full removal of the 3 SONGS 2&3 offshore conduits as estimated in the 2014 DCE.

4 The 2017 DCE includes $91.6 million52 (100% share, 2014 $) to fully remove the 5 SONGS 2&3 offshore conduits. In the 2014 DCE, the estimated cost was $96.0 million (100% share, 6 2014 $). This results in a decrease of $4.4 million. This decrease occurred because the estimated value 7 in the 2014 DCE includes a 5% adder for A&G, whereas the A&G adder is excluded from the 2017 8 DCE estimated value.

9 10. ISFSI Demolition 10 Following the removal of all spent fuel and GTCC waste by the DOE, SCE will demolish 11 and remove the ISFSI and perform activities necessary for the final restoration of the SONGS site.

12 The 2017 DCE includes $19.2 million53 (100% share, 2014 $) for ISFSI 13 decommissioning costs. In the 2014 DCE, the estimated cost was $21.1 million (100% share, 2014 $).

14 This results in a decrease of $1.9 million. At the time the 2014 DCE was prepared, the specific plans to 15 expand the ISFSI had not been defined. Later in 2014, SCE entered into a contract with Holtec to 16 expand the ISFSI. The ISFSI demolition cost in the 2017 DCE is based on a new estimate completed by 17 High Bridge Associates and reflects both the Areva and Holtec ISFSIs.

18 11. Completed Projects 19 During the period between the permanent retirement of SONGS 2&3 on June 7, 2013, 20 and December 31, 2017, SCE completed several Distributed Projects. The following completed projects 21 are some of those already submitted to the Commission for reasonableness review:

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• Included in 2014 reasonableness testimony: (1) Development of the Certified Fuel 23 Handler Program; (2) Post-Fukushima Modifications; (3) Independent Spent Fuel 24 Storage Installation (ISFSI) Pad Study; and (4) Spent Fuel Pool Analyses.54 52 See 2017 DCE, Appendix C, Table 2, line 229.

53 See 2017 DCE, Appendix C, Table 2, line 241.

54 The SONGS 2&3 Distributed Projects completed during 2014 are explained in greater detail in A.16-03-004, Exhibit SCE-09 at pages 18-21.

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1

• Included in 2015 reasonableness testimony: (1) Nuclear Fuel Contracts 2 Cancellations; (2) Legacy Radwaste Disposal; (3) Security Programs - Security 3 Shutdown Strategy; (4) Regulatory Submittals; (5) Historical Site Assessment/Site 4 Characterization; and (6) Transition Project Modifications - Special Purpose Vehicle 5 (SPV) Feasibility Study.55 6 The following completed projects are being submitted for reasonableness review in this 7 proceeding:

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• Major Projects completed during 2016-2017: (1) the Spent Fuel Islanding project; 9 (2) Selection of Decommissioning General Contractor; and (3) Transition Project 10 Modifications, including the Large Organism Exclusion Device Modification, Special 11 Purpose Vehicle - Implementation, Records Retention Project, and the Simplification 12 and Streamlining Project.56 13 The following completed activity will be submitted for reasonableness review in the 2021 14 NDCTP:

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• Defueled Safety Analysis Report (DSAR): Updates the current licensing basis for the 16 decommissioning configuration state of SONGS 2&3 and is a reference available for 17 reviewing decommissioning actions and plans affecting the SONGS 2&3 site.

18 The estimated costs for the Completed Projects are shown in Table IV-5 below:

55 The SONGS 2&3 Distributed Projects completed during 2015 are explained in greater detail in A.16-03-004, Exhibit SCE-08 at pages 26-39, and in Exhibits SCE-10 and SCE-10C.

56 The SONGS 2&3 Distributed Projects completed during 2016-2017 are explained in greater detail in A.18-03-XXX, Exhibit SCE-05.

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Table IV-5 Reconciliation of 2017 DCE to 2014 DCE Completed Projects (100% Share, Millions of 2014 $)

2017 DCE 2014 DCE Total Total Description (2014 $) (2014 $) Variance 1 2014 Reasonableness Review $ 0.6 $ 0.6 $ (0.0) 2 2015 Reasonableness Review 93.5 76.8 16.7 3 2018 Reasonableness Review 27.2 19.2 8.0 4 Future Reasonableness Reviews 2.0 1.5 0.5 5 Completed Projects Total $ 123.3 $ 98.1 $ 25.2 1 The total estimated cost for these Distributed Projects, as reflected in the 2017 DCE, was 2 $123.3 million57 (100% share, 2014 $). In the 2014 DCE, the total estimated cost for the SONGS 2&3 3 decommissioning-related Completed Distributed Projects completed during 2013-2017 was $98.1 4 million (100% share, 2014 $), resulting in a variance of $25.2 million more than estimated.

5 The explanations for the variances associated with each of these Distributed Projects are provided in the 6 testimony SCE provided to the Commission in its reasonableness review submittals for each of these 7 completed projects. The 2014 and 2015 completed projects are not being reviewed in this proceeding.

8 C. Undistributed Activities 9 1. Contracted Services 10 Contracted Services are shorter-term supplemental resources, specialty contractors and 11 consultants, third-party services, materials, and supplies that are provided on an as-needed basis to 12 support SONGS. SCE must meet several NRC regulatory requirements,58 and maintain and operate 13 SONGS to support spent nuclear fuel in the spent fuel pools and ISFSI. SCE also must meet contractual 14 obligations and provide support services (such as engineering, regulatory, financial, and custodial 15 services) for the plant and the general facility,59 as well as provide basic office services, to complete 57 See 2017 DCE, Appendix C, Table 2, lines 1, 12, 15, 18, and 24.

58 See Exhibit SCE-01, Section 1.F.2.a, Nuclear Regulatory Commission Requirements.

59 The general facility includes SONGS office buildings, roads, parking lots, fencing, lighting, and all the services necessary to maintain the site in a condition suitable for all the activities that are needed to decommissioning the plant.

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1 decommissioning planning and implement decommissioning. SCE utilizes Contracted Services for 2 these purposes.

3 Contracted Services in the 2017 DCE consists of two distinct types of costs, recorded and 4 estimated:

5 3/4 June 2013-2017 recorded costs of $83.7 million (100% share, 2014 $) equaling an 6 approximate annual average of $18.6 million (100% share, 2014 $);60 and 7 3/4 2018-2051 estimated costs of $141.5 million (100% share, 2014 $) reflecting an 8 approximate annual average of $4.2 million (100% share, 2014 $).

9 The estimated cost for Contracted Services for 2018-2051 includes support activities for 10 the organizations shown in Table IV-6 below.

Table IV-6 Contracted Services (100% Share, Millions of 2014 $)

2017 DCE Annual 2018-2051 Average Over Total 2018-2051 Description (2014 $) (2014 $)

1 Contracted Services (2018-2051) 2 Decommissioning Oversight $ 50.9 $ 1.5 3 Maintenance and Work Control 31.3 0.9 4 Nuclear Regulatory Affairs and Nuclear Oversight 22.7 0.7 5 Site Engineering 13.8 0.4 6 Site Management & Administration 10.7 0.3 7 Emergency Preparedness 6.3 0.2 8 Decommissioning Finance 4.8 0.2 9 Operations 1.0 0.0 10 Contracted Services (2018-2051) Total $ 141.5 $ 4.2 11 SCE discusses each of these below:61 60 Recorded costs during 2014-2015 were reviewed for reasonableness in the 2015 NDCTP, A.16-03-004.

Recorded costs during 2016-2017 have been submitted for reasonableness review in this proceeding.

See Exhibit SCE-05.

61 Each of these organizations also incurs common costs for items such as employment related training, office supplies, custodial support, and employment related travel expenses.

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1

• Decommissioning Oversight - Contracted services include EPRI support, 2 document governance, engineering consulting services, estimating services for 3 supply chain, and radiation protection and environmental contract support.

4

• Maintenance/Work Control - Service vendor support to perform preventive and 5 corrective maintenance on all electrical systems; mechanical systems; 6 instrumentation and controls systems; other plant systems still in operation; and 7 the seawall.

8

• Nuclear Oversight/Nuclear Regulatory Affairs - Consultants to support Nuclear 9 Regulatory Affairs (NRA) interface with the NRC regarding SONGS 10 compliance with regulatory requirements, and to support Nuclear Oversights 11 execution of SONGS decommissioning quality assurance program (DQAP).

12

• Site Engineering - Software licenses, security computer maintenance, and 13 consultants as required to resolve specific issues being faced.

14

• Site Management and Administration - Staffing consultant to determine 15 appropriate SONGS staffing levels.

16

• Emergency Preparedness - Contractor support for planning functions that 17 continue to be required by federal regulations as long as nuclear fuel is stored on-18 site, including periodic drills to verify the effectiveness of the SONGS emergency 19 preparedness program.

20 The total estimated cost for Contracted Services in the 2017 DCE is $225.2 million62 21 (100% share, 2014 $). In the 2014 DCE, the total estimated cost for Contracted Services was 22 $34.6 million (100% share, 2014 $). This resulted in an increase of $190.6 million. The 2014 DCE 23 assumed Contracted Services would involve only office supplies, computers, and related equipment for 24 utility staff use, based upon an assumed cost of $10,500 per year per employee. SCE utilized this 25 category more broadly for the services and activities discussed above. Therefore, there is a variance 62 See 2017 DCE, Appendix C, Table 2, line 287.

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1 between the DCEs because the 2014 DCE did not include forecasts for this broader group of services 2 and activities.

3 SCE developed the estimated Contracted Services costs in the 2017 DCE by analyzing 4 the costs incurred for these functions in 2013-2016, and then built them up throughout the remaining 5 decommissioning schedule (2018-2051) based on the anticipated future contracted services requirements 6 for the SONGS decommissioning organization. SCE only included the costs necessary to meet its 7 regulatory requirements related to the safe storage of spent fuel on-site; and to provide services required 8 to maintain the plant and general facility. As noted above, the annual requirements going forward are 9 substantially lower than those recorded during the initial decommissioning period and reflect the 10 changed conditions, including SCEs transition of certain work activities to the DGC. The Commission 11 should find that they are reasonable.

12 2. Service Level Agreements/A&G 13 Beginning in 2016, SONGS implemented annual intra-company Service Level 14 Agreements (SLAs) with SCE corporate service providers (e.g., HR, IT, Real Estate, Supply 15 Management, Treasurers, Environmental, and Controllers). Each SLA describes the specific 16 administrative and general (A&G) functions and services SCE provides to SONGS that support and 17 sustain the D&D activities. The SLAs meet the terms and conditions included in the Decommissioning 18 Agreement between SCE and the Participants.63 19 The 2014 DCE included an A&G adder (5.0%) that was applied to the costs of each DCE 20 line item to cover the costs of SCE corporate departments supporting SONGS decommissioning.

21 To maintain the integrity of the values referenced from the 2014 DCE in the variance explanations 22 provided elsewhere in this testimony (i.e., all other cost categories), SCE kept the 5% A&G adder with 23 each DCE line item in Table IV-2 above. This results in the value for the SLA/A&G in line 17 of 24 Table IV-2 being shown as zero dollars in the 2014 DCE column. Rather than comparing the 25 SLA/A&G amount included in the 2017 DCE to zero, it is more appropriate to compare it to the 63 Section 8.1.7.2 of the SONGS Decommissioning Agreement, dated April 23, 2015.

36

1 corresponding 5% A&G adder from the 2014 DCE. The number SCE calculated for the corresponding 2 5% A&G adder from the 2014 DCE for the period 2016-2051 is $160.8 million (100% share, 2014 $).

3 The 2017 DCE incorporated the SLA costs to replace the A&G adders during the 2016-4 2028 period. Beginning in 2029, the 2017 DCE resumes applying the 5% A&G adder to all remaining 5 decommissioning costs until project completion in 2051. Under this approach, the 2017 DCE estimates 6 the cost of these SCE corporate functions at $168.2 million64 (100% share, 2014 $), an increase of $7.4 7 million, in comparison to the corresponding 5% adder noted above. Using the combination of SLAs and 8 A&G adder provides greater transparency and certainty of costs for the benefit of Participant oversight 9 and project cost control. The Commission should find the estimated costs for the SLAs/A&G adder 10 reasonable because they more accurately reflect the anticipated costs for these corporate support 11 functions.

12 3. DGC Staffing 13 DGC staff consists of SDS personnel who provide the project management of the D&D 14 work being performed by SDS, and manage/perform the programs and functions transferred from SCE 15 to SDS. Their project management function involves the continued planning, scheduling, and 16 monitoring of the D&D work as timely as possible while maintaining a safe work environment. It also 17 includes contracting with third party specialty vendors to complete specific tasks (e.g. RVI 18 segmentation), and administering those contracts. SCE provides oversight of SDSs project 19 management. This division of labor allows SDS and SCE to utilize their core competencies to complete 20 the work in an efficient manner - SDSs expertise in deconstructing facilities and SCEs oversight role.

21 This cost category also includes staffing for a DGC that will be required during substructure removal 22 and ISFSI D&D/final site restoration to be performed during 2046-2051.

23 In the 2017 DCE, the estimated cost for DGC Staffing is $ 65 (100% share, 24 2014 $). In the 2014 DCE, the estimated cost for DGC Staffing was $423.6 million (100% share, 2014 64 See 2017 DCE, Appendix C, Table 2, line 381.

65 See 2017 DCE, Appendix C, Table 2, lines 155 and 386.

37

1 $). This resulted in a decrease of $ million. This primarily reflects the result of the competitive 2 procurement process that resulted in the selection of SDS.

3 4. Labor-Staffing 4 SCE records costs for the SONGS utility staff and security force as undistributed labor.

5 The SONGS utility staff performs various decommissioning activities relating to state and federal 6 regulatory requirements, external communications with stakeholders, and strategic planning and 7 analysis. The utility staffs activities include complying with existing technical specifications; ensuring 8 the health and safety of the workers and the public; planning and preparing the facility for 9 decommissioning; retiring plant systems to minimize or eliminate costs; and keeping the public and 10 stakeholders informed on decommissioning progress. The security force protects SONGS in accordance 11 with NRC regulations 10 C.F.R. § 73 and 10 C.F.R. § 50.54, and has been sized to meet the current 12 design basis threat assessment, pursuant to 10 C.F.R. § 73.

13 In the 2017 DCE, SCE estimates that Labor-Staffing costs will be $986.2 million66 14 (100% share, 2014 $). In the 2014 DCE, SCE estimated that Labor-Staffing costs would be $1,029.4 15 million (100% share, 2014 $). This resulted in a decrease of $43.2 million (100% share, 2014 $) relative 16 to the 2014 DCE. Now that SCE has four plus years of experience with the planning of 17 decommissioning, it is better able to identify the required staffing to safely carry out the 18 decommissioning of SONGS 2&3 and oversight of its contractors. The estimated staffing levels in the 19 2017 DCE were developed through a collaborative process between SONGS executive managers and 20 Kenrich. The staffing levels were subsequently vetted by ABZ. The Commission should find these 21 costs reasonable as they reflect the additional experience SCE has gained, have been reviewed by an 22 industry expert, and represent a well-supported estimate of the staffing levels required going forward.

23 5. All Other Non-Labor 24 Non-Labor costs include a wide range of decommissioning activities and obligations, 25 including the following:

66 See 2017 DCE, Appendix C, Table 2, line 265.

38

1

• Site Lease and Easement Expenses - SCE will be required to make annual easement 2 and lease payments to the Navy for the onshore plant site and SONGS Mesa facility 3 and to the CSLC for the SONGS 2&3 offshore conduits until the easement and lease 4 agreements are terminated.

5

• Severance - Under the Decommissioning Act, SCE is required to provide severance 6 benefits to SCE employees at SONGS whose jobs are eliminated as a result of the 7 permanent retirement of SONGS.

8

• Energy - SCE must purchase electrical energy at retail rates to power the SONGS 9 site.

10

• Loading Spent Fuel & GTCC Waste to DOE - Under the DOE Standard Contract, 11 SCE is responsible for the cost to transfer spent fuel canisters from the ISFSI and 12 loading them into DOE shipping containers on-site, and then onto the DOEs 13 transportation device.

14

• Information Technology - SCE will be required to incur software and network 15 licenses, pay network service providers, and provide internal technical support to site 16 personnel at levels commensurate with site staffing until decommissioning is 17 completed.

18

• Third Party Legal - SCE retains outside counsel as necessary to handle legal matters 19 that require specific expertise or additional resources.

20

• Emergency Preparedness Fees - SCE provides funding to local jurisdictional 21 authorities for their radiological emergency preparedness, and will continue to do so 22 until all spent fuel has been removed from SONGS, under a memorandum of 23 understanding.

24

• NRC Fees - As holder of the NRC licenses for SONGS, SCE will be required to pay 25 10 C.F.R. Part 171 annual license fees and 10 C.F.R. Part 170 inspection fees until 26 the NRC licenses are terminated.

39

1

• Utility Staff Health Physics Supplies - After SDS completes the major D&D work, 2 SCE will re-assume responsibility for providing health physics supplies as required to 3 support the ISFSI-only staff.

4

• Community Engagement Panel - SCE has chartered a panel consisting of a group of 5 representatives from surrounding cities and counties to serve as a conduit of 6 information to the public and other stakeholders regarding decommissioning that 7 seeks to educate and explain SONGS decommissioning matters of interest to the local 8 public. SCE incurs costs to conduct quarterly CEP meetings at venues in the vicinity 9 of SONGS.

10

• Environmental Permits and Fees - SONGS must comply with a variety of 11 environmental regulations and maintain several environmental permits that will 12 require periodic payments of fees.

13

• ISFSI Aging Management -The facility maintenance and inspection activities for the 14 ISFSI, in compliance with the Areva and Holtec SARs, as will be determined by the 15 ISFSI Aging Management Program to be developed.

16

• Security Related Expenses - As long as spent fuel remains on-site, the SONGS 17 security force will continue to require uniforms, weapons, ammunition, other supplies 18 and equipment, as well as background investigations, training, and vendor support.

19

• DGC Executive Oversight Committee - a five person committee that provides 20 oversight and resolves contractual issues regarding the SDS contract. SCE and SDS 21 share the cost of three independent members on the committee.

22

• Insurance - NRC regulations require SCE to maintain minimum levels of nuclear 23 liability and property insurance until the spent fuel is removed from the SONGS site.

24 SCE also maintains general liability insurance and excess workers compensation 25 insurance.

40

1

• Association Fees and Expenses - NEI membership fees, and costs related to an 2 external Nuclear Oversight Board (NOB) and an outside advisor to SCEs Internal 3 Nuclear Management Group (INMG).

4

• Water - SCE is required to purchase potable and service water for the SONGS Site.

5

• Office Space - During major D&D activities, SDS will demolish all existing office 6 space on the SONGS site and provide temporary office space as necessary.

7 After Major D&D is completed, SCE will need to provide office space for the 8 remaining employees.

9

• Decommissioning Advisor - One or more outside consultants who provide subject 10 matter expertise regarding decommissioning regulatory issues, spent fuel storage, and 11 project management.

12

• Ground Water Monitoring - SCE will be required to periodically sample, analyze, 13 and monitor the ground water beneath the SONGS site.

14 The estimated costs for Non-Labor are shown in Table IV-7 below:

41

Table IV-7 Reconciliation of 2017 DCE to 2014 DCE All Other Non-Labor (100% Share, Millions of 2014 $)

2017 DCE 2014 DCE Total Total Description (2014 $) (2014 $) Variance 1 Non-Labor 2 Site Lease and Easement Expenses $ 97.5 $ 19.5 $ 78.0 3 Severance 121.0 170.8 (49.8) 4 Energy 84.7 50.2 34.5 5 Loading Spent Fuel & GTCC Waste To DOE 30.6 - 30.6 6 Information Technology 31.9 6.6 25.3 7 Third Party Legal 23.8 - 23.8 8 Emergency Preparedness Fees 48.3 25.8 22.5 9 NRC Fees 31.2 53.6 (22.4) 10 Utility Staff Health Physics Supplies 3.7 25.8 (22.1) 11 Community Engagement Panel 12.5 34.0 (21.5) 12 Environmental Permits and Fees 6.7 27.1 (20.4) 13 ISFSI Aging Management 15.3 - 15.3 14 Security Related Expenses 11.8 18.8 (7.0) 15 DGC Executive Oversight Committee 3.7 - 3.7 16 Insurance 63.7 67.3 (3.6) 17 Association Fees and Expenses 8.6 11.0 (2.4) 18 Water 16.5 14.5 2.0 19 Office Space 1.7 - 1.7 20 Decommissioning Advisor 9.9 11.4 (1.5) 21 Ground Water Monitoring 0.5 - 0.5 22 Property Tax - 74.7 (74.7) 23 DGC Non-Labor - 35.9 (35.9) 24 Spent Fuel Maintenance - 7.4 (7.4) 25 DAW Disposal - 3.9 (3.9) 26 Tools and Equipment - 1.3 (1.3) 27 Non-Labor Total $ 623.6 $ 659.6 $ (36.0) 1 In the 2017 DCE, Other Non-Labor costs are estimated at $623.6 million67 (100% share, 2 2014 $). In the 2014 DCE, Other Non-Labor costs were estimated at $659.6 million (100% share, 67 See 2017 DCE, Appendix C, Table 2, line 375 (minus line 287 Contracted Services costs, which are discussed separately in Section IV.C.1).

42

1 2014 $). This resulted in a decrease of $36.0 million. This net decrease reflects numerous offsetting 2 increases and decreases as explained below:68 3

• Site Lease and Easement Expenses - In the 2017 DCE, SCE estimates $97.5 million69 4 (100% share, 2014 $) for site lease and easement expenses, compared with $19.5 5 million (100% share, 2014 $) in the 2014 DCE. This resulted in an increase of $78.0 6 million. SCE expects payments to the Navy to increase after the easement is 7 renegotiated and the Navy resets the fees based on the current fair market rental value 8 of the property.

9

• Severance - In the 2017 DCE, SCE estimates $121.0 million70 (100% share, 2014 $)

10 for employee severance costs, compared with $170.8 million (100% share, 2014 $) in 11 the 2014 DCE. This resulted in a decrease of $49.8 million. SCE expects decreased 12 severance costs because it has incurred lower than anticipated payouts to previously 13 terminated SONGS employees. In addition, because many employees were 14 reassigned to other positions within the company, they are no longer eligible for 15 SONGS severance benefits.

16

• Energy - In the 2017 DCE, SCE estimates $84.7 million71 (100% share, 2014 $) for 17 energy costs compared with $50.2 million (100% share, 2014 $) in the 2014 DCE, 18 resulting in an increase of $34.5 million. This variance reflects an updated forecast of 19 energy usage levels (at retail energy rates) during 2019-2028 based upon how SDS 20 plans to perform D&D.

21

• Loading Spent Fuel & GTCC Waste to DOE - In the 2017 DCE, SCE estimates that 22 the cost to transfer spent fuel canisters from the ISFSI into DOE shipping containers 68 SCE is not providing variance analyses for variances $7.0 million or when the 2017 DCE did not include costs for items included in the 2014 DCE.

69 See 2017 DCE, Appendix C, Table 2, line 358.

70 See 2017 DCE, Appendix C, Table 2, line 353.

71 See 2017 DCE, Appendix C, Table 2, line 308.

43

1 on-site, and then onto the DOEs transportation device, will be $30.6 million72 (100%

2 share, 2014 $). The 2014 DCE did not include a line item for this cost.

3

• Information Technology - In the 2017 DCE, SCE estimates $31.9 million73 (100%

4 share, 2014 $) for IT costs, compared with $6.6 million (100% share, 2014 $) in the 5 2014 DCE. This resulted in an increase of $25.3 million. The increased cost is due in 6 part to some one-time payments to network service providers in 2018. After payment 7 of these costs, SCE expects that ongoing support costs will be reduced after 2019.

8

• Third Party Legal - In the 2017 DCE, SCE estimates $23.8 million74 (100% share, 9 2014 $) for third party legal expenses. This variance occurred because the 2014 DCE 10 did not forecast these services as direct costs, but instead assumed that the costs were 11 a part of overheads.75 The services provided by outside legal counsel are required to 12 perform normal business functions as well as tasks required by the NRC, and state 13 and local agencies.

14

• Emergency Preparedness Fees - In the 2017 DCE, SCE estimates $48.3 million76 15 (100% share, 2014 $) for emergency preparedness fees, compared with $25.8million 16 (100% share, 2014 $) in the 2014 DCE. This resulted in an increase of $22.5 million.

17 In the 2017 DCE, SCE anticipates that it will continue to incur emergency 18 preparedness fees pursuant to a Memorandum of Understanding with local 19 jurisdictional authorities until all spent fuel is removed from the SONGS site versus 20 the assumption in the 2014 DCE that such payments would terminate when the spent 21 fuel was removed from the pools.

72 See 2017 DCE, Appendix C, Table 2, line 361.

73 See 2017 DCE, Appendix C, Table 2, line 325.

74 See 2017 DCE, Appendix C, Table 2, line 336.

75 Corporate support is provided by SCE from organizations other than SONGS (e.g., legal, treasurers, finance, IT, supply chain).

76 See 2017 DCE, Appendix C, Table 2, line 303.

44

1

• Utility Staff Health Physics Supplies - In the 2017 DCE, SCE estimates $3.7 2 million77 (100% share, 2014 $) for utility staff health physics supplies, compared with 3 $25.8 million (100% share, 2014 $) in the 2014 DCE. This resulted in a decrease of 4 $22.1 million. The decreased cost occurred because SDS will be performing the 5 health physics functions for the major D&D work, and incurring the cost of its health 6 physics supplies. SCE will re-assume responsibility for providing health physics 7 supplies after the major D&D work is completed, as required to support the ISFSI-8 only staff.

9

• Community Engagement Panel (CEP) - In the 2017 DCE, SCE estimates $12.5 10 million78 (100% share, 2014 $) for Community Engagement Panel expenses, 11 compared with $34.0 million (100% share, 2014 $) in the 2014 DCE. This resulted in 12 a decrease of $21.5 million. The decreased cost occurred because SCE has incurred 13 lower CEP costs than estimated in the 2014 DCE and expects similar CEP 14 expenditures in the future.

15

• NRC Fees - In the 2017 DCE, SCE estimates $31.2 million79 (100% share, 2014 $)

16 for NRC fees, compared with $53.6 million (100% share, 2014 $) in the 2014 DCE.

17 This resulted in a decrease of $22.4 million. The decreased estimated cost occurred 18 because the NRC reduced its 10 C.F.R. Part 171 annual license fees, and SCE expects 19 to incur lower NRC inspection costs under 10 C.F.R. Part 170 than previously 20 estimated.

21

• Environmental Permits and Fees - In the 2017 DCE, SCE estimates $6.7 million80 22 (100% share, 2014 $) for environmental permits and fees, compared with 23 $27.1 million (100% share, 2014 $) in the 2014 DCE. This resulted in a decrease of 24 $20.4 million. The decreased estimated cost occurred primarily due to a reduction to 77 See 2017 DCE, Appendix C, Table 2, line 373.

78 See 2017 DCE, Appendix C, Table 2, line 280.

79 See 2017 DCE, Appendix C, Table 2, line 340.

80 See 2017 DCE, Appendix C, Table 2, line 313.

45

1 the annual NPDES Permit fees. Due to a reduction in the quantity of discharges from 2 the plant associated with the permanent shutdown, SCE was able to negotiate with the 3 SWRCB a reduction to the annual NPDES permit fees from $1.1 million per year to 4 $0.2 million per year. In addition to the reduced NPDES fees, the other 5 environmental fees (e.g., hazardous waste, pollution fees) were less than estimated in 6 the 2014 DCE. The 2014 DCE was prepared before the impact of decommissioning 7 on the fees assessed by various local and state agencies was determined.

8

• ISFSI Aging Management - In the 2017 DCE, SCE estimates $15.3 million81 (100%

9 share, 2014 $) for undistributed ISFSI Aging Management expenses. The 2014 DCE 10 did not include a line item for this cost.

11 The total net variance for Other Non-Labor costs is a decrease of $36.0 million (100%

12 share, 2014 $). Because these estimated costs are necessary to complete decommissioning and reflect 13 SCEs experiences throughout four plus years of decommissioning and incurring these types of costs, 14 the Commission should find these estimated costs reasonable.

81 See 2017 DCE, Appendix C, Table 2, line 270.

46

1 V.

2 CONCLUSION 3 The 2017 DCE estimates that the total cost to decommission SONGS 2&3 will be $4,479 million 4 (100% share, 2014 $), an increase of approximately 1.5% over the 2014 DCE that the Commission 5 found reasonable in D.16-04-019.

6 In Chapter II of this testimony, SCE presented a detailed discussion of the methodology by 7 which the 2017 DCE was developed and the bases for its underlying assumptions. SCE also explained 8 that due to the existence of contract pricing for much of the decommissioning work, SCE was able to 9 reduce the overall contingency factor of the 2017 DCE from 25% to 17%. In Chapter III, SCE presented 10 the testimony of Mr. Nicholas Capik, the Managing Director of ABZ Incorporated, a major provider of 11 decommissioning cost estimates for U.S. nuclear facilities. Mr. Capik described the independent review 12 that he performed regarding the completeness and accuracy of the 2017 DCE. In Chapter IV, SCE 13 provided a detailed reconciliation of the 2017 DCE to the 2014 DCE, including detailed discussions of 14 significant cost changes between the two estimates.

15 Given SCEs thorough and detailed explanation of the 2017 DCE, SCE has met its burden to 16 demonstrate that the 2017 DCE is a reasonable estimate of SONGS 2&3 decommissioning costs, and 17 provides an appropriate basis for the Commission to evaluate the reasonableness of the 18 decommissioning costs. The Commission, therefore, should find the 2017 SONGS 2&3 DCE to be 19 reasonable.

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Appendix A Witness Qualifications

1 SOUTHERN CALIFORNIA EDISON COMPANY 2 QUALIFICATIONS AND PREPARED TESTIMONY 3 OF JOSE LUIS PEREZ 4 Q. Please state your name and business address for the record.

5 A. My name is Jose Luis Perez, and my business address is 2244 Walnut Grove Ave, Rosemead, 6 CA 91770.

7 Q. Briefly describe your present responsibilities at the Southern California Edison Company.

8 A. I am a Principal Manager, Nuclear CPUC Regulatory Affairs and Compliance, in the Regulatory 9 Affairs Organization responsible for CPUC regulatory activities and financial planning &

10 analysis for SONGS issues.

11 Q. Briefly describe your educational and professional background.

12 A. I earned an MBA from the University of California, Irvine in 1997. I earned a Bachelor of 13 Science Degree in Civil Engineering from California State University, Long Beach in 1977. I 14 am a Registered Professional Engineer in the State of California. Since joining Edison in 1982, I 15 have held various management positions in nuclear generation business, finance, regulatory 16 affairs, planning & strategy, and project controls organizations. In addition, I have managed 17 various projects, including SONGS 1 decommissioning shortly after permanent shutdown and 18 industry restructuring financial analysis. Prior to joining Edison, my professional background 19 included various home office and jobsite positions in the civil engineering, nuclear power plant 20 start-up, and project controls organizations of Bechtel Power Corporation and the collection and 21 analysis of construction cost data for publication in cost estimating manuals for Marshall and 22 Swift Publications.

23 Q. What is the purpose of your testimony in this proceeding?

24 A. The purpose of my testimony in this proceeding is to sponsor Exhibit SCE-03: Testimony On 25 The 2017 Decommissioning Cost Estimate for SONGS 2&3, as identified in the Table of 26 Contents thereto.

A-1

1 Q. Was this material prepared by you or under your supervision?

2 A. Yes, it was.

3 Q. Insofar as this material is factual in nature, do you believe it to be correct?

4 A. Yes, I do.

5 Q. Insofar as this material is in the nature of opinion or judgment, does it represent your best 6 judgment?

7 A. Yes, it does.

8 Q. Does this conclude your qualifications and prepared testimony?

9 A. Yes, it does.

A-2

1 ABZ, INCORPORATED 2 QUALIFICATIONS AND PREPARED TESTIMONY 3 OF NICHOLAS J. CAPIK 4 Q. Please state your name and business address for the record.

5 A. My name is Nicholas Joseph Capik, and my business address is 4451 Brookfield Corporate 6 Drive, Suite 107, Chantilly, VA 20151.

7 Q. Who is your current employer?

8 A. ABZ, Incorporated.

9 Q. Briefly describe your present responsibilities at ABZ.

10 A. I am a Managing Director of ABZ. In that role, I am responsible for the management and 11 execution of numerous ABZ projects performed for the nuclear industry.

12 Q. Briefly describe your educational and professional background.

13 A. I earned an BS in Mathematics from the Pennsylvania State University in 1983. I completed the 14 Navy Nuclear Training Program in 1985. I served in the U.S. Navy from 1983 through 1991.

15 Since 1991, I have been employed at ABZ. At ABZ, I have performed cost estimates for over 40 16 clients related to due diligence, decommissioning, accident cleanup, and site restoration. In this 17 role, I was responsible for the development of assumptions, the selection of scenarios, the 18 preparation of studies, and the presentation of results. I have supported litigation related to spent 19 fuel storage, and tax issues related to decommissioning. I have had oversight and involvement of 20 decommissioning activities at several nuclear facilities.

21 Q. What is the purpose of your testimony in this proceeding?

22 A. The purpose of my testimony in this proceeding is to sponsor portions of Exhibit SCE-03:

23 Testimony On The 2017 Decommissioning Cost Estimate for SONGS 2&3, as identified in the 24 Table of Contents thereto.

25 Q. Was this material prepared by you?

26 A. Yes, it was.

27 Q. Insofar as this material is factual in nature, do you believe it to be correct?

A-3

1 A. Yes, I do.

A-4

Appendix B Decommissioning Cost Estimate - Confidential

San Onofre Nuclear Generating Station Units 2 & 3 2017 Decommissioning Cost Estimate Prepared For:

Southern California Edison 2244 Walnut Grove Avenue Rosemead, CA 91770 Prepared By:

The Kenrich Group LLC 1919 M Street, NW Suite 620 Washington, DC 20036 January 26, 2018 Revised March 8, 2018 Christopher F. Tierney Vice President & Chief Financial Officer

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate DESCRIPTION OF MINOR REVISION Revision Number: 1 Effective Date: March 8, 2018 The revisions made to the 2017 SONGS 2&3 Decommissioning Cost Estimate are minor in nature and do not revise or otherwise impact the content or results of the cost estimate.

Item 1 - The Spent Fuel Shipping Schedule in Appendix A has been revised to correct the number of Units 2 & 3 canisters transferred to the ISFSI.

Item 2 - Revised an activity description in Appendix B, Detailed Project Schedule.

Item 3 - Within Appendix C, Detailed Cost Tables, the notes to Appendix C have been attached.

Item 4 - The line numbers in Table 10, Utility & Security Force Average Staffing By Period, have been corrected.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate TABLE OF CONTENTS I. EXECUTIVE

SUMMARY

..............................................................................................................1 II. INTRODUCTION ............................................................................................................................2 A. Purpose And Scope Of 2017 DCE ......................................................................................................... 2 B. Regulatory Framework........................................................................................................................... 5 C. SONGS Decommissioning Background ................................................................................................ 5 D. The Kenrich Group ................................................................................................................................ 6 III.

SUMMARY

OF THE 2017 DCE ....................................................................................................7 A. General Approach .................................................................................................................................. 7 B. EnergySolutions 2014 DCE ................................................................................................................... 7 C. 2017 DCE Structure ............................................................................................................................... 9 IV.

SUMMARY

OF 2017 DCE COSTS AND SCHEDULE .............................................................12 A. Summary Of 2017 DCE Recorded And Estimated Costs .................................................................... 12 B. Summary Of 2017 DCE By Period ...................................................................................................... 13 V. BASES OF ESTIMATE AND KEY ASSUMPTIONS ...............................................................15 A. General Principles ................................................................................................................................ 15 B. Key Facts And Assumptions ................................................................................................................ 15 C. Project Schedule................................................................................................................................... 19 D. Distributed Costs.................................................................................................................................. 19

1. Completed Projects ................................................................................................................... 19

2. ISFSI And Fuel Transfer Operations......................................................................................... 20

3. Decontamination, Dismantlement, Demolition, And Disposal.................................................. 21

4. Substructure Removal................................................................................................................ 23

5. Offshore Conduit Removal ........................................................................................................ 24

6. ISFSI Demolition....................................................................................................................... 24

7. Final Site Restoration................................................................................................................ 24

8. Other Distributed Projects ........................................................................................................ 25 E. Undistributed Costs .............................................................................................................................. 28

1. Decommissioning Staffing ......................................................................................................... 30

2. Undistributed Non-Labor Costs ................................................................................................ 33

3. Service Level Agreements For Administrative & General Expenses......................................... 40

4. DGC Staffing ............................................................................................................................. 40 F. 2017 DCE Costs By NRC Cost Category ............................................................................................ 41 G. Contingency ......................................................................................................................................... 42 VI. ADDITIONAL DISCUSSION REGARDING THE PROJECT SCHEDULE .........................44 VII. WASTE DISPOSAL ......................................................................................................................46 VIII. REFERENCES ...............................................................................................................................48 i

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate TABLES TABLE 1 2017 DCE BY UPDATE CATEGORY TABLE 2

SUMMARY

OF 2017 DCE TABLE 3

SUMMARY

OF 2017 DCE BY PERIOD (NOMINAL/2017$)

TABLE 4

SUMMARY

OF 2017 DCE BY PERIOD (2014$)

TABLE 5 ISFSI & FUEL TRANSFER OPERATIONS ESTIMATE TABLE 6 SUBSTRUCTURE REMOVAL ESTIMATE TABLE 7 OTHER DISTRIBUTED PROJECTS ESTIMATE TABLE 8 UNDISTRIBUTED COST ESTIMATE (NOMINAL/2017$)

TABLE 9 UNDISTRIBUTED COST ESTIMATE (2014$)

TABLE 10 UTILITY & SECURITY FORCE AVERAGE STAFFING BY PERIOD TABLE 11 UNDISTRIBUTED LABOR COST ESTIMATE (NOMINAL/2017$)

TABLE 12 UNDISTRIBUTED LABOR COST ESTIMATE (2014$)

TABLE 13 UNDISTRIBUTED NON-LABOR COST ESTIMATE TABLE 14 SERVICE LEVEL AGREEMENT (A&G) COST ESTIMATE TABLE 15 2017 DCE COSTS BY NRC COST CATEGORY TABLE 16 CONTINGENCY FACTORS APPLIED IN 2017 DCE TABLE 17 CONTINGENCY INCLUDED IN THE SONGS 2&3 2017 DCE TABLE 18 REMAINING WASTE DISPOSAL QUANTITIES FIGURES FIGURE 1 2017 DCE BY UPDATE CATEGORY FIGURE 2 ALIGNMENT OF 2017 DCE PERIODS TO DECOMMISSIONING MILESTONES APPENDICES APPENDIX A SPENT FUEL SHIPPING SCHEDULE APPENDIX B DETAILED PROJECT SCHEDULE APPENDIX C DETAILED COST TABLES APPENDIX D ANNUAL CASH FLOW TABLES BY NRC COST CATEGORY APPENDIX E SHARE OF LIABILITY FOR SONGS PARTICIPANTS ii

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate Acronyms and Abbreviations APCD Air Pollution Control District CCC California Coastal Commission CoC Certificate of Compliance CDP Coastal Development Permit CEQA California Environmental Quality Act CEP Community Engagement Panel CFR Code of Federal Regulations CPUC California Public Utilities Commission CSLC California State Lands Commission D&D Decontamination & Dismantlement DCE Decommissioning Cost Estimate DGC Decommissioning General Contractor DOE U.S. Department of Energy DTSC California Department of Toxic Substances Control EIR/EIS Environmental Impact Report/Statement GTCC Greater Than Class C HP Health Physics INMG SCE Internal Nuclear Management Group ISFSI Independent Spent Fuel Storage Installation LLC Limited Liability Company LLRW Low-Level Radioactive Waste NDCTP Nuclear Decommissioning Cost Triennial Proceeding NEI Nuclear Energy Institute NEPA National Environmental Policy Act NIA North Industrial Area NOB Nuclear Oversight Board NPDES National Pollutant Discharge Elimination System NRC U.S. Nuclear Regulatory Commission PG&E Pacific Gas and Electric Company PSDAR Post-Shutdown Decommissioning Activities Report SAR Safety Analysis Report SCE Southern California Edison Company SDS SONGS DecommissioningSolutions SONGS San Onofre Nuclear Generating Station WBS Work Breakdown Structure iii

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate I. Executive Summary The 2017 San Onofre Nuclear Generating Station Units 2&3 (SONGS 2&3)

Decommissioning Cost Estimate (2017 DCE) has been prepared by the Kenrich Group LLC 1 (Kenrich) for Southern California Edison Company (SCE). 2 ABZ, Inc. (ABZ) also performed an independent review of the 2017 DCE.

The 2017 DCE utilizes the same Work Breakdown Structure (WBS) and selected distributed cost estimates included in the 2014 SONGS 2&3 DCE (2014 DCE) prepared by EnergySolutions, and essentially is an update to that DCE. The 2017 DCE will be submitted for review by the California Public Utilities Commission (CPUC) in the 2018 Nuclear Decommissioning Cost Triennial Proceeding (NDCTP). SCE will also submit certain information contained in the 2017 DCE to the U.S. Nuclear Regulatory Commission (NRC) for its review. 3 The 2017 DCE incorporates pricing from two significant contracts SCE has entered into for SONGS 2&3 decommissioning. In December 2014, SCE awarded a contract to Holtec International, Inc. (Holtec) to expand the SONGS Independent Spent Fuel Storage Installation (ISFSI) and transfer fuel from the SONGS 2&3 spent fuel pools to the ISFSI (ISFSI Expansion and Fuel Transfer Operations contract). In December 2016, SCE entered into a contract with the companies that have formed a joint venture called SONGS DecommissioningSolutions (SDS) 4, who will serve as the Decommissioning General Contractor (DGC) for major decontamination and dismantlement (D&D) activities. The ISFSI expansion project is in process, with transfer of spent fuel from the SONGS 2&3 spent fuel pools to the ISFSI planned to commence in 2018.

SDS initially mobilized in January 2017, and is continuing to develop decommissioning plans and schedule. The DGC is currently expected to begin physical work in January 2019, following the approval of a Coastal Development Permit (CDP) by the California Coastal Commission (CCC). The 2017 DCE incorporates the pricing from both of these contracts.

In addition, the 2017 DCE incorporates and reflects recorded costs, new information, and experience gained from decommissioning activities SCE has completed since June 2013. Since announcing its decision in June 2013 to permanently retire SONGS 2&3, SCE has commenced preliminary decommissioning planning and performed other significant preparatory activities for 1

Kenrich is a national management consulting firm with significant experience in power plant construction and decommissioning and in the energy industry more broadly in the United States and internationally.

2 Per the SONGS Decommissioning Agreement dated April 23, 2015, Southern California Edison is currently the Decommissioning Agent acting on behalf of itself and the three other SONGS 2&3 Participants, including San Diego Electric & Gas Company, the City of Riverside, and the City of Anaheim.

3 In accordance with 10 C.F.R. § 50.82(a)(8)(v), the licensee must annually submit to the NRC by March 31 a financial assurance status report.

4 The contract is between Southern California Edison Company and EnergySolutions Services, Inc. and AECOM Energy & Construction, Inc., together the contractor, and referred to herein as SDS.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate SONGS 2&3 decommissioning. The 2017 DCE incorporates recorded costs through September 2017 associated with these efforts.

The 2017 DCE for SONGS 2&3 is $4.702 billion in Nominal/2017 dollars. The 2014 DCE was $4.411 billion in 2014 dollars. For purposes of comparison to the 2014 DCE, the 2017 DCE expressed in 2014 dollars is $4.479 billion, which results in an approximate $68 million variance (less than 2%) between the two DCEs.

II. Introduction A. Purpose And Scope Of 2017 DCE In accordance with the California Nuclear Facilities Decommissioning Act of 1985 (Act),

SCE is required by the CPUC to update the SONGS 2&3 DCE every three years in connection with the NDCTP. The DCE is reviewed by the CPUC to determine the sufficiency of SCEs and San Diego Gas & Electric Companys (SDG&E) nuclear decommissioning trust funds, and the amount of customer contributions to those trust funds, if any are required. The DCE is also used in subsequent CPUC reasonableness reviews of actual decommissioning costs.

On June 7, 2013, SCE announced its decision to cease power generation operations and permanently retire SONGS 2&3. 5 In 2014, SCE engaged EnergySolutions to evaluate decommissioning alternatives and assist in the development of a detailed project schedule and DCE to support the preparation and submittal of a Post Shutdown Decommissioning Activities Report (PSDAR) in accordance with 10 C.F.R. § 50.82(a)(4)(i), which requires that a PSDAR be submitted [to the NRC] within two years following the permanent cessation of operations. 6 SCE submitted the PSDAR and 2014 DCE to the NRC on September 23, 2014 and to the CPUC on December 10, 2014. 7 The CPUC approved the 2014 DCE as reasonable in Decision (D.) 16-04-019 issued on April 21, 2016.

In 2017, SCE engaged Kenrich to prepare the 2017 DCE to reflect the actual costs and updated information and experience gained from SCEs decommissioning activities completed since June 2013. The 2017 DCE will be reviewed by the CPUC for the purposes identified above. New and updated information incorporated into the 2017 DCE includes: 8 5

SONGS 1 has largely been decommissioned and the site it occupied is now referred to as the North Industrial Area, which includes the SONGS ISFSI.

6 EnergySolutions, 2014 Decommissioning Cost Analysis of the San Onofre Nuclear Generating Station Units 2&3, September 5, 2014.

7 The NRC accepted the SONGS 2&3 PSDAR and found the 2014 Units 2&3 DCE estimate of $4.411 billion to be reasonable on August 20, 2015.

8 Information in this DCE is intended to be current as of approximately September 30, 2017.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate x The contract pricing for the contract awarded to Holtec International, Inc.

(Holtec) for the ISFSI expansion and the transfer of spent fuel from the SONGS 2&3 spent fuel pools to the ISFSI; x Contract value for the DGC contract awarded to SONGS DecommissioningSolutions (SDS) for the decontamination and dismantlement of SONGS 2&3, and the removal and disposal of hazardous and non-hazardous waste off the site; 9 x Recorded costs for decommissioning activities through September 30, 2017; x Revised U.S. Department of Energy (DOE) spent fuel acceptance date to reflect the DOEs continued failure to perform its contractual obligation to remove spent fuel from commercial nuclear reactors in the past four years; x Revised environmental permitting approval dates based on the current permitting status and the requirements of the California Environmental Quality Act (CEQA) and the CCCs CDP processes; x Revised project execution strategy to delay substructure removal until 2046; x Updated undistributed cost projections based on historical recorded costs and revised projections; x Updated ISFSI demolition costs to reflect the Holtec ISFSI pad; and x Additional costs not included in the 2014 DCE.

In sum, significant components of the 2017 DCE are now based on competitively bid contracts, as well as three additional years of experience managing a decommissioning plant and overseeing decommissioning personnel. Where new information was not available, Kenrich worked with SCE personnel and third-party consultants to validate and refine the 2014 DCE cost and schedule assumptions. Table 1 and Figure 1 below provide a summary of the 2017 DCE in nominal/2017 dollars 10 and in 2014 dollars.

9 See Appendix B for the schedule and activities for decontamination, and dismantlement.

10 The 2017 DCE presents recorded costs in nominal dollars and estimated (i.e., October 2017-2051) costs in 2017 dollars.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate TABLE 1 - 2017 DCE BY UPDATE CATEGORY 11, 12

($ IN THOUSANDS) 2017 DCE (Nominal/ 2017 DCE Description 2017$) (2014$)

1 Recorded Costs (Through September 2017) 2 Remaining DGC and ISFSI Work Under Contract 3 Substructure Removal 4 ISFSI Demolition and Final Site Restoration 5 Other Distributed Projects 6 Site Management and Oversight 7 Non-Labor and A&G 8 Total $ 4,702,264 $ 4,478,566 FIGURE 1 - 2017 DCE BY UPDATE CATEGORY

($ IN MILLIONS OF 2017 DOLLARS)

Site Management and Oversight Non-Labor and A&G Recorded Costs (Through September 2017)

Other Distributed Projects Remaining DGC and ISFSI Work ISFSI Demolition Under Contract and Final Site Restoration Substructure Removal 11 Totals in tables throughout this report may not tie due to rounding.

12 Of the $1,183,601 (nominal dollars) in recorded costs included in the 2017 DCE, $964,996 was recorded between June 2013 and December 2016, and $218,605 was recorded between January and September 2017 ($964,996 +

$218,605 = $1,183,601).

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate B. Regulatory Framework SONGS 2&3 decommissioning is governed by the following NRC regulations:

1. 10 C.F.R. Part 50 License - SCE holds a 10 C.F.R. Part 50 license for SONGS 2&3.

SCE, as the license holder, must comply with all the requirements and standards of the Part 50 license. The Part 50 license authorizes SCE to store spent fuel on-site in wet storage (i.e., the spent fuel pool).

2. 10 C.F.R. Part 72 License - SCE is required to hold a 10 C.F.R. Part 72 license in order to store fuel on-site in dry storage at the ISFSI. The current ISFSI Part 72 license is a general license set forth in 10 C.F.R. § 72.210 and requires the possession of a Part 50 license.

3. 10 C.F.R. § 50.75(c) specifies the reporting and recordkeeping requirements for decommissioning planning and requires that the licensee provide adequate funding for termination of the Part 50 license.

4. 10 C.F.R. § 72.30 specifies the financial assurances and recordkeeping for decommissioning and requires that the licensee provide adequate funding for termination of the Part 72 license.

5. 10 C.F.R. § 50.54(bb) requires the licensee to submit written notification to the NRC within two years following permanent cessation of operation of the reactor or five years before expiration of the operating license(s), whichever occurs first, for review and preliminary approval of the program by which the licensee intends to manage and provide funding for the management of all irradiated fuel at the reactor upon expiration of the reactor operating license until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository. The 2014 DCE was submitted pursuant to this requirement.

C. SONGS Decommissioning Background SONGS is located in southern California on the shore of the Pacific Ocean, approximately 62 miles southeast of Los Angeles and 51 miles northwest of San Diego. The plant is located entirely within Marine Corps Base Camp Pendleton on land owned by the U.S.

Department of the Navy (Navy), except for the offshore intake and outfall conduits. SONGS 2&3 occupy approximately 53 acres of the 84-acre SONGS site. Approximately 16 acres are occupied by the North Industrial Area (NIA), formerly the SONGS 1 site, which is where the ISFSI is located. Additional SONGS support activities occurred on Navy property across Interstate 5 from the SONGS site, referred to as the Mesa site.

SONGS 2&3 was a 2,250-megawatt nuclear generation facility consisting of two pressurized water reactors, which commenced operation in 1983 and 1984, respectively. On June 7, 2013, SCE announced plans to permanently retire SONGS 2&3. On June 12, 2013, SCE 5

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate submitted a Certification of Permanent Cessation of Power Operations to the NRC, certifying that SCE had permanently ceased power operations of SONGS 2&3, and surrendering SCEs authority to operate the units. SCE submitted to the NRC a Certification of Permanent Removal of Fuel for Unit 3 on June 28, 2013, and for Unit 2 on July 22, 2013. As a result of these submittals, SCE now holds an NRC license that does not permit power operations, but authorizes the possession of the SONGS facilities and licensed nuclear material.

As noted above, SCE has completed preliminary planning and performed other significant preparatory activities associated with SONGS 2&3 decommissioning. These activities include: (1) expanding the on-site spent fuel dry storage facility (also referred to as the ISFSI) and beginning preparations to transfer fuel from the spent fuel pools to the ISFSI; (2) planning the major decontamination, dismantlement, demolition and disposal efforts; (3) selecting a DGC to complete major portions of the decommissioning project, including the decontamination and dismantlement of SONGS 2&3, and removal and disposal of hazardous and non-hazardous waste from the site; (4) obtaining necessary approvals of various NRC license amendments now that SONGS 2&3 is permanently retired and being decommissioned; and (5) implementing various site projects to comply with regulatory requirements and other obligations, and prepare the site for major decommissioning activities.

Along with these efforts, SCEs legal and environmental teams have been working to complete the CEQA process and obtain a CDP so that major decontamination and dismantlement work by SDS can begin.

The current Grant of Easement for SONGS from the Navy is scheduled to expire May 11, 2024. Efforts to obtain a new real estate authorization from the Navy for the plant site are ongoing, and approval for the issuance of a new real estate authorization is expected by 2024.

D. The Kenrich Group Kenrich is a national management consulting firm with substantial experience in the public utility industry, nuclear power plant construction and decommissioning, and other commercial and public construction projects. Kenrich professionals have prepared and sponsored expert testimony with respect to cost and schedule analyses, project management, and economic damages before state and federal courts, domestic and international arbitration tribunals, and state utility commissions.

Kenrich personnel have consulted with utilities for more than 30 years on a wide range of matters, including strategic planning and financial analyses to support management decision-making, reviews and investigations by state and federal regulatory commissions, and economic damages analyses in the context of business disputes. Kenrichs consultants include accountants, financial analysts, and engineers, and the firm typically focuses on complex and detailed accounting and financial issues, as well as cost and schedule performance on major projects, including nuclear power plant construction and decommissioning.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate III. Summary of the 2017 DCE A. General Approach This 2017 DCE builds on the 2014 DCE, incorporating recorded costs through September 30, 2017; contract pricing for the ISFSI expansion contract awarded to Holtec in December 2014 and the DGC contract awarded to SDS in December 2016; site restoration costs estimated by third-party engineering firms; and revised SCE estimates for ongoing plant security and maintenance, and project oversight. Kenrich worked closely with SCE management and project oversight to develop the 2017 DCE. This DCE is generally consistent with the guidance provided in NRC Regulatory Guide 1.202, Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors.

SCE retained ABZ, Incorporated (ABZ) to perform an independent review of the 2017 DCE. ABZ is a management consulting and engineering firm specializing in providing services related to decommissioning costs, scheduling, and spent fuel storage. ABZ has prepared decommissioning cost estimates for numerous nuclear plant owners, including an estimate of SONGS 2&3 decommissioning costs for SCE in 2013, shortly following the announcement of the permanent retirement of SONGS 2&3.

B. EnergySolutions 2014 DCE In January 2014, SCE retained EnergySolutions to evaluate decommissioning alternatives and assist in the development of a detailed project schedule and DCE to support the preparation and submittal of a PSDAR in accordance with 10 C.F.R. § 50.82(a)(4)(i), which requires that a PSDAR be submitted to the NRC within two years following the permanent cessation of facility operations.

The 2014 DCE included the following three cost categories:

x License Termination -- Decommissioning SONGS 2&3 to the extent required to terminate the plants operating license pursuant to 10 C.F.R. § 50.75(c);

x Spent Fuel Management -- Post-shutdown management of spent fuel until acceptance by the DOE pursuant to 10 C.F.R. § 50.54(bb) and ISFSI decommissioning pursuant to 10 C.F.R. § 72.30; and x Site Restoration -- Demolition of uncontaminated structures and restoration of the site in accordance with the Navy Grant of Easement and the California State Lands Commission (CSLC) requirements.

The 2014 DCE was prepared using a WBS to differentiate between these three major cost categories. The 2014 DCE included SCEs actual costs incurred from June 7, 2013 through December 31, 2013 and estimated costs thereafter.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate The 2014 DCE was based on the following technical approach to decommissioning:

x Prompt DECON decommissioning methodology; 13 x Decommissioning would be performed by a DGC with oversight by the SONGS participants; x Spent fuel would be transferred from the spent fuel pools and stored in Multi-Purpose Canisters at an on-site ISFSI; and 14 x The DOE would begin accepting spent fuel from the nuclear industry in 2024 and complete the removal and acceptance of all spent fuel stored at SONGS by 2049.

A dry transfer facility would not be necessary to transfer the spent nuclear fuel canisters to DOE transport canisters.

The 2014 DCE followed the approach originally presented in the Atomic Industrial Forum/National Environmental Studies Project Report AIF/NESP-036, Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates. The report was prepared in accordance with NRC Regulatory Guide 1.202, Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors. The estimate was based on compliance with current regulatory requirements and proven decommissioning technologies.

On December 10, 2014, SCE filed Application (A.)14-12-007 and submitted the 2014 SONGS DCE to the CPUC. On April 21, 2016, the CPUC issued D.16-04-019, determining that the 2014 SONGS DCE was reasonable. On August 20, 2015, the NRC accepted the PSDAR, and found the DCE to be reasonable, stating:

The NRC staff reviewed the cost estimates against the guidance in RG 1.185, Section C.3 and finds that SCEs site-specific DCE and the costs of long-term storage of spent fuel for SONGS, Units 2 and 3, are considered reasonable, are described consistent with the guidance in RG 1.185, provide sufficient details 13 DECON is one of three basic methods for decommissioning defined by the NRC. Under the DECON method, the equipment, structures, and portions of the facility and site that contain radioactive contaminants are promptly removed or decontaminated to a level that permits termination of the Part 50 license after cessation of operations.

14 The three options for long-term post-shutdown spent fuel management currently available to power plant operators are as follows: (1) wet storage consisting of continued maintenance and operation of the spent fuel pools; (2) dry storage consisting of transfer of spent fuel from the fuel pool to on-site dry storage modules after a cooling period; or (3) a combination of the two as is the present case at SONGS. Maintaining the spent fuel pool for an extended duration following cessation of operations would prevent the reduction of the Part 50 license and result in higher annual maintenance and operating costs than the dry storage alternative. Transfer of spent fuel to an ISFSI requires additional expenditures for purchase and construction of the ISFSI and dismantlement and disposal of the ISFSI following the completion of spent fuel transfer to the DOE.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate associated with the funding mechanisms, and meet the requirements of 10 CFR 50.82(a)(4)(i). 15 C. 2017 DCE Structure The 2017 DCE utilizes the WBS that was established in the 2014 DCE, 16 and is estimated in 2017 dollars. Certain comparisons of the 2014 and 2017 DCEs are provided in 2014 dollars for ease of comparison. Costs were de-escalated from 2017 dollars to 2014 dollars using escalation factors provided by SCE.

Consistent with the 2014 DCE, the 2017 DCE provides the total costs to decommission SONGS 2&3. The liability for the total decommissioning costs is shared between the SONGS participants. 17 As noted above, the 2014 DCE summarized the decommissioning costs by the License Termination, Spent Fuel Management, and Site Restoration cost categories (as generally defined by the NRC). The costs were further summarized into sequential periods within each cost category. For the 2017 DCE, Kenrich revised the periods from the 2014 DCE and established common periods that include all cost categories to better align the estimated costs with SCEs current project schedule and to simplify cost and schedule reporting. 18 The 2017 DCE periods were designed to reflect the timing and completion of certain decommissioning milestones, including the completion of: (1) ISFSI fuel transfer operations; (2) mobilization and transition of various program activities (e.g. radiation protection program, maintenance, etc.) to SDS; and (3) major D&D phases of work defined in the DGC contract. 19 The completion of these milestones are expected to trigger certain reductions in staffing and undistributed costs. Figure 2 illustrates how the 2017 DCE periods align to the DGC contract and the completion of fuel transfer operations.

15 August 20, 2015 letter from NRC to SCE Vice President and Chief Nuclear Officer, Mr. Thomas J. Palmisano (ADAM Accession No.: ML15204A383) 16 The DCE line numbers in Appendix C of this report align to the line numbers in Appendix D of the 2014 DCE.

The DCE line numbers in Appendix C of this report indicate the corresponding 2014 DCE: (1) NRC cost category, (2) 2014 DCE period, (3) cost type (i.e., distributed or undistributed), and (4) line number. For example, LT-2-D-2.17 in Appendix C of this DCE corresponds to License Termination Period 2, distributed cost line number 2.17 in Appendix D of the 2014 DCE.

17 The share of the liability for each of the SONGS Participants is provided in Appendix E.

18 While new periods are used to summarize the costs in this DCE, the underlying cost structure remains the same as the 2014 DCE and will facilitate cost reconciliations between the two estimates.

19 The phases of work in the DGC contract are described in more detail in Section V.D.3 below.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate FIGURE 2 ALIGNMENT OF 2017 DCE PERIODS TO DECOMMISSIONING MILESTONES June 2019 December 2051 December 2028 December 2049 Fuel Transfer Termination Of Partial Site SONGS 2&3 Operations License Release Substructure Complete Removal Complete 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2046 2047 2048 2049 2050 2051 Pd Period 1 Period 2 Period 4 Period 5 Period 6 Period 7 3

Fuel Pool Operations Dry Fuel Storage Initial Activities Transition To D&D Major D&D Dry Storage Only Civil Works Project ISFSI Demo

& FSR (Unit 1 Substructure Removal)

The activities in each of the 2017 DCE periods are described in more detail below.

Period 1 - Initial Activities (June 2013 - December 2016)

Period 1 began on June 7, 2013 immediately following SCEs decision to permanently retire SONGS 2&3. As the decision was made approximately nine years before the units Part 50 operating licenses would have expired, SONGSs premature retirement was unexpected. SCE spent the following six months reducing its workforce and beginning to formulate plans for decommissioning. This period includes preliminary decommissioning planning, obtaining necessary approvals of NRC license amendments, commencing the expansion of its on-site ISFSI facility, and procuring a DGC. The end of this period aligns with the selection and award of the DGC contract to SDS in December 2016.

Period 2 - Transition and Pool Storage (January 2017 - December 2018)

Period 2 began with the mobilization of SDS in January 2017 and extends through December 2018, during which time SCE will transition responsibility of D&D-related site management and support functions at SONGS to SDS. In addition, SCE will complete the CEQA process with CSLC and obtain a CDP from the CCC. The CEQA process and CDP are required for SDS to begin major decontamination and dismantlement work. Other activities during Period 2 include the ongoing expansion of the on-site ISFSI facilities, and various other smaller projects. In addition, SCE currently anticipates that Holtec will begin transferring spent fuel from the wet storage pools adjacent to the reactors into dry storage at the expanded on-site ISFSI in 2018. The fuel transfer operations will continue into Period 3.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate Period 3 - D&D and Pool Storage (January 2019 - May 2019)

Period 3 begins with SDSs mobilization to commence the major physical work to decontaminate and dismantle SONGS 2&3. SDSs initial work during this period will primarily focus on the segmentation and packaging of reactor internals. The completion of the transfer of all fuel from the operating spent fuel pools into dry storage at the on-site ISFSI marks the end of Period 3. After the SONGS spent fuel pools are empty, related systems needed for the spent fuel pools will be retired, and otherwise applicable plant programs associated with spent fuel management will be modified, allowing SCE to further reduce SONGS staffing.

Period 4 - D&D and Dry Storage (June 2019 - December 2028)

Period 4 begins with the completion of fuel transfer operations and extends through the completion of the D&D work. Period 4 is expected to span approximately 9.6 years. This period includes the decontamination, dismantlement, demolition, removal, and waste disposal of the entire SONGS plant to approximately 3 feet below grade, with the exception of the on-site ISFSI and its associated security facilities, as well as the switchyard area. At the end of this period, SDS is expected to have completed all D&D work necessary to obtain NRC approval to reduce the Part 50 license site footprint to the ISFSI area only and to allow partial release of the SONGS site for unrestricted future use.

Period 5 - Dry Storage (January 2029 - December 2045)

During Period 5, the primary activity at SONGS will be the ongoing maintenance and security of the on-site ISFSI and the transfer of all SONGS spent fuel to the DOE. For purposes of the 2017 DCE, SCE has assumed that the DOE will begin performing its obligations nationally in 2028, which means that the DOE would begin removing the SONGS 2&3 spent nuclear fuel from the on-site ISFSI in 2034 under the pick-up rates published in the DOEs July 2004 Acceptance Priority Ranking & Annual Capacity Report. In addition, Period 5 includes the Navys National Environmental Policy Act (NEPA) environmental review process, associated with amending the SONGS real estate authorization to establish the site restoration or end state requirements for SONGS to return the property to the Navy. SCE will also initiate a Request For Proposal (RFP) process for substructure removal work.

Period 6 - Civil Works Project (January 2046 - December 2049)

Period 6 begins with a contractor mobilizing in order to perform the remaining work to restore the SONGS site for its return to the Navy. This work includes removing all onshore below-grade man-made structures, with the exception of the North Industrial Area where the on-site ISFSI is located. This work is currently expected to span approximately four years and is scheduled to be completed in December 2049. During Period 6, the DOE will continue to remove the remaining SONGS spent fuel from the ISFSI. SCE assumes all fuel is removed by the DOE by December 2049, marking the end of this period and the commencement of Period 7, 11

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate the demolition and removal of the ISFSI facilities and the final site restoration of the SONGS site.

Period 7 - ISFSI Demolition and Final Site Restoration (January 2050 - December 2051)

After all of the spent fuel is removed from SONGS, SCE can begin the final decommissioning and site restoration activities. These activities include dismantling and disposing of the ISFSI, completing the final site restoration work, obtaining NRC approval to terminate the remaining license covering the ISFSI, and returning the property to the Navy. 20 SCE projects that all decommissioning activities will be completed by 2051, approximately two years after the removal of the last spent fuel from the SONGS ISFSI.

In addition, for purposes of the 2017 DCE, SCE has assumed that the offshore intake and outfall conduits will be excavated and removed during this period.

At the end of decommissioning in 2051, all above and below ground man-made improvements, including the seawall and the offshore intake and outfall conduits, will be removed, and the site will be re-graded, re-vegetated, and returned to the Navy.

IV. Summary Of 2017 DCE Costs And Schedule A. Summary Of 2017 DCE Recorded And Estimated Costs SONGS has incurred $965.0 million (nominal dollars) through December 31, 2016 and estimates $3,737 million (2017 dollars) to complete decommissioning through 2051, for a total estimate of $4,702 million (Nominal/2017 dollars). The equivalent total in 2014 dollars is

$4,479 million. Table 2 below summarizes the 2017 DCE by cost category.

20 The Units 2&3 ISFSI Demolition and Final Site Restoration scope excludes the removal of the remaining Unit 1 foundations. The scope of the removal of the Unit 1 foundations is included in the Unit 1 DCE.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate TABLE 2

SUMMARY

OF 2017 DCE 21 22

($ IN THOUSANDS)

[A] [B] [C = A + B] [D]

Recorded Estimate To Total Estimate Total Estimate Through 2016 Complete At Completion At Completion Description (Nominal $) (2017$) (Nominal /2017$) (2014$)

1 Distributed Projects 2 Completed Projects $ 216,611 $ 1,234 $ 217,845 $ 214,024 3 ISFSI & Fuel Transfer Operations 140,047 142,385 282,432 270,210 4 Decontamination, Demolition, & Disposal -

5 Other Projects 19,959 180,789 200,748 189,758 6 Substructure Removal - 287,340 287,340 273,042 7 Offshore Conduit Removal - 96,039 96,039 91,631 8 ISFSI Demolition - 20,229 20,229 19,171 9 Final Site Restoration - 7,267 7,267 6,905 10 Distributed Subtotal 11 12 Undistributed Activities 13 Labor-Staffing $ 336,628 $ 696,304 $ 1,032,932 $ 986,172 14 Non-Labor 241,104 639,572 880,676 848,786 15 Service Level Agreements 10,647 166,996 177,643 168,212 16 DGC Staffing 17 Undistributed Subtotal 18 19 Total B. Summary Of 2017 DCE By Period As discussed above, the 2017 DCE periods were designed to reflect the timing and completion of key decommissioning milestones that impact the cost estimate. The table below summarizes the 2017 DCE by period.

22 The estimate to complete amounts in the tables through the report summarize period 2 through 7 costs (i.e.,

2017 - 2051), which include January through September 2017 recorded costs.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate TABLE 3 -

SUMMARY

OF 2017 DCE BY PERIOD (NOMINAL/2017$ IN THOUSANDS)

Period 1 Period 2 Period 3 Period 4 Period 5 Period 6 Period 7 ISFSI Transition Demolition &

Initial and Pool D&D and D&D and Civil Works Final Site Total Activities Storage Pool Storage Dry Storage Dry Storage Project Restoration (Nominal/

Description (Nominal $) (2017$) (2017$) (2017$) (2017$) (2017$) (2017$) 2017$)

1 Start 6/7/2013 1/1/2017 1/1/2019 6/1/2019 1/1/2029 1/1/2046 1/1/2050 2 End 12/31/2016 12/31/2018 5/31/2019 12/31/2028 12/31/2045 12/31/2049 12/31/2051 3 Duration (Years) 36 20 04 96 17 0 40 20 4

5 Distributed Projects 6 Completed Projects $ 216,611 $ 1,234 $ - $ - $ - $ - $ - $ 217,845 7 ISFSI & Fuel Transfer Operations 140,047 138,943 3,442 - - - - 282,432 8 Decontamination, Demolition, & Disposal 9 Other Projects 19,959 42,196 7,922 55,867 31,318 43,488 - 200,748 10 Substructure Removal - - - - - 263,698 23,642 287,340 11 Offshore Conduit Removal - - - - - 670 95,369 96,039 12 ISFSI Demolition - - - - - - 20,229 20,229 13 Final Site Restoration - - - - - - 7 267 7 267 14 Distributed Subtotal 15 16 Undistributed Activities 17 Labor-Staffing $ 336,628 $ 125,814 $ 22,954 $ 284,800 $ 172,804 $ 75,196 $ 14,735 $ 1,032,932 18 Non-Labor 241,104 84,020 17,913 220,608 218,376 72,388 26,266 880,676 19 Service Level Agreements 10,647 27,510 4,518 83,094 20,521 22,210 9,143 177,643 20 DGC Staffing 21 Undistributed Subtotal 22 23 Total $ 4,702,264 TABLE 4 -

SUMMARY

OF 2017 DCE BY PERIOD (2014$ IN THOUSANDS)

Period 1 Period 2 Period 3 Period 4 Period 5 Period 6 Period 7 ISFSI Transition Demolition &

Initial and Pool D&D and D&D and Civil Works Final Site Activities Storage Pool Storage Dry Storage Dry Storage Project Restoration Total Description (2014 $) (2014$) (2014$) (2014$) (2014$) (2014$) (2014$) (2014$)

1 Start 6/7/2013 1/1/2017 1/1/2019 6/1/2019 1/1/2029 1/1/2046 1/1/2050 2 End 12/31/2016 12/31/2018 5/31/2019 12/31/2028 12/31/2045 12/31/2049 12/31/2051 3 Duration (Years) 36 20 04 96 17 0 40 20 4

5 Distributed Projects 6 Completed Projects $ 213,032 $ 992 $ - $ - $ - $ - $ - $ 214,024 7 ISFSI & Fuel Transfer Operations 136,403 130,570 3,237 - - - - 270,210 8 Decontamination, Demolition, & Disposal 9 Other Projects 19,580 39,699 7,455 52,611 29,481 40,932 - 189,758 10 Substructure Removal - - - - - 250,603 22,438 273,042 11 Offshore Conduit Removal - - - - - 637 90,994 91,631 12 ISFSI Demolition - - - - - - 19,171 19,171 13 Final Site Restoration - - - - - - 6,905 6,905 14 Distributed Subtotal 15 16 Undistributed Activities 17 Labor-Staffing $ 332,184 $ 118,054 $ 21,564 $ 267,549 $ 162,337 $ 70,641 $ 13,843 $ 986,172 18 Non-Labor 239,691 79,724 17,005 210,259 208,221 68,862 25,023 848,786 19 Service Level Agreements 10,278 26,121 4,288 78,793 19,278 20,865 8,589 168,212 20 DGC Staffing 21 Undistributed Subtotal 22 23 Total $ 4,478,566 14

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate V. Bases Of Estimate And Key Assumptions A. General Principles Where available, Kenrich relied on executed contracts, actual cost data, and lessons learned from on-site performance to date. The cost estimate of decommissioning activities through the completion of the major decontamination, dismantlement, and waste disposal activities at SONGS in 2028 is based on competitively bid contracts and detailed project cost estimates prepared by SCE project managers. Kenrich worked with SCE personnel to ensure project cost estimates were reasonable and consistent with underlying key assumptions. Kenrich also worked with SCE to determine appropriate contingency factors to ensure that the total estimate remained reasonable and conservative. In addition, Kenrich incorporated project costs that were not included in the 2014 DCE, including those associated with the substantial environmental permitting efforts that are currently in process.

The majority of the cost estimates for activities after 2028, such as the substructures removal and the final site restoration are based on either the 2014 DCE values or updated estimates prepared by High Bridge Associates, experts in cost estimating. 23 Consistent with industry practice, the 2014 DCE used quantity take-offs from plant drawings and Unit Cost Factors.

Kenrich worked with knowledgeable SCE personnel to prepare cost estimates for the ongoing operations and maintenance of the SONGS facilities, as well as the oversight and support of the decommissioning project. Consistent with the 2014 DCE, these indirect project costs are referred to as undistributed costs in the 2017 DCE. Such undistributed costs include Utility Staffing, Contracted Services, Energy, Site Lease expenses, among other items. Kenrich worked closely with knowledgeable SCE personnel to develop detailed cost estimates that reflect the current known regulatory and project support requirements throughout the entire decommissioning project. Kenrich ensured these cost estimates were supported, reviewed by subject matter experts, and consistent with the project schedule and other key underlying assumptions.

B. Key Facts And Assumptions Kenrich worked closely with SCE personnel to identify, define, and support the key assumptions underlying the 2017 DCE. As part of this process, subject matter experts were interviewed and meetings were held with cross-functional teams to review and refine the 23 High Bridge Associates is a project management consulting and services company with experience supporting capital projects, decommissioning and closure projects, new build construction projects, and operating/maintenance programs in various markets. High Bridge has provided consulting and technical subject matter expert services to customers spanning Cost Estimating, Cost/Schedule Reviews, Risk Assessments, Due Diligence Evaluations, Feasibility Studies, Readiness Assessments, Contract Change Management/Claims, and Technical/Management Assessments.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate assumptions. Additionally, relevant supporting documents were identified and reviewed to confirm accuracy and reasonableness.

The key assumptions and general bases of estimate for the 2017 DCE are summarized below. The detailed bases for the estimated costs for specific distributed and undistributed activities are described in subsequent sections of this report.

General

1. Costs are presented in the same WBS utilized in the 2014 DCE (see Appendix C).

Distributed costs are summarized and discussed by major project, and undistributed costs are discussed by cost category.

2. Recorded costs for decommissioning activities through September 30, 2017 are included in this estimate.

3. Approximately $ billion of the SONGS decommissioning project are covered by two contracts (i.e., ISFSI expansion and fuel transfer operations with Holtec and the DGC contract with SDS). Those contract amounts are incorporated into this DCE. 24 Decontamination, Dismantlement, Demolition, and Disposal to Achieve Partial Site Release

4. The DGC contract with SDS was executed in December 2016. SDS mobilized to the SONGS site and commenced Phase I work (transition and planning) on January 9, 2017.

5. The pricing of the SDS contract generally covers two phases of work: transition and planning (Phase I) and the decontamination, dismantlement, and removal of all man-made improvements to 3 feet below grade (and or deeper as required) to reduce the Part 50 license to the ISFSI area only (Phase II). In addition, SDS is expected to install backfill and perform other work as requested.

6. The CEQA review process completed by the CSLC will conclude with the issuance of an Environmental Impact Report that will be utilized by the CCC in connection with its issuance of a CDP in the last quarter of 2018. The CDP will allow physical decommissioning work to commence at SONGS. Accordingly, SDS is expected to begin Phase II work in January 2019.

7. SDSs Phase II work is estimated to be completed by December 2028, following the submission of Final Site Survey to the NRC and the approval of a partial site release, reducing the SONGS 2&3 NRC Part 50 license footprint to the ISFSI area only. 25 24 Contract milestone payments are aligned with SCEs current expected project schedule.

25 SDSs Phase II work also covers non-radiological hazardous waste disposal, e.g., asbestos, chromates, lead paint, and polychlorinated biphenyls (PCBs).

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate

8. Following the D&D work, the SONGS plant site will be backfilled to current grade levels.

Clean material available on the SONGS plant site may be acceptable for purposes of backfill and additional required backfill material will be imported from offsite. 26

9. The 2017 DCE includes costs to purchase and import backfill material from offsite.

Spent Nuclear Fuel and GTCC Waste

10. All spent fuel will be transferred from the SONGS 2&3 pools to the on-site ISFSI by June 1, 2019.

11. Greater Than Class C (GTCC) waste will be stored in twelve canisters (five for reactor internals and one for spent fuel pool hardware/contents at each unit). GTCC waste from the containment buildings (e.g., portions of the reactor vessel internals) and spent fuel pools will be loaded into canisters and the loaded canisters will be transferred to the ISFSI.

12. The DOE will remove all GTCC waste from SONGS by 2049.

13. The DOE will commence accepting spent fuel from the commercial nuclear industry in 2028.

The DOE will accept the first SONGS 2&3 spent fuel in 2034. All SONGS spent fuel will be removed from the ISFSI by 2049.

14. SCE is responsible for the loading of spent fuel and GTCC waste canisters into DOE transportation containers. (No dry transfer facility is required.)

15. GTCC disposal costs are conservatively estimated to account for potential DOE charges for acceptance of GTCC waste (i.e., in addition to the one-mill fee charged per kilowatt of generation per the Standard Contract with the DOE).

Substructure Removal Below 3 Feet Below Grade (i.e., Below 27 Feet Elevation)

16. SCE anticipates submitting an application to the Navy to amend the then current real estate authorization to seek a Navy determination of the substructure removal requirements. The Navy is expected to establish those requirements after completing a NEPA process and to include the requirements within a new or amended real estate authorization. This will define the final site release criteria for turnover of the SONGS property back to the Navy. The 26 Paragraph 12 of the Grant of Easement, U.S. Department of Navy to Southern California Edison Company and San Diego Gas & Electric Company, dated May 12, 1964 states, That upon termination of the easement granted herein, the Grantees at their expense may remove, and if desired by the government, shall remove any and all improvements installed or constructed hereunder and shall restore the Premises to a condition satisfactory to the Director, Southwest Division, Bureau of Yards and Docks, except that the Grantees shall not be obligated to restore any natural material cut or filled in the necessary excavation and grading of the Premises and such surrounding area within the Reservation as may have been contaminated by the operation of the Nuclear Station. Thus, the contract states that the Navy will specify the final site restoration requirements. The Navy has not yet specified its decontamination, backfill, compaction, grading, or re-vegetation requirements. The Navy is expected to establish these requirements as a part of the NEPA process and specify them within a new real estate authorization.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate application is currently expected to be filed in 2040, with a Navy decision by 2045. That timing may change depending upon the time frame for the DOE removal of the spent fuel.

17. The removal of substructures (i.e., man-made improvements remaining after the D&D work and reduction of the Part 50 license to the ISFSI area only) is expected to begin in 2046 and be completed by December 2049. The final site restoration criteria will not be known until the Navy amends the SONGS site real estate authorization to include such criteria.

Therefore, for purposes of the 2017 DCE, it is assumed that all SONGS 2&3 substructures will be removed during 2046-2049 (Period 6) (excluding the ISFSI which will be removed in a subsequent period). 27

18. The estimated costs for the substructure removal work scope included in the 2014 DCE were reviewed and updated by High Bridge Associates. High Bridge Associates validated the quantities contained in the 2014 DCE and reduced the costs for non-radioactive waste disposal (based on La Paz, Arizona disposal rates, as compared to Oregon state rates which were assumed for purposes of the 2014 DCE). 28

19. All concrete and other demolition debris (including clean; i.e., non-radioactive, non-hazardous material) that is deemed by the Navy or SCE to be not suitable for purposes of backfill will be transported to and disposed at an out-of-state Class III landfill at La Paz, Arizona or other facilities as may be required. 29 Cost for transporting clean scrap metal to a recycler is included in the DCE. No credit is taken for any salvage value of the scrap metal.

Conduits, ISFSI Demolition, and Final Site Restoration

20. For purposes of the 2017 DCE, it is assumed the offshore intake and outfall conduit will be removed during Period 7, ISFSI Demolition and Final Site Restoration, and will be complete by 2050.

27 Any determination in the 2017 DCE that accounts for only partial removal of substructures would be non-conservative, arbitrary and inconsistent with the U.S. Navy easement, and without basis. If the final site restoration requirements specified in the future by the Navy allow less than complete removal of non-contaminated structures below 3 feet below grade (i.e., 27 feet elevation), then that new assumption will be incorporated into the subsequent DCE update.

29 This out-of-state disposal requirement is consistent with the Governor of the State of California Executive Order D-62-02.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate

21. Following the complete removal of SONGS spent fuel and GTCC waste in 2049, the ISFSI and related facilities, and all remaining man-made structures (e.g., gunite walls, roads and parking lots, rail facilities) will be demolished and removed.

22. The SONGS site will be re-established to meet Navy site restoration requirements, including grading and re-vegetated.

Other

23. SCE expects to return the Mesa site to the Navy by July 31, 2021. The April 2011 lease from the Navy is known as the Mesa lease and contains five parcels. Parcels 5, 6, and 7 are associated with the Mesa site and are being returned. Parcels 8 & 9 are adjacent to the SONGS site and will be retained and incorporated into a new site lease during the real estate authorization process.

C. Project Schedule The 2017 DCE assumes the timing for completing major activities is generally the same as the 2014 DCE, with the exception of the timing for removing the substructures below 3 feet below grade, which moved from 2031 to 2049. The schedule assumed in the 2017 DCE is as follows:

x June 1, 2019 - Fuel Transfer Operations Complete.

x December 2028 - Completion of the D&D work and receipt of NRC approval of the amendment to achieve partial site release and reduce the Part 50 License to the ISFSI area only.

x December 2049 - Completion of Substructures removal below 3 feet below grade (i.e., 27 feet elevation).

x December 2049 - All spent fuel removed from the site.

x December 2051 - Completion of ISFSI Demolition, Conduits Removal, Final Site Restoration, and Lease Termination.

D. Distributed Costs

1. Completed Projects Following the transition to decommissioning in June 2013, SCE began efforts to prepare the site for decommissioning and obtain necessary approvals of NRC license amendments.

During the period from June 7, 2013 to September 30, 2017, SCE began and completed projects 19

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate to implement Cold & Dark, 30 perform the initial site assessment, dispose of legacy radwaste, prepare and receive approval for regulatory submittals, and select a DGC.

During this period, SCE also implemented projects that were needed to comply with regulatory requirements and other obligations. SCE began and completed projects related to Security Shutdown Strategy, Large Organism Exclusion Device Modifications, Fuel Cancellation payments, and other efforts.

Kenrich incorporated the recorded costs for the completed projects into the 2017 DCE.

SCE will support the reasonableness of costs incurred in separate filings in the 2015 and 2018 NDCTP.

2. ISFSI And Fuel Transfer Operations Following a competitive bidding process, SCE awarded a contract to Holtec to license, design, and construct an expanded on-site ISFSI; and to supply, load, and transfer the multi-purpose canisters containing fuel assemblies, from the SONGS 2&3 spent fuel pools to the expanded ISFSI. Holtecs work scope generally includes:

x Perform engineering, procurement, and construction services for a new on-site ISFSI pad and supporting facilities (e.g., security building, haul path).

x Perform fuel inspections and spent fuel pool waste characterizations.

x Provide spent fuel canisters and vertical ventilated underground dry storage modules to store SONGS spent fuel assemblies.

x Load and transport the canisters to the ISFSI and place the canisters into the dry storage modules.

x Transport the loaded GTCC waste (reactor internals and certain other non-fuel waste material) canisters to the ISFSI. 31 x Engineering analyses, documentation, licensing and permitting activities.

SCE also maintains an ISFSI oversight team to ensure safe and efficient execution of the work by Holtec. The estimate for ISFSI and Fuel Transfer Operations also includes these SCE project oversight costs.

30 Includes plant modifications to systems that are not required to support spent fuel pool cooling or to meet other license conditions and places SONGS in a Cold and Dark condition in preparation of dismantlement and decontamination.

31 The Holtec contract milestone payment for transferring the GTCC waste to the ISFSI, as well as costs associated with the procurement of GTCC canisters is included in a separate line item in the DCE for GTCC Waste Storage within Other Projects.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate TABLE 5 ISFSI & FUEL TRANSFER OPERATIONS ESTIMATE

($ IN THOUSANDS)

Recorded Estimate To Total Estimate Total Estimate Through 2016 Complete At Completion At Completion Description (Nominal $) (2017$) (Nominal /2017$) (2014$)

1 ISFSI & Fuel Transfer Operations 2 ISFSI Expansion $ 60,485 $ 74,100 $ 134,585 $ 128,026 3 Canister Fabrication 79,562 27,705 107,266 104,026 4 Spent Fuel Loading & Transfer to ISFSI - 40,580 40,580 38,159 5 ISFSI & Fuel Transfer Operations Total $ 140,047 $ 142,385 $ 282,432 $ 270,210

3. Decontamination, Dismantlement, Demolition, And Disposal In December 2016, following a competitive bidding process, SCE executed a contract with SDS to perform the major decontamination, dismantlement, demolition, and disposal work at SONGS. The SDS work will include removing all SONGS 2&3 structures, systems, and components to 3 feet below grade (i.e., to 27 feet elevation) to permit the release of the property for unrestricted future use. 32 The SDS work will include characterizing, packaging, transporting, and disposing of waste from the SONGS site to appropriately licensed or permitted facilities. 33 Additionally, SDS will support SCE to modify or amend its NRC Part 50 license for SONGS 2&3, as well as its existing agreements with the U.S. Navy and other permitting agencies as required for completion of this work scope.

The work is divided into two phases:

Phase I: Transition and mobilization Phase II: Decontamination, dismantlement, demolition, and waste disposal activities necessary to achieve partial site release and reduce the SONGS Part 50 license footprint to the ISFSI area only.

SDS will provide project management and field oversight, as well as planning and execution of D&D-related site management and support functions during the decommissioning of SONGS. SCE will perform oversight of SDSs activities, as required by the applicable licenses and permits, and will retain responsibility for license-related operations and security (i.e., spent fuel pool, fuel transfer, and ISFSI operations).

32 SDSs work scope excludes the ISFSI and switchyard facilities.

33 GTCC waste and spent fuel will be stored on the ISFSI and are not expected to be transported to a disposal facility during SDSs performance of the work.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate Phase II D&D activities will include:

x Segmenting the SONGS 2&3 reactor vessels and internals, and loading them into storage containers.

x Removing and disposing of large components including SONGS 2&3 reactor pressure vessels, steam generators, pressurizers, and turbine-generators.

x Decontaminating and removing all structures, systems, and components as necessary to achieve partial site release and reduce the Part 50 license to the ISFSI area only.

x Removing certain above-seabed components of the ocean conduits.

x Necessary backfill work to achieve level grade for the power block area at an elevation of +30.0 feet. 34 x Development of the partial site release plan in accordance with 10 C.F.R. § 20.1402 site release criteria. SDS will perform necessary D&D work to meet a radiological release criteria that does not exceed 15 millirem per year. 35 The work scope under DGC contract does not include removing the intake/discharge structure beneath the seawall; ocean conduits; seawall and pedestrian walkway; gunite slope protection; and certain railroad track and site access roads.

Support for SCE-Retained Responsibilities SCE will remain the licensed operator for NRC licenses associated with SONGS and will retain responsibility for interfacing and corresponding with the regulatory agencies in the management of licenses. 36 SCE will also continue to be the primary interface with the Navy (property owner), and the regulatory agencies and other government authorities responsible for existing permits and the issuance of new permits necessary to perform decommissioning. SDS will support SCE interface with the regulatory agencies and the Navy. 37 34 Backfill material is excluded from the fixed price portion of SDSs contract scope.

35 Per 10 C.F.R § 20.1402, the NRC site release criteria is 25 mrem per year calculated as the peak annual Total Effective Dose Equivalent (TEDE) dose expected within the first 1,000 years after decommissioning. Release criteria is defined as residual radioactivity that is distinguishable from background radiation which results in a TEDE to an average member of the critical group, including that from groundwater sources of drinking water, and has been reduced to levels that are as low as reasonably achievable (ALARA).

36 Nuclear operations are defined as operations and administration of installed, in-service structures, systems, and components within the Protected Area (PA).

37 SCE will retain responsibility for personnel screening for access and badging to the SONGS protected areas (PAs) and vital areas (VAs) until all spent fuel is removed from the spent fuel pools and placed into storage on the ISFSI and the associated security plans are revised and approved. When the PAs/VAs are reduced to the ISFSI only, SCE will transition this responsibility to SDS for all areas except the ISFSI. SCE will retain responsibility for the 22

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate

4. Substructure Removal The substructure removal work will include the activities necessary to achieve the final end state requirements determined by the Navy (which are incremental to the NRC partial site release requirements that will be met during SDSs major D&D work). SCE currently plans to select a contractor to perform the substructure removal work in the mid-2040s.

For purposes of preparing the 2017 DCE, Kenrich retained High Bridge Associates to review and update the 2014 DCE estimate for the removal of substructures below 3 feet below grade.

More specifically, substructure removal activities will include the following:

x Removing substructure systems and components required to achieve end state requirements set forth in the applicable Navy real estate authorization for the SONGS Site. This work will include cleanup, remediation, and/or removal of structures, systems, and components, soils/debris, and/or contaminated groundwater, as required. 38 x Backfilling excavations and voids with approved material and leveling the SONGS site, as required by regulatory and landowner closure requirements.

x Characterizing, packaging, transporting, processing, and disposing of SONGS waste as required to support the regulatory and landowner closure requirements.

x Removing the existing seawall and intake and outfall box culvert.

Excluded from the substructure removal work are the demolition and removal of the ISFSI after the spent nuclear fuel and GTCC waste is removed by the DOE. Also excluded is the other final site restoration work to meet requirements related to the final termination of the SONGS site easements (e.g., ocean conduits, gunite slopes, drainage requirements, access roads, etc.).

The estimated substructure removal costs are summarized in the table below.

industrial and commercial security requirements at SONGS until the security plans are revised and the NRC approves the reduction of the PA/VAs to the area associated with the on-site ISFSI. SDS will take over this responsibility following the transfer of all spent fuel and GTCC to the ISFSI and the implementation of the associated revised security plans.

38 The activities may also include removal of certain above grade facilities remaining after the major D&D work performed by SDS, potentially including non-essential utilities, parking areas, roads, and other improvements.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate TABLE 6 SUBSTRUCTURE REMOVAL ESTIMATE

($ IN THOUSANDS)

Recorded Estimate To Total Estimate Total Estimate Through 2016 Complete At Completion At Completion Description (Nominal $) (2017$) (Nominal /2017$) (2014$)

1 Substructure Removal 2 Excavation and Dewatering $ - $ 152,819 $ 152,819 $ 145,563 3 Demolition and Backfill - 108,277 108,277 102,573 4 Other - 8,833 8,833 8,386 5 Removal of Seawall and Box Culvert - 17,410 17,410 16,520 6 Substructure Removal $ - $ 287,340 $ 287,340 $ 273,042

5. Offshore Conduit Removal As was the case for the 2014 DCE, uncertainty remains regarding the requirements for removal of the offshore intake and outfall conduits located below the sea floor. For SONGS 1, the CSLC has allowed the SONGS 1 conduits to remain in place provided that the SONGS 1 Participants retain the liability to remove the SONGS 1 conduits should that be deemed by the CSLC to be necessary at a future date. For these reasons, the 2017 DCE continues to include an estimated cost to perform the full removal of the SONGS 2&3 offshore conduits as was estimated in the 2014 DCE. The 2017 DCE includes $96.0 million to fully remove the SONGS 2&3 offshore conduits.

6. ISFSI Demolition Following the removal of all spent fuel and GTCC waste by the DOE, SCE will demolish and remove the ISFSI and perform activities necessary for the final restoration of the SONGS site. At the time the 2014 DCE was prepared, the specific plans to expand the ISFSI had not been defined. Later in 2014, SCE entered into a contract with Holtec to expand the ISFSI.

Kenrich retained High Bridge Associates to update the ISFSI demolition estimate in the 2014 DCE to reflect the Holtec ISFSI pad. The updated estimate for ISFSI demolition is $20.2 million.

7. Final Site Restoration The final restoration work includes the removal of the gunite slope protection; remaining railroad tracks, rails, and ballast; access roads and parking lots. In addition, this work includes any other work required by the Navy real estate authorization, which is expected to include the final grading and re-vegetation of the SONGS site. The total estimated final site restoration work in the 2017 DCE is $7.3 million. The 2014 DCE included, as part of final site restoration, the costs to remove the intake and outfall structure underneath the seawall, which required installing and removing dewatering equipment and a temporary seawall. The intake and outfall structure beneath the seawall, as well as the seawall itself, are now expected to be removed 24

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate during the civil works project (i.e., Period 6, 2046-2049). Therefore, the second dewatering process and temporary seawall are no longer necessary during final site restoration.

8. Other Distributed Projects In addition to the major decommissioning projects discussed above, SCE must also perform other projects to comply with federal and state regulations and the terms of SCEs real estate authorizations with the Navy. These other projects and their associated estimated costs are shown in Table 7 and discussed in more detail below.

TABLE 7 OTHER DISTRIBUTED PROJECTS ESTIMATE

($ IN THOUSANDS)

Recorded Estimate To Total Estimate Total Estimate Through 2016 Complete At Completion At Completion Description (Nominal $) (2017$) (Nominal /2017$) (2014$)

1 Other Projects 2 ISFSI Aging Management $ 385 $ 38,376 $ 38,761 $ 36,489 3 Coastal Development Permit Extensions - 5,580 5,580 5,252 4 GTCC Waste Storage - 28,270 28,270 26,632 5 Mesa Site Turnover 7,245 13,967 21,212 20,341 6 CEQA Permitting 3,169 5,162 8,331 7,914 7 Initial Real Estate Authorization Renewal And Plant Easements 646 14,658 15,305 14,427 8 Plant Lease Extension - 4,118 4,118 3,878 9 Plant Lease Amendment For Final Site Restoration - 9,290 9,290 8,745 10 Cyber Security Modifications 8,513 1,131 9,644 9,380 11 DCE Update - 3,897 3,897 3,669 12 GTCC Disposal - 43,200 43,200 40,662 13 ISFSI CDP Settlement - 4,543 4,543 4,277 14 Substructure Removal Contractor Procurement - 7,447 7,447 7,011 15 NIA Sump Modifications - 1,150 1,150 1,081 16 Other Projects Total $ 19,959 $ 180,789 $ 200,748 $ 189,758

a. ISFSI Aging Management The Aging Management project was established to develop inspection and maintenance programs for the Areva and Holtec spent fuel dry storage systems. Also included are initial cask testing, inspection equipment and licensing costs for dry cask NRC Certificate of Compliance (CoC) renewals, and Safety Analysis Report (SAR) updates. Ongoing required annual maintenance and inspections of the spent fuel dry storage systems are included in the undistributed non-labor Aging Management category.

b. Coastal Development Permit Extensions SCE holds a Coastal Development Permit for the storage of SONGS 2&3 spent fuel in the Areva ISFSI system until November 2022, and a separate CDP to store SONGS 2&3 spent fuel in the Holtec ISFSI system until 2035. Therefore, SCE will need to obtain CDP extensions 25

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate from the CCC for the Areva and Holtec ISFSI systems prior to the expiration of the permits in 2022 and 2035, respectively.

c. GTCC Waste Storage As part of the DGC contract, SDS is responsible for preparing, characterizing, and packaging the GTCC waste into canisters, with the exception of the relatively small amount of GTCC waste which currently resides in the spent fuel pools and will be loaded by Holtec.

Holtec will supply the GTCC canisters and is also responsible for transferring the loaded GTCC waste canisters to the ISFSI pad. The estimated costs cover the purchase and licensing of GTCC canisters, as well as their transfer from the containment buildings to the ISFSI pad.

d. Mesa Site Turnover SCEs Mesa site consists of five parcels leased from the Navy. Parcel 5 is on the west side of U.S. Interstate Highway 5 (I-5) and includes a security station to control access to Parcels 6 and 7. Parcels 6 and 7 are located on the east side of I-5 and comprise the largest portion of the Mesa site. Parcels 8 and 9 include a parking lot and lay-down area on the west side of I-5.

SCE currently estimates that Parcels 5, 6, and 7 will be returned to the Navy in 2021, and Parcels 8 & 9 will be retained until the end of decommissioning. As part of the process to return the parcels to the Navy, SCE must first remediate any contamination and obtain No Further Action Letters from the California Department of Toxic Substances Control (DTSC) indicating the property is available for unrestricted use. 39 The estimated cost associated with the project is based on currently anticipated remediation requirements.

e. CEQA Permitting (California State Lands Commission)

Under CEQA, the CSLC, as lead agency, is required to evaluate the SONGS decommissioning project and prepare an Environmental Impact Report (EIR) in response to SCEs application to modify and extend the existing CSLC lease regarding the offshore conduits.

The CEQA permitting process began in 2015. The CSLC is expected to issue a draft EIR in the second quarter of 2018 and issue its Final EIR in the third quarter of 2018. The California Coastal Commission is then expected to review an application for a CDP based on the EIR, as well as its own additional analysis. The CCC is expected to approve the CDP in the fourth quarter of 2018. Following the receipt of the CDP, the physical decommissioning of the plant can proceed.

39 On April 24, 2017, the DTSC issued a No Further Action Letter for Parcel 5. The efforts to assess and remediate contamination for Parcels 6 and 7 are ongoing. SCE continues to hold Parcel 5 as it provides access to Parcels 6 and 7.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate

f. Real Estate Authorization Renewals and Plant Lease Amendments The current SONGS Plant Easement with the Navy expires in 2024. SCE will therefore seek an extension (new real estate authorization) covering the time to complete major decommissioning activities. As a federal agency, the Navy must undertake a NEPA environmental review prior to issuing a new real estate authorization. The initial NEPA process is expected to be completed in 2024 and will allow SCE to continue using the property until 2035.

In 2030, SCE will begin the process to further extend the lease from 2035 until such time the property is projected to be to be turned over to the Navy. In 2040, the Navy is expected to undertake another NEPA review to determine the final site restoration conditions, including the substructure removal requirements. These end-state requirements should be determined by 2045, prior to beginning the civil works project in 2046.

g. Cyber Security Modifications NRC regulations require a Cyber Security Plan at SONGS to ensure certain digital assets, such as computer and communication systems and networks, are secure and protected. SCE has implemented 7 of 8 Cyber Security Plan milestones. At the end of 2017 the NRC granted approval for a license amendment to remove the cyber security license condition, thus waiving the requirement to implement Milestone 8.

h. DCE Update As part of the NDCTP, SCE is required to submit an updated DCE for approval by the CPUC.

i. GTCC Disposal Presently, a disposal facility licensed to accept GTCC waste does not exist in the United States. Courts have determined that the DOE is obligated to accept and dispose of GTCC waste; however, issues regarding costs remain unsettled. For purposes of the 2017 DCE, the cost of shipping and disposing of a GTCC canister was assumed to equal the cost associated with a canister of SONGS spent fuel. The one-mill fee per kilowatt-hour of generation under the Standard Contract was used to estimate this cost.

j. ISFSI CDP Settlement In August 2017, SCE reached a settlement agreement with parties opposed to the storage of spent fuel at SONGS. As part of that settlement, SCE agreed to incur up to $4 million on commercially reasonable efforts to identify an alternative location for SONGS spent fuel storage.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate SCE also incurred third-party legal costs to reach the settlement. Given the ongoing analysis and current uncertainty relating to the potential location and requirements of an acceptable alternative spent fuel storage site, the associated costs with moving to an alternative site have not been included in this DCE.

k. Substructure Removal Contractor Procurement In 2044, SCE will begin efforts to procure a contractor for the removal of SONGS substructures and placement of permanent backfill. The 2017 DCE therefore includes costs to cover a competitive bidding process, including the development of a Request for Proposal, proposal evaluation, and contract award. For purposes of this DCE, the effort was assumed to be approximately one-half the expended cost to procure a DGC for the major D&D work.

l. NIA Sump Modifications The NIA sump currently discharges to the SONGS 2&3 dilution water system. The dilution water system will be retired by SDS, and therefore the discharge pathway for the NIA sump will need to be modified. Kenrich utilized the current budget estimate provided by the cognizant SCE Project Manager.

E. Undistributed Costs Undistributed costs represent activities or fees, necessary to oversee, manage and support the overall decommissioning project. Undistributed costs are sometimes referred to as collateral, indirect, or level of effort costs. By their nature, such costs are not assignable to specific activities representing the physical work performed to decommission a nuclear plant.

Undistributed activities and cost items are characterized by a uniform rate of activity over a specific period of time. Accordingly, undistributed costs were estimated for each decommissioning period. Within each period, the undistributed costs are incurred at a fixed rate and are thus largely time-dependent.

The table below summarizes the undistributed costs incurred through 2016 and future costs estimated for each decommissioning period. The costs are also segregated between labor and non-labor. The labor items include staff to provide oversight, management and other support. Non-labor items include costs associated with services performed by third-parties, as well as rents, fees, and other costs necessary to ensure compliance with regulatory and other requirements.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate TABLE 8 UNDISTRIBUTED COST ESTIMATE (NOMINAL/2017$ IN THOUSANDS)

Period 1 Period 2 Period 3 Period 4 Period 5 Period 6 Period 7 ISFSI Transition Demolition &

Initial and Pool D&D and D&D and Civil Works Final Site Total Activities Storage Pool Storage Dry Storage Dry Storage Project Restoration (Nominal/

Description (Nominal $) (2017$) (2017$) (2017$) (2017$) (2017$) (2017$) 2017$)

1 Start 6/7/2013 1/1/2017 1/1/2019 6/1/2019 1/1/2029 1/1/2046 1/1/2050 2 End 12/31/2016 12/31/2018 5/31/2019 12/31/2028 12/31/2045 12/31/2049 12/31/2051 3 Duration (Years) 36 20 04 96 17 0 40 20 4 Undistributed Activities 5 Labor-Staffing 6 Site Management & Administration $ 19,393 $ 3,379 $ 71,195 $ 16,666 $ 13,265 $ 1,901 7 Plant Management 46,774 8,140 46,085 85,274 20,799 2,340 8 Decommissioning Oversight 14,417 4,916 136,266 13,417 27,121 8,919 9 Utility Staff Subtotal $ 245,555 $ 80,583 $ 16,436 $ 253,546 $ 115,356 $ 61,185 $ 13,159 $ 785,820 10 Security Force 91,073 45,231 6,518 31,254 57,448 14,012 1,576 247,112 11 Labor-Staffing Subtotal $ 336,628 $ 125,814 $ 22,954 $ 284,800 $ 172,804 $ 75,196 $ 14,735 $ 1,032,932 12 13 Non-Labor 14 Aging Management $ - $ - $ 48 $ 4,209 $ 10,018 $ 1,955 $ - $ 16,230 15 Association Fees and Expenses 817 1,332 251 3,910 1,958 478 215 8,961 16 Community Engagement Panel 2,304 1,640 279 5,482 2,405 566 283 12,958 17 Contracted Services 67,641 33,556 3,957 59,073 50,430 16,086 4,349 235,092 18 DAW Disposal - 32 - - - - - 32 19 Decommissioning Advisor 2,515 1,231 278 6,392 - - - 10,416 20 DGC Executive Oversight Committee - 508 144 3,306 - - - 3,958 21 Emergency Preparedness Fees 9,099 3,792 864 15,081 16,998 4,146 - 49,980 22 Energy 16,964 7,571 2,241 45,194 10,983 4,117 526 87,596 23 Environmental Permits and Fees 3,081 662 14 328 1,064 1,154 576 6,879 24 Ground Water Monitoring - - - - 391 92 46 529 25 Information Technology 12,886 5,248 479 7,494 2,486 3,033 1,365 32,991 26 Insurance 13,824 4,778 977 15,947 22,029 5,688 2,479 65,722 27 Third Party Legal 4,336 2,579 479 7,571 7,648 2,300 230 25,142 28 NRC Fees 4,566 2,836 248 9,169 10,369 2,455 2,646 32,291 29 Office Space - - - 1,173 391 92 92 1,748 30 Security Related Expenses 1,552 1,209 422 1,017 5,461 2,192 526 12,378 31 Severance 89,594 9,135 6,001 9,782 2,367 - 6,165 123,044 32 Site Lease and Easement Expenses 8,049 5,710 1,039 21,040 47,825 11,552 5,930 101,145 33 Loading Spent Fuel & GTCC Waste To DOE - - - - 17,940 14,628 - 32,568 34 Tools and Equipment 49 - - - - - - 49 35 Water 1,663 1,224 184 4,243 7,261 1,771 797 17,143 36 Utility Staff Health Physics Supplies 2,163 979 9 198 352 83 41 3,825 37 Non-Labor Subtotal $ 241,104 $ 84,020 $ 17,913 $ 220,608 $ 218,376 $ 72,388 $ 26,266 $ 880,676 38 39 Service Level Agreements 10,647 27,510 4,518 83,094 20,521 22,210 9,143 177,643 40 DGC Staffing 41 Undistributed Activities Subtotal 42 43 Distributed Projects 44 45 Total $ 4,702,264 29

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate TABLE 9 UNDISTRIBUTED COST ESTIMATE (2014$ IN THOUSANDS)

Period 1 Period 2 Period 3 Period 4 Period 5 Period 6 Period 7 ISFSI Transition Demolition &

Initial and Pool D&D and D&D and Civil Works Final Site Activities Storage Pool Storage Dry Storage Dry Storage Project Restoration Total Description (2014$) (2014$) (2014$) (2014$) (2014$) (2014$) (2014$) (2014$)

1 Start 6/7/2013 1/1/2017 1/1/2019 6/1/2019 1/1/2029 1/1/2046 1/1/2050 2 End 12/31/2016 12/31/2018 5/31/2019 12/31/2028 12/31/2045 12/31/2049 12/31/2051 3 Duration (Years) 36 20 04 96 17 0 40 20 4 Undistributed Activities 5 Labor-Staffing 6 Site Management & Administration $ 18,179 $ 3,175 $ 66,883 $ 15,656 $ 12,462 $ 1,785 7 Plant Management 43,882 7,647 43,293 80,109 19,539 2,198 8 Decommissioning Oversight 13,537 4,618 128,012 12,604 25,478 8,378 9 Utility Staff Subtotal $ 242,544 $ 75,598 $ 15,440 $ 238,189 $ 108,369 $ 57,478 $ 12,362 $ 749,981 10 Security Force 89,640 42,456 6,123 29,360 53,968 13,163 1,481 236,192 11 Labor-Staffing Subtotal $ 332,184 $ 118,054 $ 21,564 $ 267,549 $ 162,337 $ 70,641 $ 13,843 $ 986,172 12 13 Non-Labor 14 Aging Management $ - $ - $ 45 $ 3,958 $ 9,421 $ 1,838 $ - $ 15,262 15 Association Fees and Expenses 800 1,277 237 3,701 1,882 459 207 8,564 16 Community Engagement Panel 2,267 1,556 267 5,268 2,311 544 272 12,486 17 Contracted Services 66,942 31,650 3,736 55,800 47,718 15,215 4,102 225,164 18 DAW Disposal - 30 - - - - - 30 19 Decommissioning Advisor 2,470 1,156 261 6,011 - - - 9,899 20 DGC Executive Oversight Committee - 477 135 3,109 - - - 3,722 21 Emergency Preparedness Fees 9,047 3,645 830 14,496 16,339 3,985 - 48,341 22 Energy 16,840 7,277 2,154 43,440 10,557 3,957 506 84,732 23 Environmental Permits and Fees 3,065 636 14 312 1,007 1,108 553 6,695 24 Ground Water Monitoring - - - - 368 87 43 497 25 Information Technology 12,845 4,945 454 7,117 2,361 2,881 1,296 31,900 26 Insurance 13,779 4,592 939 15,328 21,175 5,467 2,383 63,663 27 Third Party Legal 4,234 2,425 451 7,119 7,192 2,163 216 23,799 28 NRC Fees 4,539 2,725 239 8,813 9,967 2,360 2,544 31,187 29 Office Space - - - 1,104 376 88 87 1,655 30 Security Related Expenses 1,536 1,150 403 973 5,166 2,069 496 11,792 31 Severance 89,524 8,599 5,657 9,222 2,232 - 5,812 121,047 32 Site Lease and Easement Expenses 7,996 5,488 999 20,223 45,970 11,104 5,700 97,481 33 Loading Spent Fuel & GTCC Waste To DOE - - - - 16,870 13,756 - 30,626 34 Tools and Equipment 49 - - - - - - 49 35 Water 1,654 1,176 177 4,078 6,979 1,702 766 16,534 36 Utility Staff Health Physics Supplies 2,103 918 8 187 331 78 39 3,663 37 Non-Labor Subtotal $ 239,691 $ 79,724 $ 17,005 $ 210,259 $ 208,221 $ 68,862 $ 25,023 $ 848,786 38 39 Service Level Agreements 10,278 26,121 4,288 78,793 19,278 20,865 8,589 168,212 40 DGC Staffing 41 Undistributed Activities Subtotal 42 43 Distributed Projects 44 45 Total $ 4,478,566

1. Decommissioning Staffing Since January 2017, SCE and SDS have been working closely to manage and implement the transition of numerous management programs and functions from SCE to SDS. Following this transition, SCE will maintain an oversight role with respect to SDSs contract. SCE will continue to be responsible for the ISFSI project, for ongoing nuclear operations, security, and other distributed projects (e.g., ISFSI Aging Management, Mesa Turnover). Following the completion of the SDS D&D contract, SCE will take back over the performance of the on-site programs and functions that had been transitioned to SDS.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate With contracts now in place for the majority of the SONGS decommissioning work, SCE was able to carefully evaluate its own staffing needs. As part of the process to develop the staffing projections, each SONGS division was grouped into the following categories.

Site Management & Administration - Responsible for oversight and strategic planning, ensuring compliance with regulatory and permitting requirements, safety, security, and overall project cost and schedule.

Plant Management - Responsible for the operations, maintenance, and security of the plant facilities. Staffing levels are expected to decrease significantly after the nuclear fuel is transferred from the spent fuel pool to the ISFSI pad.

Project Oversight - Responsible for oversight of the SDS D&D contract, management of the ISFSI, and other distributed projects. The oversight role ensures all work is completed safely and in compliance with the contract, government regulations, and permits. The staffing levels will vary over the duration of the project based on the amount of physical work being performed (e.g., the number of radiological oversight personnel will decrease after D&D is complete).

As part of the process to estimate staffing needs, senior management met with SONGS division managers to identify major activities during each phase of the decommissioning project.

The estimated staffing for each period was based on a bottom up assessment of each needed discipline and position. Kenrich also worked with SCE management to vet the underlying assumptions and confirm the rationale underlying the projections. This effort involved numerous interviews of SONGS division managers, an analysis of the plan to transition management and supervision responsibilities from SCE to SDS, and a reconciliation to the staffing levels in the 2014 DCE. 40 Staffing levels at other utilities having nuclear decommissioning experience were reviewed and considered, while also taking into account site-specific requirements and characteristics of SONGS. To further ensure the reasonableness of the SONGS staffing projections, SCE retained ABZ, an industry expert in decommissioning cost estimating. SCE specifically requested ABZ to provide input based on their experiences working with other nuclear utilities and to confirm that the SONGS projections were in line with industry norms.

The table below summarizes the staffing projection by period. The average staffing levels estimated for each period are intended to account for anticipated adjustments within each decommissioning period.

40 The 2014 DCE did not assume the transition of programs to the DGC, therefore the headcount for certain divisions, such as maintenance and radiological control and chemistry, decreased in the 2017 DCE, but the decommissioning oversight positions increased in the 2017 DCE.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate TABLE 10 UTILITY & SECURITY FORCE AVERAGE STAFFING BY PERIOD 41 Period 2 Period 3 Period 4 Period 5 Period 6 Period 7 ISFSI Transition Demolition &

and Pool D&D and D&D and Civil Works Final Site Description Storage Pool Storage Dry Storage Dry Storage Project Restoration 1 Start 1/1/2017 1/1/2019 6/1/2019 1/1/2029 1/1/2046 1/1/2050 2 End 12/31/2018 5/31/2019 12/31/2028 12/31/2045 12/31/2049 12/31/2051 3 Duration (Years) 20 04 96 17 0 40 20 4

5 Site Management & Administration 6 Site Management & Administration 16 11 10 1 3 -

7 Decommissioning Finance 5 8 8 1 4 1 8 Regulatory Affairs & Nuclear Oversight 10 8 8 2 4 4 9 Total Site Management & Administration 30 27 26 4 11 5 10 11 Plant Management 12 Plant Management 1 1 1 1 1 -

13 Operations 40 36 - - - -

14 Radiological Control & Chemistry 13 - - - - -

15 Maintenance, Work Control, & PI/CAP 18 7 7 7 7 3 16 Engineering 15 7 7 7 7 3 17 EP Planning 3 3 2 2 2 1 18 Security 155 158 34 34 34 14 19 Total Plant Management 244 212 51 51 51 20 20 21 Decommissioning Oversight 23 38 45 - 22 16 22 23 Total 296 277 122 55 84 41 The costs associated with the projected staffing is based on average labor rates for each position. The staffing cost estimate includes labor burdens and short-term incentive compensation, and accounts for positions being filled by contractors.

The table below summarizes the labor-staffing costs by each project period.

41 Excludes DGC staffing and third-party contractors at SONGS.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate TABLE 11 UNDISTRIBUTED LABOR COST ESTIMATE (NOMINAL/2017$ IN THOUSANDS)

Period 1 Period 2 Period 3 Period 4 Period 5 Period 6 Period 7 ISFSI Transition Demolition &

Initial and Pool D&D and D&D and Civil Works Final Site Total Activities Storage Pool Storage Dry Storage Dry Storage Project Restoration (Nominal/

Description (Nominal) (2017$) (2017$) (2017$) (2017$) (2017$) (2017$) 2017$)

1 Start 6/7/2013 1/1/2017 1/1/2019 6/1/2019 1/1/2029 1/1/2046 1/1/2050 2 End 12/31/2016 12/31/2018 5/31/2019 12/31/2028 12/31/2045 12/31/2049 12/31/2051 3 Duration (Years) 36 20 04 96 17 0 40 20 4 Utility Staff 5 Site Management & Administration $ 19,393 $ 3,379 $ 71,195 $ 16,666 $ 13,265 $ 1,901 6 Plant Management 46,774 8,140 46,085 85,274 20,799 2,340 7 Decommissioning Oversight 14,417 4,916 136,266 13,417 27,121 8,919 8 Utility Staff Subtotal $ 245,555 $ 80,583 $ 16,436 $ 253,546 $ 115,356 $ 61,185 $ 13,159 $ 785,820 9 Security Force 91,073 45,231 6,518 31,254 57,448 14,012 1,576 247,112 10 Labor-Staffing Total $ 336,628 $ 125,814 $ 22,954 $ 284,800 $ 172,804 $ 75,196 $ 14,735 $ 1,032,932 TABLE 12 UNDISTRIBUTED LABOR COST ESTIMATE (2014$ IN THOUSANDS)

Period 1 Period 2 Period 3 Period 4 Period 5 Period 6 Period 7 ISFSI Transition Demolition &

Initial and Pool D&D and D&D and Civil Works Final Site Activities Storage Pool Storage Dry Storage Dry Storage Project Restoration Total Description (2014$) (2014$) (2014$) (2014$) (2014$) (2014$) (2014$) (2014$)

1 Start 6/7/2013 1/1/2017 1/1/2019 6/1/2019 1/1/2029 1/1/2046 1/1/2050 2 End 12/31/2016 12/31/2018 5/31/2019 12/31/2028 12/31/2045 12/31/2049 12/31/2051 3 Duration (Years) 36 20 04 96 17 0 40 20 4 Utility Staff 5 Site Management & Administration $ 18,179 $ 3,175 $ 66,883 $ 15,656 $ 12,462 $ 1,785 6 Plant Management 43,882 7,647 43,293 80,109 19,539 2,198 7 Decommissioning Oversight 13,537 4,618 128,012 12,604 25,478 8,378 8 Utility Staff Subtotal $ 242,544 $ 75,598 $ 15,440 $ 238,189 $ 108,369 $ 57,478 $ 12,362 $ 749,981 9 Security Force 89,640 42,456 6,123 29,360 53,968 13,163 1,481 236,192 10 Labor-Staffing Total $ 332,184 $ 118,054 $ 21,564 $ 267,549 $ 162,337 $ 70,641 $ 13,843 $ 986,172

2. Undistributed Non-Labor Costs In addition to staffing, SCE incurs non-labor costs to support the decommissioning efforts. As part of the process to identify and estimate future non-labor costs, historical recorded costs were reviewed in detail. Kenrich worked with knowledgeable SONGS personnel to develop and estimate future decommissioning costs which are summarized in Table 13 and broken down below.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate TABLE 13 UNDISTRIBUTED NON-LABOR COST ESTIMATE

($ IN THOUSANDS)

Recorded Estimate To Total Estimate Total Estimate Through 2016 Complete At Completion At Completion Description (Nominal $) (2017$) (Nominal /2017$) (2014$)

1 Non-Labor 2 Aging Management $ - $ 16,230 $ 16,230 $ 15,262 3 Association Fees and Expenses 817 8,144 8,961 8,564 4 Community Engagement Panel 2,304 10,653 12,958 12,486 5 Contracted Services 67,641 167,451 235,092 225,164 6 DAW Disposal - 32 32 30 7 Decommissioning Advisor 2,515 7,901 10,416 9,899 8 DGC Executive Oversight Committee - 3,958 3,958 3,722 9 Emergency Preparedness Fees 9,099 40,881 49,980 48,341 10 Energy 16,964 70,631 87,596 84,732 11 Environmental Permits and Fees 3,081 3,798 6,879 6,695 12 Ground Water Monitoring - 529 529 497 13 Information Technology 12,886 20,105 32,991 31,900 14 Insurance 13,824 51,898 65,722 63,663 15 Third Party Legal 4,336 20,807 25,142 23,799 16 NRC Fees 4,566 27,724 32,291 31,187 17 Office Space - 1,748 1,748 1,655 18 Security Related Expenses 1,552 10,826 12,378 11,792 19 Severance 89,594 33,450 123,044 121,047 20 Site Lease and Easement Expenses 8,049 93,096 101,145 97,481 21 Tools and Equipment 49 - 49 49 22 Water 1,663 15,480 17,143 16,534 23 Utility Staff Health Physics Supplies 2,163 1,662 3,825 3,663 24 Loading Spent Fuel & GTCC Waste To DOE - 32,568 32,568 30,626 25 Non-Labor Total $ 241,104 $ 639,572 $ 880,676 $ 848,786

a. Aging Management Aging Management programs cover both the Areva and Holtec dry storage systems. In addition to the scope covered by the distributed Aging Management project, the programs include annual facility maintenance and inspection as well as in-service canister inspections every five years, in compliance with the respective Areva and Holtec SARs.

The Areva Aging Management undistributed costs begin in 2022, after the NRC Certificate of Compliance is renewed. These costs continue until the DOE is assumed to accept the final Areva canister from SONGS in 2037. The Holtec Aging Management costs begin in 2019 after all of the fuel has been transferred from the SONGS 2&3 spent pools to the ISFSI, and then continue until the DOE is assumed to accept the final Holtec canister in 2049.

b. Association Fees and Other Expenses Association Fees and Other Expenses include Nuclear Energy Institute (NEI) membership fees, costs related to an external Nuclear Oversight Board (NOB), and an outside 34

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate advisor to SCEs Internal Nuclear Management Group (INMG). SCE remains an NEI member to obtain access to industry policies, standards, and guidance regarding decommissioning. The NOB is composed of independent review specialists who provide independent review of decommissioning activities.

NEI Fees are estimated to be incurred through Period 7 (ISFSI Demolition & Final Site Restoration); NOB costs are expected through Period 4 (major D&D); and SCE anticipates retaining an outside advisor to the INMG until 2022.

c. Community Engagement Panel The SONGS Community Engagement Panel (CEP) holds periodic meetings with the public to provide information on various issues, including decommissioning plans, spent fuel management, emergency planning, security, and the environmental review process. CEP costs are estimated to be incurred through the end of Period 7 (ISFSI Demolition & Final Site Restoration). The annual estimate is based on the 2018 budgeted amounts per CEP meeting, and is adjusted proportionately based on the number of meetings estimated each year. Six CEP meetings are assumed in 2018, four CEP meetings per year are estimated during major D&D, through 2028, and one meeting per year is assumed after major D&D is complete.

d. Contracted Services Contracted Services generally consist of shorter-term supplemental resources, specialty contractors and consultants, third-party services, materials, equipment, and supplies. SONGS senior management, division managers, and Kenrich worked together to identify and estimate the projected costs. Contracted Services costs were estimated for each decommissioning period in each of the following divisions: (1) Decommissioning Projects / Decommissioning Oversight; (2) Engineering; (3) Emergency Preparedness; (4) Maintenance; (5) Nuclear Oversight, Safety, Regulatory Affairs; (6) Operations; (7) Decommissioning Finance; and (8) Site Management &

Administration.

Similar to the undistributed staffing, the projected needs for Contracted Services are reduced after major decommissioning milestones are achieved. For example:

x Transition of SONGS Programs to SDS - SDS will assume responsibility for the management of numerous SONGS programs by the end of 2017.

Accordingly, the estimated costs for contracted services in the Maintenance and Decommissioning Projects divisions are significantly lower in 2018.

x Completion of Fuel Transfer Operations - After all spent fuel has been transferred to the ISFSI, the Operations division and its associated contracted services will no longer be needed.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate x D&D Complete - Many of the contracted services costs in the Decommissioning Oversight and Site Management & Administration divisions will not be needed after SDS completes its work and the SONGS programs are reduced.

e. Decommissioning Advisor The Decommissioning Advisor provides subject matter expertise and assistance on various matters, including regulatory issues, spent fuel storage, and project management.

Decommissioning Advisor costs are estimated through Period 4 (D&D).

f. DGC Executive Oversight Committee The SDS D&D contract requires an Executive Oversight Committee composed of five individuals charged with resolving contractual issues. The committee includes one person each from SCE and SDS, and three independent third-party members. SCE and SDS share the costs of the third-party positions.

g. Emergency Preparedness Fees SCE provides funding to local jurisdictions for the management of radiological emergency preparedness, including planning, response, and recovery activities. Currently, SCE pays fees in accordance with a December 2015 Memorandum of Understanding (MOU) covering a period through 2020. The Emergency Preparedness fees are assumed to be paid annually until all spent fuel has been removed from SONGS.

h. Energy SCE must purchase energy from the grid to power the site, including loads required for decommissioning work. The energy costs are based on historical retail electricity rates and on projected usage. The projected usage was prepared by SCE Engineering and reflects the major activities in each decommissioning period.

i. Environmental Permits And Fees SONGS must comply with a variety of environmental regulations and maintain numerous permits, which involve the payment of fees. These permits and associated fees include: (1) the State Water Resource Control Board National Pollutant Discharge Elimination System (NPDES) permit fees and Stormwater Pollution Prevention Plan (SWPPP) fees; (2) State of California Board of Equalization mixed waste fees; (3) fees for the California Department of Environmental Health Permit, which includes the permit for Underground Storage Tanks; (4) Air Pollution Control District Permit (APCD) fees; (5) Diesel Generator permit fees; (6) California Coastal 36

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate Commission fees; (7) Refrigerant Management Program; and (8) Kelp consortium costs for monitoring and surveying ocean kelp.

During the D&D period, SDS will be responsible for certain permits and fees, including the NPDES permit, mixed waste fee, SWPPP fee, and APCD permit. However, SCE will continue to maintain other permits and incur other fees (e.g. Department of Environmental Health fees, Diesel Generator air permits, CCC fees, and Refrigerant Management Program fees) through this period.

j. Ground Water Monitoring SCE is required to monitor the ground water beneath the site for the presence of tritium.

The costs include sampling, analysis, and monitoring performed by third-party contractors and will be required through the end of SONGS decommissioning. During the D&D period, SDS will assume responsibility for ground water monitoring.

k. Information Technology Information Technology (IT) costs include SONGS software and network licenses, internal technical support, and payments to network service providers. IT costs are expected to decrease after 2018 after one-time IT projects are completed, and ongoing support costs will be reduced after 2019. 42

l. Insurance NRC regulations require that SCE maintains a minimum level of nuclear liability and property insurance, including Nuclear Property Insurance (provided by Nuclear Electric Insurance Limited) and Nuclear Liability Insurance (provided by American Nuclear Insurers). 43 SCE must maintain nuclear-related insurance coverage until the spent nuclear fuel is removed from the SONGS site. 44 In addition, SCE also maintains General Liability Insurance and Excess Workers' Compensation Insurance, the cost of which is generally a function of SONGS headcount.

Historical costs were used as the primary basis to estimate future insurance costs.

42 Separately, SONGS also incurs costs associated with support provided by SCE corporate IT personnel and resources. The costs for such additional IT support are provided via a Service Level Agreement with SCE.

43 Should the Participants choose to reduce current insurance coverage amounts, the future premiums would be reduced accordingly. In December 2017, the Participants received an exemption from the NRC allowing them to reduce insurance coverage.

44 Insurance requirements per NRC regulations 10 C.F.R § 50.54(w) and 10 C.F.R § 140.11.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate

m. Third Party Legal SCE retains outside counsel as necessary to handle legal matters that require specific expertise, or when legal matters require additional resources. For example, SCE engaged outside counsel to support decommissioning licensing proceedings before the NRC, and environmental/land use permitting proceedings before the CCC, CSLC, and other government agencies.

n. NRC Fees The NRC charges two different types of fees to nuclear reactor licensees: (1) annual fees (Part 171 Fees), and (2) inspection fees (Part 170 Fees). The Part 171 Fees are fixed annual payments per licensee (i.e., an annual fee for each SONGS unit), including nuclear plants that have been permanently retired. The Part 171 fees are to cover generic (i.e., non-licensee specific) activities performed by the NRC. In contrast, the NRC charges licensees Part 170 Fees based on the time it spends on performance reviews, evaluations, incident investigations, and other activities that are specific to an individual licensee.

o. Office Space Following the completion of major D&D, SCE will need to lease office space for the remaining employees as all the existing office space on the SONGS site will have been removed.

The costs to install trailers and annual lease payments are included in the estimate. During major D&D, SDS is responsible for providing SCEs office space.

p. Security Related Expenses Security Related Expenses include uniforms, weapons, ammunition, and other supplies and equipment to support the SONGS Security Force, as well as background investigations, training costs, and vendor support.

q. Severance Under the California Nuclear Facilities Decommissioning Act of 1985, 45 SCE employees at SONGS who are severed as a result of the shutdown and permanent retirement of SONGS are eligible for severance benefits. These benefits include lump sum cash payments based on years of service, outplacement services, and reimbursement for educational expenses.

45 California Public Utilities Code § 8322(g).

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate

r. Site Lease And Easements SCE makes annual lease and easement payments to the Navy for the SONGS plant site and Mesa, and to the CSLC for the SONGS offshore conduits. The current site lease with the Navy ends in 2024. As previously discussed, SCE expects to negotiate a new lease to cover the period after 2024 through the end of Period 7 (ISFSI Demolition and Final Site Restoration).

The rate per acre in the new plant site lease agreement is expected to increase to account for the fair market value of the property.

The Mesa lease payments to the Navy are expected to remain consistent with the current agreement until Mesa Parcels 5, 6, and 7 are returned to the Navy in 2021. The conduits lease payments to the CSLC are expected to remain consistent with the current agreement, which includes periodic increases in lease payments, through the end of Period 7 (ISFSI Demolition and Final Site Restoration).

s. Water Utilities includes expenses for water provided by the South Coast Water District (SCWD)

Joint Regional Water Supply System (JRWSS). Costs were estimated based on historical recorded costs.

t. Utility Staff Health Physics Supplies Health Physics (also referred to as HP or Radiation Protection) supplies, including personal radiological monitoring and protection equipment, are used by personnel performing work in radiological areas of the plant. Beginning in 2018, SDS will assume responsibility for the radiation protection program. SCE will resume responsibility after the D&D work is performed. Minimal Health Physics supplies will be needed to support the ISFSI only staff as virtually all contaminated materials will have been removed from the site.

u. Loading Spent Fuel And GTCC Waste To DOE Under the Standard Contract with the DOE, SCE is responsible for transferring canisters from the ISFSI and loading them into DOE shipping containers on-site. The estimate assumes the DOE will accept the loaded canisters and that a dry fuel transfer facility is not necessary.

The DOE will take title to the waste after it is loaded onto the DOEs transport device and the carrier signs for the shipment at the plant site. For purposes of the 2017 DCE, DOE loading costs are assumed to equal approximately 50% of the costs to load and transfer the spent fuel to the ISFSI. The timing of the DOE loading costs is based on the assumed Spent Fuel Shipping Schedule (Appendix A).

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate

3. Service Level Agreements For Administrative & General Expenses The 2014 DCE included 5% on all estimated costs to account for SCEs administrative and general (A&G) expenses supporting the SONGS decommissioning project. Beginning in 2016, SCE started to develop Service Level Agreements (SLAs) between the SONGS Participants and the SCE departments that support SONGS decommissioning. The SLAs are intended to provide additional transparency with respect to types of costs and level of support needed. There are separate SLAs for each SCE department supporting SONGS (e.g., Human Resources, IT, Legal, CPUC Regulatory Affairs). Beginning in 2029, after Period 4 is completed, corporate support functions are estimated in the A&G line item in lieu of separate SLAs, and is calculated as 5% of all other 2029-2051 estimated costs. The table below summarizes the SLAs and their associated estimated costs.

TABLE 14 SERVICE LEVEL AGREEMENT (A&G) COST ESTIMATE

($ IN THOUSANDS)

Estimate To Estimate To Recorded Complete Complete Total Estimate Total Estimate Through 2016 2017 - 2028 2029 - 2051 At Completion At Completion Description (Nominal $) (2017$) (2017$) (Nominal /2017$) (2014$)

1 Service Level Agreements (A&G) 2 Audit Services $ - $ 9,893 $ - $ 9,893 $ 9,404 3 Controllers - 12,193 - 12,193 11,587 4 Corporate Communications 228 1,933 - 2,161 2,043 5 Corporate Security - 2,878 - 2,878 2,754 6 CPUC Regulatory Affairs - 10,982 - 10,982 10,444 7 Decommissioning Finance 1,128 718 - 1,846 1,760 8 Environmental Policy - 1,833 - 1,833 1,726 9 Environmental Services 107 2,243 - 2,349 2,211 10 Human Resources - 8,005 - 8,005 7,588 11 Information Governance - 1,092 - 1,092 1,033 12 Information Technology 7,037 24,820 - 31,857 30,461 13 Legal - 10,883 - 10,883 10,226 14 Local Public Affairs - 764 - 764 719 15 Real Properties 247 659 - 906 856 16 Risk Management - 300 - 300 283 17 Short Term Incentive Plan (STIP) - 6,050 - 6,050 5,684 18 Supply Management 1,375 9,341 - 10,716 10,147 19 Tax - 1,874 - 1,874 1,787 20 Transportation Services 525 4,989 - 5,514 5,308 21 Treasurers - 3,672 - 3,672 3,461 22 A&G (2029 - 2051) - - 51,874 51,874 48,732 23 Service Level Agreements (A&G) Total $ 10,647 $ 115,122 $ 51,874 $ 177,643 $ 168,212

4. DGC Staffing 40

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate F. 2017 DCE Costs By NRC Cost Category SONGS distributed projects are classified into one of the following three NRC cost categories: (1) License Termination (LT); (2) Spent Fuel Management (SNF); and (3) Site Restoration (SR). License Termination activities are those required to decontaminate the site and reduce residual radioactivity in order to terminate the NRC licenses pursuant to 10 C.F.R § 50.75(c). License termination activities are expected to be completed in 2028, following the SDS D&D work, and NRC approval of the partial site release.

Spent Fuel Management activities are those required to operate and maintain the on-site spent fuel storage facilities until such time the spent fuel is removed by the DOE, in accordance with 10 C.F.R § 50.54(bb). The decommissioning of the ISFSI after the spent fuel is transferred offsite (10 C.F.R § 72.30) is also classified as a Spent Fuel Management activity.

The remaining distributed costs are classified as Site Restoration costs, which are primarily driven by the terms of the easement and lease agreements with the Navy and CSLC.

Site Restoration distributed projects include non-radiological decommissioning activities, such as the removal of non-contaminated substructures below 3 feet below grade.

The classification of distributed projects in this DCE to NRC cost categories is generally consistent with how projects were classified in the 2014 DCE.

Undistributed costs are also assigned to NRC cost categories. Certain undistributed cost items are assignable to a single NRC cost category (e.g., 100% of the annual cost to load spent fuel to the DOE is classified as Spent Fuel Management). However, given their nature, there are many other undistributed cost items which support multiple decommissioning activities (e.g.,

energy costs). These undistributed costs are allocated to License Termination, Spent Fuel Management, and Site Restoration based on the distributed cost amounts in each NRC cost category. 46 The table below summarizes the 2017 DCE costs by NRC cost category.

46 The undistributed costs incurred to date were recorded to each NRC cost category based on the allocation percentages assumed in the 2014 DCE.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate TABLE 15 2017 DCE BY NRC COST CATEGORY

($ IN THOUSANDS)

Recorded Estimate To Total Estimate Total Estimate Through 2016 Complete At Completion At Completion Description (Nominal $) (2017$) (Nominal /2017$) (2014$)

1 License Termination 2 Distributed $

3 Undistributed 4 License Termination Subtotal $ 1,906,728 5

6 Spent Fuel Management 7 Distributed $

8 Undistributed 9 Spent Fuel Management Subtotal $ 1,367,361 10 11 Site Restoration 12 Distributed 13 Undistributed 14 Site Restoration Subtotal $ 166,324 $ 1,098,532 $ 1,264,856 $ 1,204,476 15 16 Total $ 4,478,566 G. Contingency Contingency is used in cost estimates to account for the costs of unplanned events and circumstances that often occur during the performance of a project. As defined in the American Association of Cost Engineers Project and Cost Engineers Handbook, contingency is an amount added to an estimate to allow for items, conditions, or events for which the state, occurrence, or effect is uncertain and that experience shows will likely result, in aggregate, in additional costs.

Examples of costs intended to be covered by contingency include planning and estimating errors and omissions, design development and changes within scope, minor price fluctuations, and variations in the market and environmental conditions. Contingency is not intended to cover all unknowns or unplanned occurrences. For example, contingency usually excludes major scope changes, extraordinary events such as strikes and natural disasters, specified management reserves for defined issues, and general price escalation or currency effects.

The consensus in industry literature is that a primary consideration in determining appropriate amounts for contingency on a particular project is the stage of development and level of confidence in the estimated known base project costs. The 2014 DCE used a 25%

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate contingency factor, 47 which was deemed reasonable by the CPUC in D.16-04-019 given the then-existing level of uncertainty in the then-current DCE. 48 Given the current stage of decommissioning, a lower contingency factor is warranted in some areas. Kenrich and knowledgeable SCE personnel reviewed each major category of costs and determined an individual contingency factor for each group. In determining the contingency factors for each cost grouping, consideration was given to contracting status (e.g., ISFSI and D&D work are under contract), technical complexity, estimating approach, and other variables.

The remaining work associated with ISFSI is primarily the loading and transfer of spent fuel canisters to the ISFSI. The associated contingency factor reflects that this work is under contract and benefits from significant learning and industry experience over many decades. The D&D work is also under contract, following a rigorous competitive procurement process.

However, the contingency factor for this work also accounts for the significant influence of site-specific factors on D&D work. For other distributed work, not currently under contract and planned to occur in the relative distant future, the same 25% contingency factor used in the 2014 DCE was used in this DCE. With regard to undistributed labor and non-labor costs, the associated contingency factors account for a significantly more rigorous process used to develop the estimates contained in this DCE. In contrast to the 2014 DCE, the estimated headcount and non-labor costs for each division were subject to more substantial and iterative internal review and updating processes.

The table below summarizes the contingency factor applied to the to-go costs for each estimate.

47 Contingency of 25% was applied to all costs in the 2014 DCE with the following exceptions: 2013 and 2014 Actual Expenditures 0%; Department of Navy Easement Payments 15%; Hazardous and Asbestos Wastes 50%; Site Characterization Surveys 15%; Temporary Facilities 15%; Backfill and Compaction 15%.

48 Specifically referring to SONGS in its 2012 NDCTP decision, the CPUC stated, [t]he Commission finds the reasonableness of a contingency amount is significantly related to the stage of decommissioning and the activities projected, including particular site-specific challenges. Consequently, the reasonable contingency factor may vary between nuclear plants and at different stages of decommissioning. (D.14-12-082 at 38). Further, in its April 20, 2017 proposed decision pertaining to PG&Es updated cost estimates for the decommissioning of its two nuclear power plants, the CPUC specifically noted that PG&E use of a 25% contingency factor for Diablo Canyon raised questions in light of other information which had been supplied by PG&Es third-party decommissioning cost consultant, TLG Services, Incorporated (TLG). Specially, TLG estimated contingency on a line item basis and the resulting composite contingency factor was 17.4%.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate TABLE 16 CONTINGENCY FACTORS APPLIED IN 2017 DCE Contingency 2017 DCE Category Factor Recorded Costs Through September 2017 0%

ISFSI & Fuel Transfer Operations Substructure Removal 25%

Other Projects 15-25%

Offshore Conduit Removal 25%

ISFSI Demolition 25%

Final Site Restoration 25%

Undistributed Labor 10%

Undistributed Non-Labor 15%

Service Level Agreements 10%

The composite contingency factor included in the 2017 DCE is approximately percent of base estimated costs.

TABLE 17 CONTINGENCY INCLUDED IN THE SONGS 2&3 2017 DCE

($ IN THOUSANDS) 2017 DCE 2017 DCE Description (Nominal /2017$) (2014$)

1 Base Estimated Costs 2 Estimated Contingency 3 Subtotal Estimated Costs $ 3,518,663 $ 3,322,641 4 Recorded Costs 1,183,601 1,155,925 5 Total DCE Value $ 4,702,264 $ 4,478,566 VI. Additional Discussion Regarding The Project Schedule The SONGS decommissioning project schedule defines the sequence and timing of activities, the completion dates for major project milestones, and the duration of each decommissioning period. The 2017 DCE is presented in 2017 dollars. These constant dollars are spread over the duration of the SONGS entire decommissioning project based on the 2017 DCE project schedule. 49 In accordance with the contract, SDS has developed a baseline schedule for completing its major D&D and achieving partial site release. SCE incorporated SDSs Baseline Schedule 49 To assess the adequacy of the amount of funds residing in the Nuclear Decommissioning Trust, the annual constant dollar cash flows are escalated and discounted to present value.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate into the overall decommissioning project schedule on which the 2017 DCE is based. The completion dates were mapped to corresponding 2017 DCE milestones.

As described earlier, the decommissioning schedule is comprised of seven (7) periods.

Each period is generally defined by the major focus of activity on-site, as well as the licensing status of the plant (i.e., from an NRC perspective). SONGS is currently planning and preparing for the physical decommissioning of the plant facilities (Periods 1 and 2). The major D&D work is expected to begin in 2019 and estimated to be completed by late 2028 (Periods 3 and 4). At the conclusion of the major D&D work, all structures, systems, and components on-site will have been removed to at least 3 feet below grade and the NRC Part 50 license will have been reduced to the ISFSI area only.

From 2029 until 2046, when the work to remove the below-grade structures begins, the only significant activity at the site will be the transfer of spent fuel canisters to the DOE (Period 5). During this period, SCE will become informed regarding the regulatory and landowner end-state requirements for the SONGS site. The demolition and removal of the ISFSI and remaining below-grade structures will be performed after 2046 (Periods 6 and 7). This timing of this work is determined in part by the anticipated date by which the DOE is expected to have removed all SONGS spent fuel. The DOE is currently assumed to begin removing SONGS 2&3 spent fuel in 2034 and complete the removal of all fuel by 2049. Final site restoration and license termination is projected to be completed by 2051.

Two critical milestones include the completion of spent fuel transfer operations (i.e.,

transfer of all spent fuel from the wet pools to the ISFSI) in mid-2019 and the completion of major D&D work in late 2028. After each of these milestones, SONGSs licensing status and regulatory requirements change such that the associated costs to manage and support (e.g.,

operations, maintenance, security, management, and contract oversight) the decommissioning of the site will be substantially reduced.

SCE currently anticipates commencing spent fuel transfer operations in 2018 and is targeting completion in early to mid-2019. Fuel transfer operations are relatively complex, subject to extensive regulatory oversight, and intended to be performed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, seven days per week. Accordingly, for purposes of this DCE, SCE included schedule margin in its determination of the June 1, 2019 milestone completion date.

The critical activities driving the overall duration of major D&D work are the removal of the nuclear steam supply system (NSSS) equipment (e.g., reactor vessels, steam generators, reactor coolant pumps) from inside the containment buildings, and then the decontamination, demolition, and removal of the containment buildings. The decontamination, demolition, and removal of other SONGS buildings and facilities will be performed concurrently.

SCE and SDS are continuing to plan and schedule major D&D work. Currently, SDS intends to complete the physical decommissioning work in 2025 and obtain final NRC approval of the final site survey and partial site release in 2026. SDSs schedule is currently based on performing the preparation and segmentation of the reactor vessel internals and NSSS large component removal at both Units 2 and 3 in parallel. These activities include relatively high-risk 45

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate cutting and material handling operations. As another example of uncertainty that is currently inherent in the major D&D schedule, SCE is currently planning for increased radiological decontamination efforts associated with the below-grade structures that will remain at SONGS after SDS completes its work. Accordingly, for purposes of this DCE, SCE has included schedule margin in its determination of the planned completion date of major D&D in late 2028. 50 VII. Waste Disposal The disposition of waste is a significant activity in the decommissioning of SONGS. A brief description of the waste to be generated from the SONGS decommissioning process is described below. In addition, the estimated quantity of each type of waste is summarized in Table 18 below.

Spent Nuclear Fuel - Under the Nuclear Waste Policy Act of 1982, the DOE is responsible for the removal and permanent disposal of all SONGS spent nuclear fuel. In the 2014 DCE, SCE assumed the DOE would begin accepting spent fuel from domestic commercial nuclear power plants in 2024 at the rate published in DOEs July 2004 Acceptance Priority Ranking & Annual Capacity Report. Due to DOE inactivity in the past four years, SCE revised its spent fuel shipping schedule for the 2017 DCE to assume that the DOE will begin accepting spent fuel from the nuclear industry in 2028.

GTCC Waste - GTCC waste will be generated when SDS segments the reactor vessel internals. Additional GTCC waste may reside in the spent fuel pools. GTCC waste cannot be disposed of in a federally licensed low-level radioactive waste (LLRW) disposal facility. As explained above, courts have held that the DOE must accept GTCC waste, but currently there is no disposal facility in the U.S. that is licensed to accept it. Therefore, GTCC waste will be packaged and stored in licensed canisters on the SONGS ISFSI until final disposal.

Low-Level Radioactive Waste (LLRW) - 10 C.F.R. § 61 outlines the requirements for LLRW and identifies the criteria for the classifications of waste materials that can be accepted at federally licensed LLRW disposal facilities. SDS will characterize, package, and transport offsite the Class A, Class B, and Class C waste.

Exempt Waste - It is assumed that some waste generated during the decommissioning of SONGS will receive NRC approval to be disposed of at a facility that accepts very low-level waste. According to the NRC, 10 CFR 20.2002 is available for use by licensees for wastes that typically are a small fraction of the Class A limits contained in Part 61, and for which the extensive controls in Part 61 are not needed to ensure protection of public health and safety and the environment. Thus, 10 CFR 20.2002 provides an alternative, safe, risk-informed disposal 50 The 2028 date is generally consistent with the schedule that was assumed in the 2014 DCE.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate method for these materials, which are frequently called very low-level waste (VLLW), or low-activity waste (LAW). 51 Non-Radiologically Contaminated Waste - Radiologically clean concrete or debris will be disposed of at an out of state Class III landfill. This material will be scanned for radiological contamination prior to leaving SONGS to meet all applicable regulatory requirements. Non-contaminated reinforcing and structural steel may be recycled.

Non-Radiologically Contaminated Hazardous and Industrial Waste Disposal - Lead shielding and other hazardous materials and chemicals will be removed and properly disposed of during decommissioning. Non-Radioactive contaminated surfaces coated with tightly adhering and undamaged lead-based paint will be removed as non-hazardous building demolition debris.

Table 18 summarizes the estimated waste disposal quantities by class for the remainder of SONGS decommissioning.

TABLE 18 REMAINING WASTE DISPOSAL QUANTITIES Period 2 Periods 3 & 4 Period 5 Period 6 Period 7 ISFSI Demolition &

Transition and Civil Works Final Site Pool Storage D&D Dry Storage Project Restoration Total Description (lbs) (lbs) (lbs) (lbs) (lbs) (lbs) 1 Start 1/1/2017 1/1/2019 1/1/2029 1/1/2046 1/1/2050 2 End 12/31/2018 12/31/2028 12/31/2045 12/31/2049 12/31/2051 3 Duration (Years) 2.0 10.0 17.0 4.0 2.0 4 Class B, C, GTCC 5 Class B - 69,320 - - - 69,320 6 Class C 5,700 inc - - - 5,700 7 GTCC - 222,800 - - - 222,800 8 Class B, C, GTCC Subtotal 5,700 292,120 - - - 297,820 9 Class A 10 Class A - 395,096,463 - - 502,383 395,598,846 11 Class A - Containerized Waste 7,950 inc - - - 7,950 12 Class A Subtotal 7,950 395,096,463 - - 502,383 395,606,796 13 Other 14 Out of State Landfill / Exempt - 489,594,000 - 1,074,296,250 394,648,923 1,958,539,173 15 Scrap Metal Recycler - 105,391,000 - 71,736,000 10,325,800 187,452,800 16 Other Subtotal - 594,985,000 - 1,146,032,250 404,974,723 2,145,991,973 17 18 Waste Total 13,650 990,373,583 - 1,146,032,250 405,477,106 2,541,896,589 51 Low-Level Waste Disposal Under 10 C.F.R. § 20.2002. U.S. NRC, 21 September 2017, https://www.nrc.gov/waste/llw-disposal/10cfr20-2002-info.html, accessed December 1, 2017.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate VIII. References

1. EnergySolutions, 2014 Decommissioning Cost Analysis of the San Onofre Nuclear Generating Station Units 2&3, September 5, 2014

2. August 20, 2015 letter from NRC to SCE Vice President and Chief Nuclear Officer, Mr.

Thomas J. Palmisano (ADAM Accession No.: ML15204A383)

3. Application 14-12-007 Joint Application Of Southern California Edison Company (U 338-E) And San Diego Gas & Electric Company (U 902-E) For 2014 SONGS Units 2&3 Decommissioning Cost Estimate And Related Decommissioning Issues, December 10, 2014

4. California Public Utilities Commission Decision 16-04-109, Decision Approving Decommissioning Cost Estimate, April 21, 2016

5. State of California State Lands Commission, Lease P.R.C. No. 4862.1, November 19, 1984

6. Department of the Navy, Grant of Easement, May 1964

7. State of California, Executive Order D-62-02, September 2002

8. U.S. Nuclear Regulatory Commission, Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors, Regulatory Guide 1.202, February 2005

9. California Public Utilities Commission Proposed Decision A.16-03-006, Decision Approving Decommissioning Cost Estimate, April 20, 2017 48

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate Appendix $

Spent Fuel Shipping Schedule

%

SONGS Units 1, 2, and 3 Spent Fuel Shipping Schedule 2028 DOE Acceptance (as of 1/2/2018)

On-Site Inventory (Beginning of Year) On-Site Transfers (During Year) Off-Site Transfers (During Year)

Units 1, 2, & 3 Units 2 & 3 Fuel Units 2 & 3 Unit 1 Unit 2 Unit 3 Canisters Unit 1 Fuel Unit 1 Fuel Units 2 & 3 Fuel Units 2 & 3 Fuel Units 1, 2, & 3 Assemblies Canisters Assemblies Assemblies Assemblies Transferred Assemblies at Assemblies in Assemblies in Assemblies in Canisters in Transferred to Transferred to Transferred to Transferred to Transferred to from ISFSI to Morris ISFSI Pools ISFSI ISFSI* ISFSI ISFSI DOE DOE** DOE** DOE*

2016 270 395 2,668 792 50 - - - - - -

2017 270 395 2,668 792 50 - - - - -

2018 270 395 2,668 792 110 2,220 60 - - - -

2019 270 395 448 3,012 170 448 1 - - - -

2020 270 395 - 3,460 182 - - - - - -

2021 270 395 - 3,460 182 - - - - - -

2022 270 395 - 3,460 182 - - - - - -

2023 270 395 - 3,460 182 - - - - - -

2024 270 395 - 3,460 182 - - - - - -

2025 270 395 - 3,460 182 - - - - - -

2026 270 395 - 3,460 182 - - - - - -

2027 270 395 - 3,460 182 - - - - - -

2028 270 395 - 3,460 182 - - 96 - - 4 2029 270 299 - 3,460 178 - - 48 - - 2 2030 270 251 - 3,460 176 - - 120 - - 5 2031 270 131 - 3,460 171 - - 48 - - 2 2032 270 83 - 3,460 169 - - 48 - - 2 2033 270 35 - 3,460 167 - - - - - -

2034 270 35 - 3,460 167 - - 35 48 48 6 2035 270 - - 3,364 161 - - - 192 96 12 2036 270 - - 3,076 149 - - - 120 168 12 2037 270 - - 2,788 137 - - - 48 72 5 2038** 270 - - 2,668 132 - - - 74 111 5 2039 270 - - 2,483 127 - - - 111 111 6 2040 270 - - 2,261 121 - - - 111 74 5 2041 270 - - 2,076 116 - - - - - -

2042 270 - - 2,076 116 - - - 111 111 6 2043 270 - - 1,854 110 - - - 74 111 5 2044 270 - - 1,669 105 - - - 111 74 5 2045 270 - - 1,484 100 - - - - - -

2046 270 - - 1,484 100 - - - 222 222 12 2047 270 - - 1,040 88 - - - 74 74 4 2048 270 - - 892 84 - - - 222 222 12 2049 270 - - 448 72 - - - 208 240 13 2050*** 270 - - - 59 - - 270 - - 13 2051 - - - - - - - - - - -

• Excluding GTCC Waste

• • Before 2038, SONGS 2 & 3 fuel assemblies shipped in Areva 24-PTH canisters Beginning in 2038, SONGS 2 & 3 fuel assemblies shipped in Holtec MPC canisters

• • • Unit 1 fuel assemblies transferred to DOE from GE facility in Morris, Illinois in TADS (21 assemblies per TAD)

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate Appendix %

Detailed Project Schedule

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate Appendix &

Detailed Cost Table

%

Appendix C Table 1 Detailed Cost Table By Cost Type (Dollars In Thousands, 100% Share)

Total (Nominal / 2017$)

(1)

DCE No. Description Labor Material Contract Other Disposal Overheads Contingency Total 1 Completed Projects - 2015 NDCTP $ 1,223 $ 2,671 $ 89,834 $ (137) $ - $ 1,563 $ - $ 95,154 2

3 LT-2-D-2 18 Planning & Design For Cold and Dark 1,888 1,008 14,977 1,054 - 1,373 - 20,299 4 LT-2-D-2 19 Implement Cold and Dark (Repower Site) 2,151 415 52,191 (663) - 1,522 - 55,615 5 LT-2-D-2 20 Install 12 kV Service Line to Power Temp Power Ring 1,579 2,779 4,746 419 - 758 - 10,281 6 LT-2-D-2 21 Drain & De-Energize Non-Essential Systems (DEC Process) 2,363 946 1,299 14 - 1,487 - 6,111 7 LT-2-D-2 29 Implement Control Room Modifications (Command Center Relocation) - 4 340 3 - 3 - 350 8 Completed Activities - Initial D&D Activities Subtotal $ 7,981 $ 5,152 $ 73,553 $ 826 $ - $ 5,143 $ - $ 92,655 9

10 LT-2-D-2 26 Install Spent Fuel Pool System Modifications - Unit 2 139 2,814 1,159 31 - 129 - 4,271 11 LT-2-D-2 27 Install Spent Fuel Pool System Modifications - Unit 3 139 2,814 1,159 31 - 129 - 4,271 12 Completed Activities - Spent Fuel Islanding Subtotal $ 277 $ 5,627 $ 2,317 $ 63 $ - $ 258 $ - $ 8,543 13 14 LT-2-D-2 07 Prepare Defueled Safety Analysis Report (DSAR) 1 - 1,991 8 - 21 - 2,021 15 Completed Activities - Phase 2 Regulatory Compliance Subtotal $ 1 $ - $ 1,991 $ 8 $ - $ 21 $ - $ 2,021 16 17 LT-2-D-2 22 Select Decommissioning General Contractor (DGC) 1,219 7 11,842 392 - 809 - 14,270 18 Completed Activities - DCG RFP & Prep Subtotal $ 1,219 $ 7 $ 11,842 $ 392 $ - $ 809 $ - $ 14,270 19 (2) 20 LT-2-D-LOED Large Organism Exclusion Device Modification 69 1,070 178 (4) - 51 - 1,364 (2) 21 LT-D-SPV Special Purpose Vehicle Support - - 442 - - 6 - 448 (2) 22 LT-3-D-RecB Records Backlog - - 1,807 186 - 20 - 2,014 (2) 23 LT-3-D-S&S Simplification & Streamlining Project 1 6 1,329 33 - 8 - 1,377 24 Completed Activities - Transition Modifications Subtotal $ 69 $ 1,076 $ 3,757 $ 215 $ - $ 84 $ - $ 5,202 25 26 Completed Projects And Activities Subtotal $ 10,771 $ 14,534 $ 183,294 $ 1,368 $ - $ 7,877 $ - $ 217,845 27 28 ISFSI & Fuel Transfer Operations (3) 29 SNF-1-D-7 02 Holtec Long Lead Items and Areva Contract Closure 95 16,342 32,106 (12,796) - 445 1,026 37,219 30 SNF-2-D-8 07 ISFSI Pad Study - - 199 2 - 2 - 203 (4) 31 SNF-2-D-8 08 Design ISFSI Expansion, Fuel Inspection, and Oversight 1,284 103 76,028 2,808 - 916 3,589 84,729 32 SNF-2-D-8 09 Construct ISFSI Expansion 96 5 44,885 267 - 177 4,225 49,655 (5) 33 SNF-2-D-8 10 Fabrication of Spent Fuel Canisters - Unit 2 24 1,696 27,107 8,978 - 568 317 38,690 (5) 34 SNF-2-D-8 11 Fabrication of Spent Fuel Canisters - Unit 3 23 1,696 19,640 8,979 - 490 528 31,357 (6) 35 SNF-2-D-8 12 Load Fuel Canisters and Fuel Transfer Operations - Unit 2 - - 17,684 - - - 2,606 20,290 (6) 36 SNF-2-D-8 13 Load Fuel Canisters and Fuel Transfer Operations - Unit 3 - - 17,684 - - - 2,606 20,290 37 ISFSI & Fuel Transfer Operations Subtotal $ 1,523 $ 19,842 $ 235,332 $ 8,239 $ - $ 2,598 $ 14,899 $ 282,432 38 39 Decontamination, Demolition, & Disposal 40 Prepare Integrated Work Sequence and Schedule for Decommissioning - - - - -

41 Modify Containment Access- Unit 2 - - - - -

42 Modify Containment Access- Unit 3 - - - - -

43 Remove and Dispose of Missile Shields - Unit 2 - - - -

44 Remove and Dispose of Reactor Head - Unit 2 - - - -

45 Remove and Dispose of Missile Shields - Unit 3 - - - -

46 Remove and Dispose of Reactor Head - Unit 3 - - - -

47 Prepare Activity Specifications - U2 - - - - -

(2) 48 Waste Contracts - - - - -

49 Install GARDIAN System - - - - -

50 Decontamination, Demolition, & Disposal - Initial D&D Activities Subtotal $ - $ - $ $ - $ $ - $ $

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DCE No. Description Labor Material Contract Other Disposal Overheads Contingency Total 51 52 Design, Specify, and Procure Special Items and Materials - - - - -

53 Test Special Cutting and Handling Equipment and Train Operators - - - - -

54 Finalize Internals and Vessel Segmenting Details - Unit 2 - - - - -

55 Segment, Package and Dispose of Reactor Internals - Unit 2 - - - -

56 Segment, Package and Dispose of Reactor Internals - Unit 3 - - - -

57 Decontamination, Demolition, & Disposal - Internals and Vessel Segmentation Subtotal $ - $ - $ $ - $ $ - $ $

58 59 Remove Underground Diesel Tank - Unit 2 - - - - -

60 Remove Underground Diesel Tank - Unit 3 - - - - -

61 Remove and Dispose of Spent Fuel Storage Racks - Unit 2 - - - -

62 Remove and Dispose of Spent Fuel Storage Racks - Unit 3 - - - -

63 Drain Spent Fuel Pool and Process Liquid Waste - Unit 2 - - - - -

64 Drain Spent Fuel Pool and Process Liquid Waste - Unit 3 - - - - -

65 Remove Protected Area Security Fencing - - - - -

66 Decontamination, Demolition, & Disposal - Removal Of Spent Fuel Systems/Equipment Subtotal $ - $ - $ $ - $ $ - $ $

67 68 Remove and Dispose of Steam Generators - Unit 2 - - - -

69 Remove and Dispose of Steam Generators - Unit 3 - - - -

70 Decontamination, Demolition, & Disposal - Steam Generator Removal Subtotal $ - $ - $ $ - $ $ - $ $

71 72 Upgrade Rail Spur - - - - -

73 Remove, Package and Dispose of Non-Essential Systems - Unit 2 - - - -

74 Remove, Package and Dispose of Non-Essential Systems - Unit 3 - - - -

75 Decontamination, Demolition, & Disposal - Non-Essential System Removal Subtotal $ - $ - $ $ - $ $ - $ $

76 77 Remove, Package and Dispose of Essential Systems - - - -

78 Reactor Vessel Insulation Removal and Disposal - Unit 2 - - - -

79 Segment, Package and Dispose of Reactor Pressure Vessel - Unit 2 - - - -

80 Reactor Vessel Insulation Removal and Disposal - Unit 3 - - - -

81 Segment, Package and Dispose of Reactor Pressure Vessel - Unit 3 - - - -

82 Remove and Dispose of Pressurizer - Unit 2 - - - -

83 Remove and Dispose of Pressurizer - Unit 3 - - - -

84 Remove and Dispose of Turbine Gantry Crane - Unit 2 - - - -

85 Remove and Dispose of Turbine Gantry Crane - Unit 3 - - - -

86 Decontamination, Demolition, & Disposal - Large Component Removal Subtotal $ - $ - $ $ - $ $ - $ $

87 88 Demolish Service Building (K-10, 20, 30) - - - -

89 Demolish South Security Processing Facility (K-70) - - - -

90 Demolish South Yard Area Buildings T-10, 20, 60 and Haz Mat - - - -

91 Procure Clean Building Demolition Equipment - - - -

92 Demolish Diesel Generator Building - Unit 3 - - - -

93 Demolish Diesel Generator Building - Unit 2 - - - -

94 Demolish Condensate Building and Transformer Pads - Unit 2 - - - -

95 Demolish Full Flow Area and Turbine Building - Unit 2 - - - -

96 Demolish AWS Building - - - -

97 Demolish Building L-50 - - - -

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DCE No. Description Labor Material Contract Other Disposal Overheads Contingency Total 98 Demolish Maintenance Building 4 (B-64/B-65) - - - -

99 Demolish Maintenance Building 5 (B-62/B-63) - - - -

100 Demolish Outage Control Center - - - -

101 Demolish Maintenance Building 2 (B-49/B-50) - - - -

102 Demolish Maintenance Building 1 (B-43/B-44) - - - -

103 Demolish Auxiliary Radwaste Building - Common - - - -

104 Demolish Auxiliary Control Building - Common - - - -

105 Remove Systems and Demolish Make-Up Demineralizer Structures - - - -

106 Install Concrete Plugs in Intake and Discharge Structures - - - - -

107 Demolish Intake and Discharge Structures to 3-Feet Below Grade - - - -

108 Decontamination, Demolition, & Disposal - Initial Plant Building Demo Subtotal $ - $ - $ $ - $ $ - $ $ 1 109 110 Decon Containment Building - Unit 3 - - - -

111 Decon Penetration Building - Unit 3 - - - -

112 Decon Safety Equipment and MSIV Building - Unit 3 - - - -

113 Decon Fuel Handling Building - Unit 3 - - - -

114 Decon Containment Building - Unit 2 - - - -

115 Decon Penetration Building - Unit 2 - - - -

116 Decon Safety Equipment and MSIV Building - Unit 2 - - - -

117 Decon Fuel Handling Building - Unit 2 - - - -

118 Decon Turbine Building - Unit 2 - - - -

119 Decon Auxiliary Radwaste Building - Common - - - -

120 Decon Auxiliary Control Building - Common - - - -

121 Decontamination, Demolition, & Disposal - Building Decontamination Subtotal $ - $ - $ $ - $ $ - $ $ 2 122 123 Remove Protected Area Pavement - - - -

124 Demolish Condensate Building and Transformer Pads - Unit 3 - - - -

125 Demolish Full Flow Area and Turbine Building - Unit 3 - - - -

126 Demolish Unit 3 Fuel Handling Building to 3-Feet Below Grade - - - -

127 Demolish Penetration Building - Unit 3 - - - -

128 Demolish Unit 2 Fuel Handling Building to 3-Feet Below Grade - - - -

129 Demolish Penetration Building - Unit 2 - - - -

130 Decontamination, Demolition, & Disposal - Final Plant Building Demo Subtotal $ - $ - $ $ - $ $ - $ $

131 (2) 132 Offshore Conduit Diffuser and Risers - - - - -

133 (2) 134 Backfill - - - - -

135 136 Demolish Staging Warehouse - - - -

137 Demolish Administration Building (K-40/50) - - - -

138 Detension and Remove Unit 3 Containment Building Tendons - - - - -

139 Demolish Safety Equipment and MSIV Building - Unit 3 - - - -

140 Demolish Unit 3 Containment Building to 3-Feet Below Grade - - - -

141 Detension and Remove Unit 2 Containment Building Tendons - - - -

142 Demolish Safety and MSIV Equipment Building - Unit 2 - - - -

143 Demolish Unit 2 Containment Building to 3-Feet Below Grade - - - -

144 Decontamination, Demolition, & Disposal - Containment Building Demo Subtotal $ - $ - $ $ - $ $ - $ $

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DCE No. Description Labor Material Cont Other Disposal Overheads Contingency Total 146 Prepare License Termination Plan - - - - -

147 Final Status Survey - - - -

148 Subsurface Structure Removal Engineering Planning and Design - - - - -

149 Decontamination, Demolition, & Disposal - Final Survey/License Termination Subtotal $ - $ - $ $ - $ $ - $ $

150 (2) 151 Waste Taxes (Pass Through) - - - - -

(2) 152 Waste Taxes (Pass Through) - - - - -

153 Decontamination, Demolition, & Disposal - Waste Subtotal $ - $ - $ - $ - $ $ - $ $

154 155 - - - - -

156 157 $ - $ - $ $ - $ $ - $ $

158 159 Other Projects (2) (7) 160 SNF-2-D-AM Areva Areva ISFSI Relicensing - - 12,550 8 - - 2,441 14,998 (2) (7) 161 SNF-2-D-AM Holtec 1 Holtec ISFSI I&M Program Development - - 14,892 25 - 3 2,843 17,763 (2) 162 SNF-2-D-AM Holtec 2 Holtec ISFSI Relicensing - - 5,000 - - - 1,000 6,000 163 ISFSI Aging Management Subtotal $ - $ - $ 32,441 $ 32 $ - $ 3 $ 6,284 $ 38,761 164 (2) 165 SNF-2-D-EP Holtec Environmental Permitting - Holtec - - 3,000 - - - 600 3,600 (2) 166 SNF-2-D-EP Areva Environmental Permitting - Areva - - 1,650 - - - 330 1,980 167 Coastal Development Permit Extension Subtotal $ - $ - $ 4,650 $ - $ - $ - $ 930 $ 5,580 168 (2) 169 SNF-2-D-GTCC GTCC Waste Storage - - 22,616 - - - 5,654 28,270 170 (8) 171 SR-1-D-14 01 Mesa Site Phase I and II Site Assessment and Lease Surrender 526 - 7,213 25 - 173 1,118 9,054 172 SR-1-D-14 02 Disposition Hazardous Waste from Mesa Site 113 - 10 - - 73 - 195 173 SR-1-D-14 03 Mesa Site Characterization Survey 15 - 138 (102) - 10 - 61 (9) 174 SR-2-D-15 02 Obtain Required Permits - Mesa - - 55 26 - 1 - 82 (10) 175 SR-2-D-15 09 Mesa Buildings - Demo, Maintenance 258 42 8,783 64 - 99 545 9,791 176 SR-2-D-15 11 Demolish Mesa Roads and Parking Lots - 396 591 - - - 197 1,185 177 SR-2-D-15 12 Finish Grading and Re-vegetate Mesa Site - 400 304 - - - 141 845 178 Mesa Site Turnover Subtotal $ 911 $ 838 $ 17,093 $ 13 $ - $ 356 $ 2,001 $ 21,212 179 (2) 180 LT-3-D-DCE DCE Update - - 2,183 375 - - 189 2,747 (2) 181 SNF-D-DCE DCE Update - - 1,000 - - - 150 1,150 182 DCE Update Subtotal $ - $ - $ 3,183 $ 375 $ - $ - $ 339 $ 3,897 183 (11) 184 SR-3-D-16 05 Obtain CEQA Permit & Approvals 947 16 5,896 327 - 433 712 8,331 (12) 185 SR-3-D-16 03 Initial Real Estate Authorization Renewal and Plant Easement 2,377 - 9,418 640 - 647 2,223 15,305 (2) 186 SR-D-NEPA 2 Plant Lease Extension 1,397 - 1,576 45 - 414 686 4,118 (2) 187 SR-D-NEPA 3 Plant Lease Amendment For Final Site Restoration 1,663 - 5,532 54 - 493 1,548 9,290 (2) 188 SNF-D-GTCC Disp GTCC Disposal - - 36,000 - - - 7,200 43,200 (2) 189 SNF-2-D-CDP ISFSI CDP Settlement - - 3,743 800 - - - 4,543 (2) 190 SR-D-RFP Substructure Removal Contractor Procurement 4,741 59 - - - 1,406 1,241 7,447 191 SNF-1-D-7 05 Cyber Security Modifications 341 671 8,241 55 - 336 - 9,644 (2) 192 SNF-D-NIA Sump NIA Sump Modifications - - 1,000 - - - 150 1,150 193 Other Projects Subtotal $ 12,377 $ 1,583 $ 151,389 $ 2,341 $ - $ 4,088 $ 28,969 $ 200,748 194 4 Of 9

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DCE No. Description Labor Material Contract Other Disposal Overheads Contingency Total 195 Substructure Removal (2) 196 SR-D-BKFL REM Backfill Removal 3,358 2,713 - - - 996 1,767 8,833 197 SR-5-D-18 02 Install Sheet Piling and Excavation Shoring - 20,385 10,280 - - - 7,666 38,332 198 SR-5-D-18 03 Install Dewatering System and Effluent Treatment and Discharge Controls - - - 29,053 - - 7,263 36,316 199 SR-5-D-18 04 Demolish and Backfill Unit 3 Condensate Storage Area Below -3 Feet - 292 207 - 569 - 267 1,334 200 SR-5-D-18 05 Demolish and Backfill Unit 3 Diesel Generator Building Below -3 Feet - 166 118 - 276 - 140 701 201 SR-5-D-18 06 Demolish and Backfill Unit 3 Fuel Handling Building Below -3 Feet - 449 344 - 938 - 433 2,163 202 SR-5-D-18 07 Demolish and Backfill Unit 3 Radwaste and Control Building Below -3 Feet - 1,183 1,062 - 1,819 - 1,016 5,079 203 SR-5-D-18 08 Demolish and Backfill Unit 3 Turbine Building Structure Below 9 Ft Elevation - 5,374 4,502 - 7,880 - 4,439 22,195 204 SR-5-D-18 09 Demolish and Backfill Unit 3 Safety Equipment Building Below -3 Feet - 841 828 - 4,120 - 1,447 7,237 205 SR-5-D-18 10 Demolish and Backfill Unit 3 Penetration Area Below -3 Feet - 394 323 - 801 - 380 1,899 206 SR-5-D-18 11 Demolish and Backfill Unit 3 Full Flow Building Below -3 Feet - 148 104 - 256 - 127 637 207 SR-5-D-18 12 Demolish and Backfill Unit 3 Containment Building Below -3 Feet - 1,789 1,358 - 5,048 - 2,049 10,243 208 SR-5-D-18 13 Demolish and Backfill Unit 2 Condensate Storage Area Below -3 Feet - 292 207 - 569 - 267 1,334 209 SR-5-D-18 14 Demolish and Backfill Unit 2 Diesel Generator Building Below -3 Feet - 166 118 - 276 - 140 701 210 SR-5-D-18 15 Demolish and Backfill Unit 2 Fuel Handling Building Below -3 Feet - 449 344 - 938 - 433 2,163 211 SR-5-D-18 16 Demolish and Backfill Unit 2 Radwaste and Control Building Below -3 Feet - 1,282 1,098 - 1,819 - 1,050 5,249 212 SR-5-D-18 17 Demolish and Backfill Unit 2 Turbine Building Structure Below 9 Ft Elevation - 5,374 4,502 - 7,881 - 4,439 22,195 213 SR-5-D-18 18 Demolish and Backfill Unit 2 Safety Equipment Building Below -3 Feet - 841 828 - 4,120 - 1,447 7,237 214 SR-5-D-18 19 Demolish and Backfill Unit 2 Penetration Area Below -3 Feet - 394 323 - 801 - 380 1,899 215 SR-5-D-18 20 Demolish and Backfill Unit 2 Full Flow Building Below -3 Feet - 405 248 - 256 - 227 1,137 216 SR-5-D-18 21 Demolish and Backfill Unit 2 Containment Building Below -3 Feet - 1,786 1,356 - 5,048 - 2,047 10,237 217 SR-5-D-18 22 Demolish and Backfill Intake Structure Below -3 Feet - 10,418 7,867 - 25,339 - 10,906 54,529 218 SR-5-D-18 24 Remove Sheet Piling and Excavation Shoring - - 11,967 - - - 2,992 14,958 219 SR-5-D-18 25 Remove Dewatering System and Effluent Treatment - - - 6,947 - - 1,737 8,684 220 SR-6-D-19 06 Remove and Stockpile Existing Seawall Erosion Protection - 11 6 - - - 4 21 221 SR-6-D-19 07 Remove Unit 2 and 3 Seawall and Pedestrian Walkway - 3,032 3,258 - 4,606 - 2,724 13,620 222 SR-6-D-19 08 Remove Remaining Intake and Outfall Box Culvert - 464 341 - 2,211 - 754 3,770 223 SR-6-D-19 10 Backfill and Compaction of Excavation - 2,217 1,495 - - - 928 4,640 224 Substructure Removal Subtotal $ 3,358 $ 60,862 $ 53,084 $ 36,000 $ 75,573 $ 996 $ 57,468 $ 287,340 225 226 Offshore Conduit Removal 227 SR-3-D-16 01 Hydrogeologic Investigation and Outfall Conduit Survey - 130 302 104 - - 134 670 228 SR-5-D-18 23 Remove Off Shore Intake and Outfall Conduits - 43,901 12,606 - 19,788 - 19,074 95,369 229 Offshore Conduit Removal Subtotal $ - $ 44,031 $ 12,908 $ 104 $ 19,788 $ - $ 19,208 $ 96,039 230 231 ISFSI Demolition 232 SNF D&D-1-D-12 01 Preparation and NRC Review of License Termination Plan - - 118 161 - - 70 349 233 SNF D&D-2-D-13 01 Install GARDIAN Bulk Assay System - - - 546 - - 137 683 (13) 234 SNF D&D-2-D-13 02 Decon Areva Modules - 47 111 - 141 - 75 374 235 SNF D&D-2-D-13 03 Final Status Survey of ISFSI - 82 520 - - - 151 753 (14) 236 SNF D&D-2-D-13 04 Clean Demo of Areva ISFSI Pad and Modules - 1,049 1,923 - 1,270 - 1,060 5,302 (15) 237 SNF D&D-2-D-13 05 Demolish ISFSI Security Building - 266 199 - 528 - 248 1,240 238 SNF D&D-2-D-13 06 Restore ISFSI Site - 512 346 - - - 215 1,073 239 SNF D&D-2-D-13 07 Preparation of Final Report on Decommissioning and NRC Review - - 55 - - - 14 69 (2) 240 SNF D&D-2-D-13 08 Clean Demo of Holtec ISFSI Pad and Modules - 1,946 1,452 - 4,910 - 2,077 10,386 241 ISFSI Demolition Subtotal $ - $ 3,902 $ 4,725 $ 707 $ 6,849 $ - $ 4,046 $ 20,229 242 5 Of 9

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DCE No. Description Labor Material Contract Other Disposal Overheads Contingency Total 243 Final Site Restoration 244 SR-6-D-19 01 Obtain Required Permits and Approvals - 20 410 130 - - 140 700 245 SR-6-D-19 03 Procure Site Restoration Equipment - 400 - - - - 100 500 246 SR-6-D-19 12 Install Shoreline Erosion Control and Restoration Features - 142 10 - - - 38 190 247 SR-6-D-19 13 Remove Railroad Tracks, Rails and Ballast - 35 64 - - - 25 123 248 SR-6-D-19 14 Remove Gunite Slope Protection - 362 267 - 1,728 - 589 2,946 249 SR-6-D-19 15 Remove Access Roads and Parking Lots - 179 244 - - - 106 529 250 SR-6-D-19 16 Finish Grading and Re-Vegetate Site - 834 987 - - - 455 2,276 251 Final Site Restoration Subtotal $ - $ 1,973 $ 1,981 $ 130 $ 1,728 $ - $ 1,453 $ 7,267 252 253 Distributed Subtotal 254 255 Labor-Staffing 256 LT-U-1 01 Utility Staff 153,426 544 101,384 1,302 - 59,298 16,414 332,367 257 SNF-U-2 01 Utility Staff 196,990 399 39,185 1,045 - 68,546 18,789 324,954 258 SR-U-3 01 Utility Staff 44,437 24 61,492 68 - 11,056 11,423 128,499 259 Utility Staff Subtotal $ 394,852 $ 967 $ 202,061 $ 2,415 $ - $ 138,899 $ 46,625 $ 785,820 260 261 LT-U-1 03 Security Force 11,563 4 146 17 - 2,200 601 14,532 262 SNF-U-2 04 Security Force 163,052 58 2,487 45 - 54,788 12,148 232,580 263 Security Force Subtotal $ 174,615 $ 62 $ 2,633 $ 63 $ - $ 56,989 $ 12,749 $ 247,112 264 265 Labor-Staffing Subtotal $ 569,468 $ 1,029 $ 204,694 $ 2,478 $ - $ 195,888 $ 59,375 $ 1,032,932 266 267 Non-Labor (2) 268 SNF-U-AM Areva Areva ISFSI Aging Management - - 3,713 - - - 557 4,270 (2) 269 SNF-U-AM Holtec Holtec ISFSI Aging Management - - 10,400 - - - 1,560 11,960 270 Aging Management Subtotal $ - $ - $ 14,113 $ - $ - $ - $ 2,117 $ 16,230 271 272 LT-U-1 17 Association Fees and Expenses - 3 2,393 2,193 - 9 540 5,138 (2) 273 SNF-U-2 26 Association Fees and Expenses - - 212 1,838 - - 307 2,357 (2) 274 SR-U-3 17 Association Fees and Expenses - - 481 793 - - 191 1,466 275 Association Fees and Expenses Subtotal $ - $ 3 $ 3,086 $ 4,825 $ - $ 9 $ 1,039 $ 8,961 276 277 LT-U-1 15 Community Engagement Panel 382 63 2,324 4,285 - 157 679 7,890 (2) 278 SNF-U-2 25 Community Engagement Panel - - 26 2,440 - - 370 2,836 (2) 279 SR-U-3 21 Community Engagement Panel - - 8 1,933 - - 291 2,232 280 Community Engagement Panel Subtotal $ 382 $ 63 $ 2,358 $ 8,658 $ - $ 157 $ 1,340 $ 12,958 281 6 Of 9

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DCE No. Description Labor Material Contract Other Disposal Overheads Contingency Total (16) 282 LT-U-1 08 Contracted Services 705 9,613 78,768 7,991 - 92 6,641 103,810 (16) 283 SNF-U-2 11 Contracted Services 349 11,718 62,692 18,422 - 165 10,528 103,875 (16) 284 SR-U-3 06 Contracted Services 19 761 21,008 2,452 - 18 3,433 27,690 (2) 285 SR-U-Bank Bank Fees And Interest - - - (68) - - - (68)

(2) 286 SR-U-Inv Adj Vendor Invoice Adjustment - - - (213) - (1) - (214) 287 Contracted Services Subtotal $ 1,073 $ 22,092 $ 162,468 $ 28,583 $ - $ 274 $ 20,602 $ 235,092 288 289 LT-U-1 09 DAW Disposal - - 21 - - - - 21 290 SNF-U-2 12 DAW Disposal - - 10 - - - - 10 291 DAW Disposal Subtotal $ - $ - $ 32 $ - $ - $ - $ - $ 32 292 293 LT-U-1 25 Decommissioning Advisor - 735 6,854 10 - 25 698 8,322 (2) 294 SNF-U-2 28 Decommissioning Advisor - - 292 - - - 44 336 (2) 295 SR-U-3 22 Decommissioning Advisor - - 1,528 - - - 229 1,758 296 Decommissioning Advisor Subtotal $ - $ 735 $ 8,674 $ 10 $ - $ 25 $ 971 $ 10,416 297 (2) 298 LT-U-CO DGC Executive Oversight Committee - - 2,696 - - - 404 3,100 (2) 299 SR-U-CO DGC Executive Oversight Committee - - 746 - - - 112 857 300 DGC Executive Oversight Committee Subtotal $ - $ - $ 3,441 $ - $ - $ - $ 516 $ 3,958 301 302 SNF-U-2 09 Emergency Preparedness Fees - 22 150 44,615 - 90 5,103 49,980 303 Emergency Preparedness Fees Subtotal $ - $ 22 $ 150 $ 44,615 $ - $ 90 $ 5,103 $ 49,980 304 305 LT-U-1 10 Energy - - - 46,606 - 137 4,762 51,505 306 SNF-U-2 13 Energy - - - 16,988 - 31 2,036 19,055 307 SR-U-3 07 Energy - - - 14,814 - - 2,222 17,036 308 Energy Subtotal $ - $ - $ - $ 78,408 $ - $ 168 $ 9,020 $ 87,596 309 310 LT-U-1 24 Environmental Permits and Fees 2 - 344 3,348 - 27 82 3,802 (2) 311 SNF-U-2 27 Environmental Permits and Fees - - 676 346 - - 153 1,176 (2) 312 SR-U-3 23 Environmental Permits and Fees - - 193 1,460 - - 248 1,901 313 Environmental Permits and Fees Subtotal $ 2 $ - $ 1,212 $ 5,154 $ - $ 27 $ 484 $ 6,879 314 (2) 315 SNF-U-GW Ground Water Monitoring - - 340 - - - 51 391 (2) 316 SR-U-GW Ground Water Monitoring - - 120 - - - 18 138 317 Ground Water Monitoring Subtotal $ - $ - $ 460 $ - $ - $ - $ 69 $ 529 318 (17) 319 LT-U-1 20 Information Technology 2,532 1,605 6,001 6,044 - 1,687 1,035 18,905 (17) 320 SNF-U-2 20 Information Technology - 998 3,730 389 - - 768 5,885 (17) 321 SR-U-3 15 Information Technology - 1,670 2,746 649 - - 760 5,825 (18) 322 LT-U-1 21 Telecommunications 1,275 35 137 88 - 815 - 2,350 (18) 323 LT-U-1 22 Personal Computers - 9 9 - - - - 18 (18) 324 SNF-U-2 22 Personal Computers - 7 - - - - - 7 325 Information Technology Subtotal $ 3,808 $ 4,324 $ 12,623 $ 7,171 $ - $ 2,502 $ 2,563 $ 32,991 326 7 Of 9

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DCE No. Description Labor Material Contract Other Disposal Overheads Contingency Total 327 LT-U-1 05 Insurance 1 - - 18,981 - - 1,090 20,072 (19) 328 LT-U-1 14 Workers Compensation Insurance - - - 384 - - - 384 329 SNF-U-2 06 Insurance - - - 35,022 - - 5,030 40,052 330 SR-U-3 04 Insurance - - - 4,533 - - 680 5,213 331 Insurance Subtotal $ 1 $ - $ - $ 58,921 $ - $ - $ 6,800 $ 65,722 332 (2) 333 LT-U-Legal Third-Party Legal - - 8,960 (125) - 16 1,047 9,899 (2) 334 SNF-U-Legal Third-Party Legal - - 9,533 16 - 20 1,119 10,688 (2) 335 SR-U-Legal Third-Party Legal (836) - 5,285 6 - (405) 505 4,555 336 Third-Party Legal Subtotal $ (836) $ - $ 23,778 $ (103) $ - $ (369) $ 2,671 $ 25,142 337 338 LT-U-1 07 NRC Fees - - 4 10,756 - 43 964 11,767 339 SNF-U-2 08 NRC Fees - - 30 17,916 - 3 2,574 20,523 340 NRC Fees Subtotal $ - $ - $ 34 $ 28,673 $ - $ 46 $ 3,538 $ 32,291 341 (2) 342 LT-U-Office Office Space - 20 1,000 - - - 153 1,173 (2) 343 SNF-U-Office Office Space - 356 3 - - - 54 413 (2) 344 SR-U-Office Office Space - 104 37 - - - 21 162 345 Office Space Lease Subtotal $ - $ 480 $ 1,040 $ - $ - $ - $ 228 $ 1,748 346 347 LT-U-1 04 Security Related Expenses - 166 216 249 - 2 56 690 348 SNF-U-2 05 Security Related Expenses 1 1,913 6,562 1,305 - 10 1,310 11,102 349 SR-U-3 03 Security Related Expenses 2 124 323 116 - 4 17 586 350 Security Related Expenses Subtotal $ 4 $ 2,203 $ 7,101 $ 1,671 $ - $ 16 $ 1,383 $ 12,378 351 352 SR-U-3 11 Severance 104,551 - 1,816 4,142 - 8,452 4,084 123,044 353 Severance Subtotal $ 104,551 $ - $ 1,816 $ 4,142 $ - $ 8,452 $ 4,084 $ 123,044 354 355 LT-U-1 06 Site Lease and Easement Expenses 1 - 69 4,102 - - 350 4,521 356 SNF-U-2 07 Site Lease and Easement Expenses - - - 41,587 - - 6,238 47,825 357 SR-U-3 05 Site Lease and Easement Expenses 2 - 223 43,225 - - 5,348 48,798 358 Site Lease and Easement Expenses Subtotal $ 3 $ - $ 292 $ 88,914 $ - $ - $ 11,936 $ 101,145 359 (2) 360 SNF-U-SFL Loading Spent Fuel & GTCC Waste To DOE - - 28,320 - - - 4,248 32,568 361 Loading Spent Fuel & GTCC Waste To DOE Subtotal $ - $ - $ 28,320 $ - $ - $ - $ 4,248 $ 32,568 362 363 LT-U-1 19 Tools and Equipment - - 14 35 - - - 49 364 Tools and Equipment Subtotal $ - $ - $ 14 $ 35 $ - $ - $ - $ 49 365 (20) 366 LT-U-1 18 Water - - - 3,890 - 9 436 4,336 (20) 367 SNF-U-2 18 Water - - - 8,275 - 6 1,119 9,400 (20) 368 SR-U-3 13 Water - - - 2,965 - - 443 3,408 369 Water Subtotal $ - $ - $ - $ 15,130 $ - $ 15 $ 1,998 $ 17,143 370 371 LT-U-1 02 Utility Staff Health Physics Supplies - 114 1,012 28 - 8 21 1,183 372 SNF-U-2 02 Utility Staff Health Physics Supplies - 152 2,305 46 - 13 127 2,643 373 Utility Staff Health Physics Supplies Subtotal $ - $ 266 $ 3,317 $ 74 $ - $ 21 $ 148 $ 3,825 374 375 Non-Labor Subtotal $ 108,987 $ 30,189 $ 274,329 $ 374,880 $ - $ 11,432 $ 80,859 $ 880,676 8 Of 9

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DCE No. Description Labor Material Contract Other Disposal Overheads Contingency Total 376 377 Service Level Agreements (2) 378 LT-U-SLA Service Level Agreements 32,318 (9) 2,301 30,114 - 9,098 6,278 80,099 (2) 379 SNF-U-SLA Service Level Agreements 7,908 (9) 2,080 9,175 - 25,896 3,521 48,571 (2) 380 SR-U-SLA Service Level Agreements 9,783 (1) 132 8,254 - 26,401 4,403 48,973 381 Service Level Agreements Subtotal $ 50,010 $ (19) $ 4,514 $ 47,543 $ - $ 61,395 $ 14,202 $ 177,643 382 383 DGC Staffing 384 - - - - -

385 - - - - -

386 Subtotal DGC Staffing $ - $ - $ $ - $ - $ - $ $

387 388 Undistributed Subtotal $ $ $ $ $ - $ $ $

389 390 Total $ $ $ $ $ $ $ $

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DCE No. Description Labor Material Contract Other Disposal Overheads Contingency Total 1 Completed Projects - 2015 NDCTP $ 1,236 $ 2,663 $ 88,707 $ (134) $ - $ 1,569 $ - $ 94,041 2

3 LT-2-D-2 18 Planning & Design For Cold and Dark 1,887 1,008 14,875 1,067 - 1,372 - 20,208 4 LT-2-D-2 19 Implement Cold and Dark (Repower Site) 2,083 412 50,494 (458) - 1,479 - 54,010 5 LT-2-D-2 20 Install 12 kV Service Line to Power Temp Power Ring 1,535 2,746 4,617 413 - 738 - 10,050 6 LT-2-D-2 21 Drain & De-Energize Non-Essential Systems (DEC Process) 2,343 946 1,288 16 - 1,477 - 6,070 7 LT-2-D-2 29 Implement Control Room Modifications (Command Center Relocation) - 4 332 3 - 3 - 343 8 Completed Activities - Initial D&D Activities Subtotal $ 7,849 $ 5,116 $ 71,606 $ 1,041 $ - $ 5,069 $ - $ 90,680 9

10 LT-2-D-2 26 Install Spent Fuel Pool System Modifications - Unit 2 136 2,795 1,125 43 - 126 - 4,225 11 LT-2-D-2 27 Install Spent Fuel Pool System Modifications - Unit 3 136 2,795 1,125 43 - 126 - 4,225 12 Completed Activities - Spent Fuel Islanding Subtotal $ 272 $ 5,589 $ 2,251 $ 85 $ - $ 253 $ - $ 8,450 13 14 LT-2-D-2 07 Prepare Defueled Safety Analysis Report (DSAR) 1 - 1,946 11 - 20 - 1,978 15 Completed Activities - Phase 2 Regulatory Compliance Subtotal $ 1 $ - $ 1,946 $ 11 $ - $ 20 $ - $ 1,978 16 17 LT-2-D-2 22 Select Decommissioning General Contractor (DGC) 1,179 7 11,471 406 - 784 - 13,847 18 Completed Activities - DCG RFP & Prep Subtotal $ 1,179 $ 7 $ 11,471 $ 406 $ - $ 784 $ - $ 13,847 19 (2) 20 LT-2-D-LOED Large Organism Exclusion Device Modification 66 1,054 171 (3) - 49 - 1,337 (2) 21 LT-D-SPV Special Purpose Vehicle Support - - 424 1 - 5 - 430 (2) 22 LT-3-D-RecB Records Backlog - - 1,733 183 - 19 - 1,936 (2) 23 LT-3-D-S&S Simplification & Streamlining Project 1 6 1,262 50 - 7 - 1,325 24 Completed Activities - Transition Modifications Subtotal $ 67 $ 1,060 $ 3,589 $ 230 $ - $ 81 $ - $ 5,027 25 26 Completed Projects And Activities Subtotal $ 10,603 $ 14,435 $ 179,568 $ 1,640 $ - $ 7,776 $ - $ 214,024 27 28 ISFSI & Fuel Transfer Operations (3) 29 SNF-1-D-7 02 Holtec Long Lead Items and Areva Contract Closure 95 16,219 30,966 (12,666) - 438 986 36,039 30 SNF-2-D-8 07 ISFSI Pad Study - - 199 2 - 2 - 203 (4) 31 SNF-2-D-8 08 Design ISFSI Expansion, Fuel Inspection, and Oversight 1,219 102 72,413 2,808 - 879 3,450 80,871 32 SNF-2-D-8 09 Construct ISFSI Expansion 92 5 42,362 263 - 170 4,061 46,953 (5) 33 SNF-2-D-8 10 Fabrication of Spent Fuel Canisters - Unit 2 24 1,696 25,947 9,012 - 563 305 37,547 (5) 34 SNF-2-D-8 11 Fabrication of Spent Fuel Canisters - Unit 3 23 1,696 18,782 8,943 - 487 508 30,439 (6) 35 SNF-2-D-8 12 Load Fuel Canisters and Fuel Transfer Operations - Unit 2 - - 16,574 (1) - - 2,505 19,078 (6) 36 SNF-2-D-8 13 Load Fuel Canisters and Fuel Transfer Operations - Unit 3 - - 16,574 - - - 2,505 19,079 37 ISFSI & Fuel Transfer Operations Subtotal $ 1,453 $ 19,719 $ 223,817 $ 8,362 $ - $ 2,540 $ 14,321 $ 270,210 38 39 Decontamination, Demolition, & Disposal 40 Prepare Integrated Work Sequence and Schedule for Decommissioning - - - - -

41 Modify Containment Access- Unit 2 - - - - -

42 Modify Containment Access- Unit 3 - - - - -

43 Remove and Dispose of Missile Shields - Unit 2 - - - -

44 Remove and Dispose of Reactor Head - Unit 2 - - - -

45 Remove and Dispose of Missile Shields - Unit 3 - - - -

46 Remove and Dispose of Reactor Head - Unit 3 - - - -

47 Prepare Activity Specifications - U2 - - - - -

(2) 48 Waste Contracts - - - - -

49 Install GARDIAN System - - - - -

50 Decontamination, Demolition, & Disposal - Initial D&D Activities Subtotal $ - $ - $ $ - $ $ - $ $

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DCE No. Description Labor Material Contract Other Disposal Overheads Contingency Total 51 52 Design, Specify, and Procure Special Items and Materials - - - - -

53 Test Special Cutting and Handling Equipment and Train Operators - - - - -

54 Finalize Internals and Vessel Segmenting Details - Unit 2 - - - - -

55 Segment, Package and Dispose of Reactor Internals - Unit 2 - - - -

56 Segment, Package and Dispose of Reactor Internals - Unit 3 - - - -

57 Decontamination, Demolition, & Disposal - Internals and Vessel Segmentation Subtotal $ - $ - $ $ - $ $ - $ $

58 59 Remove Underground Diesel Tank - Unit 2 - - - - -

60 Remove Underground Diesel Tank - Unit 3 - - - - -

61 Remove and Dispose of Spent Fuel Storage Racks - Unit 2 - - - -

62 Remove and Dispose of Spent Fuel Storage Racks - Unit 3 - - - -

63 Drain Spent Fuel Pool and Process Liquid Waste - Unit 2 - - - - -

64 Drain Spent Fuel Pool and Process Liquid Waste - Unit 3 - - - - -

65 Remove Protected Area Security Fencing - - - - -

66 Decontamination, Demolition, & Disposal - Removal Of Spent Fuel Systems/Equipment Subtotal $ - $ - $ $ - $ $ - $ $

67 68 Remove and Dispose of Steam Generators - Unit 2 - - - -

69 Remove and Dispose of Steam Generators - Unit 3 - - - -

70 Decontamination, Demolition, & Disposal - Steam Generator Removal Subtotal $ - $ - $ $ - $ $ - $ $

71 72 Upgrade Rail Spur - - - - -

73 Remove, Package and Dispose of Non-Essential Systems - Unit 2 - - - -

74 Remove, Package and Dispose of Non-Essential Systems - Unit 3 - - - -

75 Decontamination, Demolition, & Disposal - Non-Essential System Removal Subtotal $ - $ - $ $ - $ $ - $ $

76 77 Remove, Package and Dispose of Essential Systems - - - -

78 Reactor Vessel Insulation Removal and Disposal - Unit 2 - - - -

79 Segment, Package and Dispose of Reactor Pressure Vessel - Unit 2 - - - -

80 Reactor Vessel Insulation Removal and Disposal - Unit 3 - - - -

81 Segment, Package and Dispose of Reactor Pressure Vessel - Unit 3 - - - -

82 Remove and Dispose of Pressurizer - Unit 2 - - - -

83 Remove and Dispose of Pressurizer - Unit 3 - - - -

84 Remove and Dispose of Turbine Gantry Crane - Unit 2 - - - -

85 Remove and Dispose of Turbine Gantry Crane - Unit 3 - - - -

86 Decontamination, Demolition, & Disposal - Large Component Removal Subtotal $ - $ - $ $ - $ $ - $ $

87 88 Demolish Service Building (K-10, 20, 30) - - - -

89 Demolish South Security Processing Facility (K-70) - - - -

90 Demolish South Yard Area Buildings T-10, 20, 60 and Haz Mat - - - -

91 Procure Clean Building Demolition Equipment - - - - -

92 Demolish Diesel Generator Building - Unit 3 - - - -

93 Demolish Diesel Generator Building - Unit 2 - - - -

94 Demolish Condensate Building and Transformer Pads - Unit 2 - - - -

95 Demolish Full Flow Area and Turbine Building - Unit 2 - - - -

96 Demolish AWS Building - - - -

97 Demolish Building L-50 - - - -

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DCE No. Description Labor Material Contract Other Disposal Overheads Contingency Total 98 Demolish Maintenance Building 4 (B-64/B-65) - - - -

99 Demolish Maintenance Building 5 (B-62/B-63) - - - -

100 Demolish Outage Control Center - - - -

101 Demolish Maintenance Building 2 (B-49/B-50) - - - -

102 Demolish Maintenance Building 1 (B-43/B-44) - - - -

103 Demolish Auxiliary Radwaste Building - Common - - - -

104 Demolish Auxiliary Control Building - Common - - - -

105 Remove Systems and Demolish Make-Up Demineralizer Structures - - - -

106 Install Concrete Plugs in Intake and Discharge Structures - - - - -

107 Demolish Intake and Discharge Structures to 3-Feet Below Grade - - - -

108 Decontamination, Demolition, & Disposal - Initial Plant Building Demo Subtotal $ - $ - $ $ - $ $ - $ $

109 110 Decon Containment Building - Unit 3 - - - -

111 Decon Penetration Building - Unit 3 - - - -

112 Decon Safety Equipment and MSIV Building - Unit 3 - - - -

113 Decon Fuel Handling Building - Unit 3 - - - -

114 Decon Containment Building - Unit 2 - - - -

115 Decon Penetration Building - Unit 2 - - - -

116 Decon Safety Equipment and MSIV Building - Unit 2 - - - -

117 Decon Fuel Handling Building - Unit 2 - - - -

118 Decon Turbine Building - Unit 2 - - - -

119 Decon Auxiliary Radwaste Building - Common - - - -

120 Decon Auxiliary Control Building - Common - - - -

121 Decontamination, Demolition, & Disposal - Building Decontamination Subtotal $ - $ - $ $ - $ $ - $ $

122 123 Remove Protected Area Pavement - - - -

124 Demolish Condensate Building and Transformer Pads - Unit 3 - - - -

125 Demolish Full Flow Area and Turbine Building - Unit 3 - - - -

126 Demolish Unit 3 Fuel Handling Building to 3-Feet Below Grade - - - -

127 Demolish Penetration Building - Unit 3 - - - -

128 Demolish Unit 2 Fuel Handling Building to 3-Feet Below Grade - - - -

129 Demolish Penetration Building - Unit 2 - - - -

130 Decontamination, Demolition, & Disposal - Final Plant Building Demo Subtotal $ - $ - $ $ - $ $ - $ $

131 (2) 132 Offshore Conduit Diffuser and Risers - - - - -

133 (2) 134 Backfill - - - - -

135 136 Demolish Staging Warehouse - - - -

137 Demolish Administration Building (K-40/50) - - - -

138 Detension and Remove Unit 3 Containment Building Tendons - - - -

139 Demolish Safety Equipment and MSIV Building - Unit 3 - - - -

140 Demolish Unit 3 Containment Building to 3-Feet Below Grade - - - -

141 Detension and Remove Unit 2 Containment Building Tendons - - - -

142 Demolish Safety and MSIV Equipment Building - Unit 2 - - - -

143 Demolish Unit 2 Containment Building to 3-Feet Below Grade - - - -

144 Decontamination, Demolition, & Disposal - Containment Building Demo Subtotal $ - $ - $ $ - $ $ - $ $

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DCE No. Description Labor Material Contract Other Disposal Overheads Contingency Total 146 Prepare License Termination Plan - - - - -

147 Final Status Survey - - - -

148 Subsurface Structure Removal Engineering Planning and Design - - - - -

149 Decontamination, Demolition, & Disposal - Final Survey/License Termination Subtotal $ - $ - $ $ - $ $ - $ $

150 (2) 151 Waste Taxes (Pass Through) - - - - -

(2) 152 Waste Taxes (Pass Through) - - - - -

153 Decontamination, Demolition, & Disposal - Waste Subtotal $ - $ - $ - $ - $ $ - $ $

154 155 - - - - -

156 157 Decontamination, Demolition, & Disposal Subtotal $ - $ - $ $ - $ $ - $ $

158 159 Other Projects (2) (7) 160 SNF-2-D-AM Areva Areva ISFSI Relicensing - - 11,763 7 - - 2,346 14,117 (2) (7) 161 SNF-2-D-AM Holtec 1 Holtec ISFSI I&M Program Development - - 13,964 24 - 3 2,733 16,724 (2) 162 SNF-2-D-AM Holtec 2 Holtec ISFSI Relicensing - - 4,686 - - - 961 5,647 163 ISFSI Aging Management Subtotal $ - $ - $ 30,414 $ 32 $ - $ 3 $ 6,040 $ 36,489 164 (2) 165 SNF-2-D-EP Holtec Environmental Permitting - Holtec - - 2,812 - - - 577 3,388 (2) 166 SNF-2-D-EP Areva Environmental Permitting - Areva - - 1,546 - - - 317 1,864 167 Coastal Development Permit Extension Subtotal $ - $ - $ 4,358 $ - $ - $ - $ 894 $ 5,252 168 (2) 169 SNF-2-D-GTCC GTCC Waste Storage - - 21,197 - - - 5,435 26,632 170 (8) 171 SR-1-D-14 01 Mesa Site Phase I and II Site Assessment and Lease Surrender 494 - 6,784 27 - 163 1,075 8,542 172 SR-1-D-14 02 Disposition Hazardous Waste from Mesa Site 113 - 9 - - 73 - 195 173 SR-1-D-14 03 Mesa Site Characterization Survey 15 - 133 (102) - 10 - 56 (9) 174 SR-2-D-15 02 Obtain Required Permits - Mesa - - 54 26 - 1 - 81 (10) 175 SR-2-D-15 09 Mesa Buildings - Demo, Maintenance 254 42 8,558 62 - 97 524 9,537 176 SR-2-D-15 11 Demolish Mesa Roads and Parking Lots - 381 554 - - - 190 1,125 177 SR-2-D-15 12 Finish Grading and Re-vegetate Mesa Site - 385 285 - - - 135 805 178 Mesa Site Turnover Subtotal $ 875 $ 807 $ 16,377 $ 14 $ - $ 344 $ 1,923 $ 20,341 179 (2) 180 LT-3-D-DCE DCE Update - - 2,046 360 - - 181 2,588 (2) 181 SNF-D-DCE DCE Update - - 937 - - - 144 1,081 182 DCE Update Subtotal $ - $ - $ 2,983 $ 360 $ - $ - $ 326 $ 3,669 183 (11) 184 SR-3-D-16 05 Obtain CEQA Permit & Approvals 902 15 5,573 325 - 414 685 7,914 (12) 185 SR-3-D-16 03 Initial Real Estate Authorization Renewal and Plant Easement 2,231 - 8,836 616 - 607 2,137 14,427 (2) 186 SR-D-NEPA 2 Plant Lease Extension 1,309 - 1,477 43 - 388 660 3,878 (2) 187 SR-D-NEPA 3 Plant Lease Amendment For Final Site Restoration 1,558 - 5,185 52 - 462 1,488 8,745 (2) 188 SNF-D-GTCC Disp GTCC Disposal - - 33,741 - - - 6,921 40,662 (2) 189 SNF-2-D-CDP ISFSI CDP Settlement - - 3,508 769 - - - 4,277 (2) 190 SR-D-RFP Substructure Removal Contractor Procurement 4,444 56 - - - 1,318 1,193 7,011 191 SNF-1-D-7 05 Cyber Security Modifications 337 670 7,959 81 - 332 - 9,380 (2) 192 SNF-D-NIA Sump NIA Sump Modifications - - 937 - - - 144 1,081 193 Other Projects Subtotal $ 11,657 $ 1,549 $ 142,546 $ 2,293 $ - $ 3,868 $ 27,845 $ 189,758 194 4 Of 9

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DCE No. Description Labor Material Contract Other Disposal Overheads Contingency Total 195 Substructure Removal (2) 196 SR-D-BKFL REM Backfill Removal 3,147 2,608 - - - 933 1,698 8,386 197 SR-5-D-18 02 Install Sheet Piling and Excavation Shoring - 19,594 9,635 - - - 7,369 36,599 198 SR-5-D-18 03 Install Dewatering System and Effluent Treatment and Discharge Controls - - - 27,926 - - 6,981 34,907 199 SR-5-D-18 04 Demolish and Backfill Unit 3 Condensate Storage Area Below -3 Feet - 280 194 - 533 - 256 1,264 200 SR-5-D-18 05 Demolish and Backfill Unit 3 Diesel Generator Building Below -3 Feet - 159 111 - 259 - 135 664 201 SR-5-D-18 06 Demolish and Backfill Unit 3 Fuel Handling Building Below -3 Feet - 431 322 - 879 - 416 2,048 202 SR-5-D-18 07 Demolish and Backfill Unit 3 Radwaste and Control Building Below -3 Feet - 1,137 995 - 1,705 - 976 4,813 203 SR-5-D-18 08 Demolish and Backfill Unit 3 Turbine Building Structure Below 9 Ft Elevation - 5,165 4,219 - 7,386 - 4,267 21,037 204 SR-5-D-18 09 Demolish and Backfill Unit 3 Safety Equipment Building Below -3 Feet - 809 776 - 3,861 - 1,391 6,838 205 SR-5-D-18 10 Demolish and Backfill Unit 3 Penetration Area Below -3 Feet - 379 303 - 751 - 365 1,798 206 SR-5-D-18 11 Demolish and Backfill Unit 3 Full Flow Building Below -3 Feet - 143 98 - 240 - 122 603 207 SR-5-D-18 12 Demolish and Backfill Unit 3 Containment Building Below -3 Feet - 1,719 1,272 - 4,731 - 1,969 9,692 208 SR-5-D-18 13 Demolish and Backfill Unit 2 Condensate Storage Area Below -3 Feet - 280 194 - 533 - 256 1,264 209 SR-5-D-18 14 Demolish and Backfill Unit 2 Diesel Generator Building Below -3 Feet - 159 111 - 259 - 135 664 210 SR-5-D-18 15 Demolish and Backfill Unit 2 Fuel Handling Building Below -3 Feet - 431 322 - 879 - 416 2,048 211 SR-5-D-18 16 Demolish and Backfill Unit 2 Radwaste and Control Building Below -3 Feet - 1,233 1,030 - 1,705 - 1,009 4,976 212 SR-5-D-18 17 Demolish and Backfill Unit 2 Turbine Building Structure Below 9 Ft Elevation - 5,165 4,219 - 7,386 - 4,267 21,038 213 SR-5-D-18 18 Demolish and Backfill Unit 2 Safety Equipment Building Below -3 Feet - 809 776 - 3,861 - 1,391 6,838 214 SR-5-D-18 19 Demolish and Backfill Unit 2 Penetration Area Below -3 Feet - 379 303 - 751 - 365 1,798 215 SR-5-D-18 20 Demolish and Backfill Unit 2 Full Flow Building Below -3 Feet - 390 232 - 240 - 219 1,081 216 SR-5-D-18 21 Demolish and Backfill Unit 2 Containment Building Below -3 Feet - 1,716 1,271 - 4,731 - 1,968 9,686 217 SR-5-D-18 22 Demolish and Backfill Intake Structure Below -3 Feet - 10,013 7,373 - 23,749 - 10,483 51,618 218 SR-5-D-18 24 Remove Sheet Piling and Excavation Shoring - - 11,216 - - - 2,876 14,091 219 SR-5-D-18 25 Remove Dewatering System and Effluent Treatment - - - 6,678 - - 1,669 8,347 220 SR-6-D-19 06 Remove and Stockpile Existing Seawall Erosion Protection - 10 5 - - - 4 20 221 SR-6-D-19 07 Remove Unit 2 and 3 Seawall and Pedestrian Walkway - 2,914 2,826 (38) 4,606 - 2,618 12,927 222 SR-6-D-19 08 Remove Remaining Intake and Outfall Box Culvert - 446 210 (18) 2,211 - 725 3,574 223 SR-6-D-19 10 Backfill and Compaction of Excavation - 2,131 1,401 - - - 892 4,424 224 Substructure Removal Subtotal $ 3,147 $ 58,501 $ 49,416 $ 34,547 $ 71,258 $ 933 $ 55,239 $ 273,042 225 226 Offshore Conduit Removal 227 SR-3-D-16 01 Hydrogeologic Investigation and Outfall Conduit Survey - 125 283 100 - - 129 637 228 SR-5-D-18 23 Remove Off Shore Intake and Outfall Conduits - 42,198 10,838 (163) 19,788 - 18,334 90,995 229 Offshore Conduit Removal Subtotal $ - $ 42,323 $ 11,121 $ (63) $ 19,788 $ - $ 18,463 $ 91,631 230 231 ISFSI Demolition 232 SNF D&D-1-D-12 01 Preparation and NRC Review of License Termination Plan - - 111 155 - - 67 333 233 SNF D&D-2-D-13 01 Install GARDIAN Bulk Assay System - - - 525 - - 131 656 (13) 234 SNF D&D-2-D-13 02 Decon Areva Modules - 45 104 - 136 - 72 357 235 SNF D&D-2-D-13 03 Final Status Survey of ISFSI - 78 488 - - - 145 711 (14) 236 SNF D&D-2-D-13 04 Clean Demo of Areva ISFSI Pad and Modules - 1,009 1,802 - 1,190 - 1,019 5,020 (15) 237 SNF D&D-2-D-13 05 Demolish ISFSI Security Building - 255 186 - 495 - 238 1,174 238 SNF D&D-2-D-13 06 Restore ISFSI Site - 492 325 - - - 206 1,023 239 SNF D&D-2-D-13 07 Preparation of Final Report on Decommissioning and NRC Review - - 52 - - - 13 65 (2) 240 SNF D&D-2-D-13 08 Clean Demo of Holtec ISFSI Pad and Modules - 1,871 1,361 - 4,602 - 1,997 9,831 241 ISFSI Demolition Subtotal $ - $ 3,750 $ 4,429 $ 680 $ 6,423 $ - $ 3,889 $ 19,171 242 5 Of 9

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Total (2014$)

(1)

DCE No. Description Labor Material Contract Other Disposal Overheads Contingency Total 243 Final Site Restoration 244 SR-6-D-19 01 Obtain Required Permits and Approvals - 19 384 125 - - 135 663 245 SR-6-D-19 03 Procure Site Restoration Equipment - 385 - - - - 96 481 246 SR-6-D-19 12 Install Shoreline Erosion Control and Restoration Features - 137 9 - - - 37 182 247 SR-6-D-19 13 Remove Railroad Tracks, Rails and Ballast - 33 60 - - - 24 116 248 SR-6-D-19 14 Remove Gunite Slope Protection - 348 164 (14) 1,728 - 566 2,793 249 SR-6-D-19 15 Remove Access Roads and Parking Lots - 173 229 - - - 102 503 250 SR-6-D-19 16 Finish Grading and Re-Vegetate Site - 801 925 - - - 438 2,164 251 Final Site Restoration Subtotal $ - $ 1,897 $ 1,772 $ 111 $ 1,728 $ - $ 1,397 $ 6,905 252 253 Distributed Subtotal 254 255 Labor-Staffing 256 LT-U-1 01 Utility Staff 147,700 538 95,923 1,316 - 57,551 15,777 318,805 257 SNF-U-2 01 Utility Staff 187,798 394 37,206 1,074 - 65,874 18,060 310,406 258 SR-U-3 01 Utility Staff 41,681 24 57,641 66 - 10,379 10,980 120,770 259 Utility Staff Subtotal $ 377,179 $ 956 $ 190,770 $ 2,457 $ - $ 133,803 $ 44,817 $ 749,981 260 261 LT-U-1 03 Security Force 11,010 4 138 18 - 2,128 577 13,875 262 SNF-U-2 04 Security Force 155,557 58 2,344 45 - 52,636 11,677 222,317 263 Security Force Subtotal $ 166,567 $ 61 $ 2,482 $ 63 $ - $ 54,764 $ 12,255 $ 236,192 264 265 Labor-Staffing Subtotal $ 543,746 $ 1,017 $ 193,252 $ 2,519 $ - $ 188,567 $ 57,071 $ 986,172 266 267 Non-Labor (2) 268 SNF-U-AM Areva Areva ISFSI Aging Management - - 3,480 - - - 535 4,015 (2) 269 SNF-U-AM Holtec Holtec ISFSI Aging Management - - 9,747 - - - 1,499 11,247 270 Aging Management Subtotal $ - $ - $ 13,227 $ - $ - $ - $ 2,035 $ 15,262 271 272 LT-U-1 17 Association Fees and Expenses - 3 2,253 2,122 - 8 519 4,906 (2) 273 SNF-U-2 26 Association Fees and Expenses - - 198 1,767 - - 296 2,261 (2) 274 SR-U-3 17 Association Fees and Expenses - - 451 762 - - 184 1,397 275 Association Fees and Expenses Subtotal $ - $ 3 $ 2,903 $ 4,651 $ - $ 8 $ 999 $ 8,564 276 277 LT-U-1 15 Community Engagement Panel 382 63 2,234 4,128 - 156 653 7,615 (2) 278 SNF-U-2 25 Community Engagement Panel - - 24 2,345 - - 356 2,725 (2) 279 SR-U-3 21 Community Engagement Panel - - 7 1,858 - - 280 2,145 280 Community Engagement Panel Subtotal $ 382 $ 63 $ 2,265 $ 8,332 $ - $ 156 $ 1,288 $ 12,486 281 6 Of 9

%

Appendix C Table 2 Detailed Cost Table By Cost Type (2014 Dollars In Thousands, 100% Share)

Total (2014$)

(1)

DCE No. Description Labor Material Contract Other Disposal Overheads Contingency Total (16) 282 LT-U-1 08 Contracted Services 684 9,499 75,723 7,883 - 75 6,383 100,247 (16) 283 SNF-U-2 11 Contracted Services 340 11,309 59,271 17,865 - 155 10,120 99,060 (16) 284 SR-U-3 06 Contracted Services 18 732 19,705 2,361 - 17 3,300 26,134 (2) 285 SR-U-Bank Bank Fees And Interest - - - (67) - - - (67)

(2) 286 SR-U-Inv Adj Vendor Invoice Adjustment - - - (209) - (1) - (210) 287 Contracted Services Subtotal $ 1,042 $ 21,540 $ 154,700 $ 27,833 $ - $ 247 $ 19,803 $ 225,164 288 289 LT-U-1 09 DAW Disposal - - 20 - - - - 20 290 SNF-U-2 12 DAW Disposal - - 10 - - - - 10 291 DAW Disposal Subtotal $ - $ - $ 30 $ - $ - $ - $ - $ 30 292 293 LT-U-1 25 Decommissioning Advisor - 730 6,487 16 - 25 671 7,930 (2) 294 SNF-U-2 28 Decommissioning Advisor - - 274 - - - 42 316 (2) 295 SR-U-3 22 Decommissioning Advisor - - 1,432 - - - 220 1,653 296 Decommissioning Advisor Subtotal $ - $ 730 $ 8,193 $ 16 $ - $ 25 $ 934 $ 9,899 297 (2) 298 LT-U-CO DGC Executive Oversight Committee - - 2,527 - - - 389 2,915 (2) 299 SR-U-CO DGC Executive Oversight Committee - - 699 - - - 107 806 300 DGC Executive Oversight Committee Subtotal $ - $ - $ 3,225 $ - $ - $ - $ 496 $ 3,722 301 302 SNF-U-2 09 Emergency Preparedness Fees - 22 144 43,181 - 89 4,905 48,341 303 Emergency Preparedness Fees Subtotal $ - $ 22 $ 144 $ 43,181 $ - $ 89 $ 4,905 $ 48,341 304 305 LT-U-1 10 Energy - - - 45,237 - 134 4,577 49,948 306 SNF-U-2 13 Energy - - - 16,421 - 30 1,957 18,409 307 SR-U-3 07 Energy - - - 14,239 - - 2,136 16,375 308 Energy Subtotal $ - $ - $ - $ 75,897 $ - $ 164 $ 8,670 $ 84,732 309 310 LT-U-1 24 Environmental Permits and Fees 2 - 334 3,317 - 26 79 3,758 (2) 311 SNF-U-2 27 Environmental Permits and Fees - - 633 333 - - 147 1,114 (2) 312 SR-U-3 23 Environmental Permits and Fees - - 181 1,403 - - 238 1,822 313 Environmental Permits and Fees Subtotal $ 2 $ - $ 1,149 $ 5,053 $ - $ 26 $ 465 $ 6,695 314 (2) 315 SNF-U-GW Ground Water Monitoring - - 319 - - - 49 368 (2) 316 SR-U-GW Ground Water Monitoring - - 112 - - - 17 130 317 Ground Water Monitoring Subtotal $ - $ - $ 431 $ - $ - $ - $ 66 $ 497 318 (17) 319 LT-U-1 20 Information Technology 2,524 1,547 5,684 5,993 - 1,680 995 18,424 (17) 320 SNF-U-2 20 Information Technology - 960 3,496 374 - - 738 5,568 (17) 321 SR-U-3 15 Information Technology - 1,605 2,574 624 - - 730 5,533 (18) 322 LT-U-1 21 Telecommunications 1,275 35 137 88 - 815 - 2,350 (18) 323 LT-U-1 22 Personal Computers - 9 9 - - - - 18 (18) 324 SNF-U-2 22 Personal Computers - 7 - - - - - 7 325 Information Technology Subtotal $ 3,799 $ 4,163 $ 11,900 $ 7,080 $ - $ 2,496 $ 2,463 $ 31,900 326 7 Of 9

%

Appendix C Table 2 Detailed Cost Table By Cost Type (2014 Dollars In Thousands, 100% Share)

Total (2014$)

(1)

DCE No. Description Labor Material Contract Other Disposal Overheads Contingency Total 327 LT-U-1 05 Insurance 1 - - 18,675 - - 1,048 19,723 (19) 328 LT-U-1 14 Workers Compensation Insurance - - - 381 - - - 381 329 SNF-U-2 06 Insurance - - - 33,712 - - 4,835 38,547 330 SR-U-3 04 Insurance - - - 4,358 - - 654 5,011 331 Insurance Subtotal $ 1 $ - $ - $ 57,126 $ - $ - $ 6,536 $ 63,663 332 (2) 333 LT-U-Legal Third-Party Legal - - 8,460 (122) - 16 1,006 9,359 (2) 334 SNF-U-Legal Third-Party Legal - - 9,013 15 - 19 1,076 10,123 (2) 335 SR-U-Legal Third-Party Legal (802) - 5,013 7 - (389) 486 4,315 336 Third-Party Legal Subtotal $ (802) $ - $ 22,486 $ (100) $ - $ (353) $ 2,568 $ 23,799 337 338 LT-U-1 07 NRC Fees - - 4 10,480 - 42 927 11,452 339 SNF-U-2 08 NRC Fees - - 28 17,229 - 3 2,474 19,735 340 NRC Fees Subtotal $ - $ - $ 32 $ 27,709 $ - $ 45 $ 3,401 $ 31,187 341 (2) 342 LT-U-Office Office Space - 19 937 - - - 147 1,104 (2) 343 SNF-U-Office Office Space - 343 3 - - - 52 397 (2) 344 SR-U-Office Office Space - 100 35 - - - 20 154 345 Office Space Lease Subtotal $ - $ 461 $ 975 $ - $ - $ - $ 219 $ 1,655 346 347 LT-U-1 04 Security Related Expenses - 160 205 245 - 2 54 667 348 SNF-U-2 05 Security Related Expenses 1 1,847 6,180 1,261 - 10 1,259 10,559 349 SR-U-3 03 Security Related Expenses 2 121 309 114 - 4 16 566 350 Security Related Expenses Subtotal $ 4 $ 2,129 $ 6,694 $ 1,620 $ - $ 16 $ 1,329 $ 11,792 351 352 SR-U-3 11 Severance 102,979 - 1,796 4,018 - 8,329 3,925 121,047 353 Severance Subtotal $ 102,979 $ - $ 1,796 $ 4,018 $ - $ 8,329 $ 3,925 $ 121,047 354 355 LT-U-1 06 Site Lease and Easement Expenses 1 - 68 3,996 - - 336 4,401 356 SNF-U-2 07 Site Lease and Easement Expenses - - - 39,974 - - 5,996 45,970 357 SR-U-3 05 Site Lease and Easement Expenses 2 - 218 41,749 - - 5,141 47,110 358 Site Lease and Easement Expenses Subtotal $ 3 $ - $ 286 $ 85,719 $ - $ - $ 11,473 $ 97,481 359 (2) 360 SNF-U-SFL Loading Spent Fuel & GTCC Waste To DOE - - 26,543 - - - 4,083 30,626 361 Loading Spent Fuel & GTCC Waste To DOE Subtotal $ - $ - $ 26,543 $ - $ - $ - $ 4,083 $ 30,626 362 363 LT-U-1 19 Tools and Equipment - - 14 34 - - - 49 364 Tools and Equipment Subtotal $ - $ - $ 14 $ 34 $ - $ - $ - $ 49 365 (20) 366 LT-U-1 18 Water - - - 3,773 - 9 419 4,201 (20) 367 SNF-U-2 18 Water - - - 7,975 - 6 1,076 9,056 (20) 368 SR-U-3 13 Water - - - 2,850 - - 426 3,276 369 Water Subtotal $ - $ - $ - $ 14,598 $ - $ 15 $ 1,921 $ 16,534 370 371 LT-U-1 02 Utility Staff Health Physics Supplies - 113 970 28 - 8 20 1,139 372 SNF-U-2 02 Utility Staff Health Physics Supplies - 150 2,192 47 - 12 122 2,524 373 Utility Staff Health Physics Supplies Subtotal $ - $ 263 $ 3,162 $ 75 $ - $ 20 $ 142 $ 3,663 374 375 Non-Labor Subtotal $ 107,408 $ 29,374 $ 260,155 $ 362,842 $ - $ 11,283 $ 77,722 $ 848,786 8 Of 9

%

Appendix C Table 2 Detailed Cost Table By Cost Type (2014 Dollars In Thousands, 100% Share)

Total (2014$)

(1)

DCE No. Description Labor Material Contract Other Disposal Overheads Contingency Total 376 377 Service Level Agreements (2) 378 LT-U-SLA Service Level Agreements 30,319 (9) 2,204 28,976 - 8,542 6,034 76,066 (2) 379 SNF-U-SLA Service Level Agreements 7,435 (8) 1,993 8,847 - 24,284 3,385 45,935 (2) 380 SR-U-SLA Service Level Agreements 9,171 - 127 7,936 - 24,745 4,232 46,211 381 Service Level Agreements Subtotal $ 46,925 $ (17) $ 4,324 $ 45,759 $ - $ 57,571 $ 13,651 $ 168,212 382 383 DGC Staffing 384 - - - - -

385 - - - - -

386 Subtotal DGC Staffing $ - $ - $ $ - $ - $ - $ $

387 388 Undistributed Subtotal $ $ $ $ $ - $ $ $

389 390 Total $ $ $ $ $ $ $ $

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Notes To Appendix C Notes:

(1) The DCE line numbers align to the line numbers in Appendix D of the 2014 DCE. The DCE line numbers indicate the corresponding 2014 DCE (1) NRC cost account, (2) 2014 DCE period, (3) cost type (i.e., distributed or undistributed), and (4) line number. For example, LT-2-D-2.17 in Appendix C of this DCE corresponds to License Termination Period 2 distributed cost line number 2.17 in Appendix D of the 2014 DCE.

(2) These line items were not included in the 2014 DCE, and therefore a new DCE No. has been created.

(3) The description for DCE line number SNF-1-D-7.02 in the 2014 DCE of "Design and Fabricate Spent Fuel Canisters" has been updated to "Holtec Long Lead Items and Areva Contract Closure" to better reflect the associated costs.

(4) The description for DCE line number SNF-2-D-8.08 in the 2014 DCE of "Design ISFSI Expansion" has been updated to "Design ISFSI Expansion, Fuel Inspection, and Oversight" to better reflect the associated costs.

(5) The description for DCE line numbers SNF-2-D-8.10 and SNF-2-D-8.11 in the 2014 DCE of "Purchase and Fabrication of Spent Fuel Canisters and AHSMs" for Units 2 & 3, respectively, have been updated to "Fabrication of Spent Fuel Canisters" to better reflect the associated costs.

(6) The description for DCE line numbers SNF-2-D-8.12 and SNF-2-D-8.13 in the 2014 DCE of "Deliver and Load Spent Fuel Canisters and Transfer to ISFSI" for Units 2 & 3, respectively, have been updated to "Load Fuel Canisters and Fuel Transfer Operations" to better reflect the associated costs.

(7) In Advice Letter 3589-E, Aging Management recorded costs were included in DCE No. SNF-2-D-AM. In the 2017 DCE, Areva and Holtec Aging Management costs are estimated separately, and therefore the Areva and Holtec recorded costs are also shown separately and are included in DCE Nos. SNF-2-D-AM Areva and SNF-2-D-AM Holtec 1.

(8) The description for DCE line number SR-1-D-14.01 in the 2014 DCE of "Mesa Site Phase I and II Site Assessment" has been updated to "Mesa Site Phase I and II Site Assessment and Lease Surrender" to better reflect the associated costs.

(9) The description for DCE line number SR-2-D-15.02 in the 2014 DCE of "Obtain Required Permits For Mesa, South Access and South Yard" has been updated to "Obtain Required Permits - Mesa" to better reflect the associated costs.

(10) The description for DCE line number SR-2-D-15.09 in the 2014 DCE of "Demolish Mesa Buildings" has been updated to "Mesa Buildings - Demo, Maintenance" to better reflect the associated costs.

(11) The description for DCE line number SR-3-D-16.05 in the 2014 DCE of "Obtain Required Permits and Approvals" has been updated to "Obtain CEQA Permit &

Approvals" to better reflect the associated costs.

(12) The description for DCE line number SR-3-D-16.03 in the 2014 DCE of "Environmental Impacts Analyses for Lease Termination Activities" has been updated to "Initial Real Estate Authorization Renewal and Plant Easement" to better reflect the associated costs.

(13) The description for DCE line number SNF D&D-2-D-13.02 in the 2014 DCE of "Decon AHSMs" has been updated to "Decon Areva Modules" to better reflect the associated costs.

(14) The description for DCE line number SNF D&D-2-D-13.04 in the 2014 DCE of "Clean Demolition of ISFSI AHSMs and Pad" has been updated to "Clean Demo of Areva ISFSI Pad and Modules" to better reflect the associated costs.

(15) The description for DCE line number SNF D&D-2-D-13.05 in the 2014 DCE of "Clean Demolition of ISFSI Support Structures" has been updated to "Demolish ISFSI Security Building" to better reflect the associated costs.

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Notes To Appendix C (16) The description for DCE line numbers LT-U-1.08, SNF-U-2.11, and SR-U-3.06 in the 2014 DCE of "Materials and Services" has been updated to "Contracted Services" to better reflect the associated costs.

(17) The description for DCE line numbers LT-U-1.20, SNF-U-2.20, and SR-U-3.15 in the 2014 DCE of "Non-Process Computers" has been updated to "Information Technology" to better reflect the associated costs.

(18) All estimated (i.e., 2017-2051) undistributed Information Technology costs that are not covered by the IT Service Level Agreement are captured in DCE line items LT-U-1.20, SNF-U-2.20, and SR-U-3.15, "Information Technology," and therefore DCE line items LT-U-1.21, LT-U-1.22, and SNF-U-2.22 for Telecommunications and Personal Computers do not include any estimated costs.

(19) Estimated costs (i.e., 2017-2051) for workers compensation insurance are included in DCE line items LT-U-1.05, SNF-U-2.06, and SR-U-3.04, "Insurance."

(20) The description for DCE line numbers LT-U-1.18, SNF-U-2.18, and SR-U-3.13 in the 2014 DCE of "Utilities (Water, Gas, Phone)" has been updated to "Water" to better reflect the associated costs.

(21) The undistributed DGC staffing costs associated with the fixed price contract are included in the distributed project for Decontamination, Demolition, & Disposal.

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San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate Appendix '

Annual Cash Flow Tables By NRC Cost &DWHJRU\

%

Appendix D Table 1-A Annual Cash Flow Table By NRC&RVW &DWHJRU\ - Unit 2 Nominal / 2017 Dollars in Thousands License Spent Fuel Period Year Termination Management Site Restoration Total Pd 1 - Initial Activities 2013 $ 40,388 $ 40,591 $ 40,988 $ 121,967 2014 56,443 39,579 12,731 108,753 2015 63,557 55,132 25,520 144,209 2016 43,464 62,700 1,044 107,208 Pd 2 -Transition & Pool 2017 104,155 67,490 4,667 176,313 Storage 2018 61,943 68,965 3,710 134,618 Pd 3 Pd 4 - D&D and Dry 2019 49,280 27,254 9,911 86,445 Storage 2020 58,306 15,799 1,847 75,951 2021 141,012 8,718 2,240 151,971 2022 153,239 8,077 22,202 183,517 2023 65,533 5,536 52,406 123,475 2024 40,938 5,423 32,450 78,811 2025 31,276 5,344 24,942 61,562 2026 60,901 5,747 15,901 82,548 2027 17,045 5,536 41,145 63,726 2028 19,853 5,678 1,871 27,402 Pd 5 - Dry Storage 2029 - 9,883 1,241 11,124 2030 - 9,842 - 9,842 2031 - 10,224 20 10,244 2032 - 10,528 24 10,552 2033 - 12,192 18 12,209 2034 - 12,170 18 12,187 2035 - 13,401 20 13,422 2036 - 12,628 - 12,628 2037 - 11,127 - 11,127 2038 - 10,971 - 10,971 2039 - 11,445 - 11,445 2040 - 11,363 68 11,431 2041 - 10,905 45 10,950 2042 - 11,626 43 11,669 2043 - 11,629 27 11,656 2044 - 11,041 4,317 15,359 2045 - 10,440 4,308 14,748 Pd 6 - Civil Works 2046 - 8,600 29,378 37,977 Project 2047 - 7,150 76,564 83,714 2048 - 8,454 62,150 70,604 2049 - 35,143 14,931 50,074 Pd 7 - ISFSI Demolition 2050 - 12,763 12,744 25,507

& Final Site Restoration 2051 - 6,125 23,682 29,807 Total $ 1,007,333 $ 697,217 $ 523,173 $ 2,227,722

%

Appendix D Table 1-B Annual Cash Flow Table By NRC &RVW&DWHJRU\ - Unit 3 Nominal / 2017 Dollars in Thousands License Spent Fuel Period Year Termination Management Site Restoration Total Pd 1 - Initial Activities 2013 $ 40,388 $ 40,161 $ 40,988 $ 121,538 2014 56,270 39,421 12,731 108,422 2015 63,601 47,813 27,164 138,577 2016 43,688 65,477 5,157 114,322 Pd 2 -Transition & Pool 2017 99,851 69,885 15,574 185,310 Storage 2018 62,289 70,530 11,543 144,362 Pd 3 Pd 4 - D&D and Dry 2019 52,448 28,927 16,145 97,520 Storage 2020 76,967 17,443 5,994 100,404 2021 122,673 10,562 8,131 141,366 2022 118,848 9,931 27,672 156,451 2023 65,340 7,406 55,726 128,472 2024 46,564 7,293 39,281 93,137 2025 53,899 7,214 37,747 98,860 2026 51,797 6,684 23,721 82,202 2027 23,351 6,473 40,386 70,210 2028 19,859 6,615 1,895 28,369 Pd 5 - Dry Storage 2029 - 10,908 1,241 12,150 2030 - 10,811 - 10,811 2031 - 11,192 834 12,027 2032 - 11,568 1,011 12,579 2033 - 13,203 749 13,952 2034 - 13,174 757 13,930 2035 - 14,552 867 15,420 2036 - 13,700 - 13,700 2037 - 12,199 - 12,199 2038 - 12,100 - 12,100 2039 - 12,517 - 12,517 2040 - 12,435 2,879 15,314 2041 - 12,034 1,916 13,950 2042 - 12,698 1,804 14,502 2043 - 12,701 1,123 13,824 2044 - 12,688 9,105 21,794 2045 - 11,972 8,718 20,690 Pd 6 - Civil Works 2046 - 9,654 29,648 39,302 Project 2047 - 8,492 76,834 85,326 2048 - 9,508 61,774 71,282 2049 - 36,198 34,134 70,331 Pd 7 - ISFSI Demolition 2050 - 12,763 66,431 79,194

& Final Site Restoration 2051 - 6,125 72,005 78,130 Total $ 997,833 $ 735,025 $ 741,683 $ 2,474,542

%

Appendix D Table 2-A Annual Cash Flow Table By NRC &RVW&DtHJRU\ - Unit 2 2014 Dollars in Thousands License Spent Fuel Period Year Termination Management Site Restoration Total Pd 1 - Initial Activities 2013 $ 40,388 $ 40,591 $ 40,988 $ 121,967 2014 56,443 39,579 12,731 108,753 2015 62,388 54,147 25,017 141,552 2016 41,851 60,067 1,026 102,945 Pd 2 -Transition & Pool 2017 97,798 63,427 4,397 165,622 Storage 2018 58,415 64,919 3,512 126,845 Pd 3 Pd 4 - D&D and Dry 2019 46,449 25,691 9,376 81,515 Storage 2020 54,947 14,904 1,767 71,617 2021 132,808 8,224 2,138 143,170 2022 144,304 7,618 20,915 172,837 2023 61,728 5,225 49,370 116,323 2024 38,580 5,120 30,609 74,309 2025 29,487 5,044 23,539 58,070 2026 57,385 5,423 15,014 77,822 2027 16,089 5,226 38,808 60,123 2028 18,764 5,358 1,787 25,909 Pd 5 - Dry Storage 2029 - 9,361 1,170 10,531 2030 - 9,325 - 9,325 2031 - 9,680 19 9,698 2032 - 9,965 22 9,988 2033 - 11,534 17 11,550 2034 - 11,513 17 11,529 2035 - 12,671 19 12,691 2036 - 11,946 - 11,946 2037 - 10,530 - 10,530 2038 - 10,383 - 10,383 2039 - 10,835 - 10,835 2040 - 10,754 64 10,818 2041 - 10,323 43 10,365 2042 - 11,004 40 11,044 2043 - 11,003 25 11,028 2044 - 10,452 4,057 14,510 2045 - 9,889 4,049 13,938 Pd 6 - Civil Works 2046 - 8,106 27,855 35,962 Project 2047 - 6,743 72,797 79,540 2048 - 7,972 58,788 66,760 2049 - 33,100 14,123 47,223 Pd 7 - ISFSI Demolition 2050 - 12,071 12,050 24,121

& Final Site Restoration 2051 - 5,804 22,433 28,238 Total $ 957,823 $ 665,525 $ 498,584 $ 2,121,932

%

Appendix D Table 2-B Annual Cash Flow Table By NRC&RVW&DWHJRU\ - Unit 3 2014 Dollars in Thousands License Spent Fuel Period Year Termination Management Site Restoration Total Pd 1 - Initial Activities 2013 $ 40,388 $ 40,161 $ 40,988 $ 121,538 2014 56,270 39,421 12,731 108,422 2015 62,436 46,872 26,631 135,939 2016 42,075 63,001 4,981 110,057 Pd 2 -Transition & Pool 2017 93,754 65,719 14,650 174,122 Storage 2018 58,747 66,431 10,886 136,065 Pd 3 Pd 4 - D&D and Dry 2019 49,431 27,304 15,243 91,978 Storage 2020 72,511 16,489 5,671 94,671 2021 115,546 9,997 7,703 133,246 2022 111,934 9,400 26,065 147,399 2023 61,546 7,022 52,495 121,063 2024 43,875 6,917 37,039 87,831 2025 50,781 6,841 35,592 93,213 2026 48,817 6,323 22,375 77,514 2027 22,025 6,126 38,094 66,245 2028 18,770 6,258 1,810 26,839 Pd 5 - Dry Storage 2029 - 10,345 1,170 11,515 2030 - 10,255 - 10,255 2031 - 10,610 786 11,396 2032 - 10,963 952 11,916 2033 - 12,505 705 13,210 2034 - 12,477 712 13,189 2035 - 13,776 816 14,592 2036 - 12,976 - 12,976 2037 - 11,560 - 11,560 2038 - 11,467 - 11,467 2039 - 11,865 - 11,865 2040 - 11,784 2,710 14,494 2041 - 11,407 1,803 13,210 2042 - 12,034 1,698 13,732 2043 - 12,033 1,057 13,090 2044 - 12,023 8,565 20,588 2045 - 11,351 8,201 19,552 Pd 6 - Civil Works 2046 - 9,120 28,115 37,235 Project 2047 - 8,027 73,056 81,083 2048 - 8,986 58,430 67,416 2049 - 34,114 32,373 66,487 Pd 7 - ISFSI Demolition 2050 - 12,071 63,258 75,328

& Final Site Restoration 2051 - 5,804 68,532 74,336 Total $ 948,906 $ 701,836 $ 705,892 $ 2,356,634

%

San Onofre Nuclear Generating Station Units 2&3 2017 Decommissioning Cost Estimate Appendix (

6KDUH2I/LDELOLW\)RU621*63DUWLFLSDQWV

%

Appendix E Share Of Liability For SONGS ParticipanWV Cost Categories SDG&E Riverside Anaheim SCE SONGS 1 20% 0% 0% 80%

SONGS 2 20% 1.79% 2.4737% 75.7363%

SONGS 3 20% 1.79% 2.4625% 75.4775%

Common Facilities (Units 2 & 3) 20% 1.79% 2.4681% 75.7419%

SONGS 1 Fuel 20% 0% 0% 80%

SONGS 2/3 Fuel 20% 1.79% 2.3398% 75.8702%

ISFSI Maintenance and D&D 20% 1.6066% 2.2686% 76.1248%

San Diego Switchyard 100% 0% 0% 0%

Edison Switchyard 0% 0% 0% 100%

Interconnection Facilities 50% 0% 0% 50%

Nuclear Fuel Cancellation Charges 20% 1.79% 0% 78.21%

Note:

SDG&E, Riverside, and Anaheim incur additional costs related to oversight activities that are not included in the 2017 DCE.

%

Appendix C Reconciliation - Confidential

Appendix D Declaration of Todd R. Adler Regarding the Confidentiality of Certain Data

1 SCEs 2018 NUCLEAR DECOMMISSIONING COST TRIENNIAL PROCEEDING 2 DECLARATION OF TODD R. ADLER 3 REGARDING THE CONFIDENTIALITY OF CERTAIN DATA 4

5 I, Todd R. Adler, declare and state:

6 1. I am employed by Southern California Edison (SCE) as a Principal Manager for Nuclear 7 Projects Management, San Onofre Nuclear Generating Station (SONGS). In my position as Principal 8 Manager, I have responsibility regarding the Decommissioning General Contractor (DGC) 9 Agreement between SCE, EnergySolutions Services, Inc. (EnergySolutions), and AECOM Energy &

10 Construction, Inc. (AECOM), dated December 20, 2016 (DGC Agreement). EnergySolutions and 11 AECOM formed a joint venture known as SONGS DecommissioningSolutions (SDS). I also am 12 familiar with the Independent Spent Fuel Storage Installation (ISFSI) Agreement between SCE and 13 Holtec International (ISFSI Agreement), dated December 5, 2015. I had responsibility for overseeing 14 and reviewing Exhibits SCE-03 and SCE-05, which contain certain confidential information 15 pertaining to the DGC Agreement and ISFSI Agreement. Thomas J. Palmisano, Vice President of 16 SONGS Decommissioning and Chief Nuclear Officer, delegated authority to me to sign this 17 declaration regarding the confidentiality of this information, as described below.

18 2. I am making this declaration in accordance with the instructions set forth in Decision 16-19 08-024 and Decision 17-09-023 of R. 14-11-001, which were issued August 25, 2016, and September 20 28, 2017, respectively, and govern the submission of confidential documents to the Commission.

21 3. I have personal knowledge of the facts and representations herein and, if called upon to 22 testify, could and would do so, except for those facts expressly stated to be based upon information 23 and belief, and as to those matters, I believe them to be true.

24 4. Listed below are the data for which SCE is seeking confidential protection and the basis 25 for SCEs confidentiality request. Paragraphs 5-10 also provide additional reasons supporting SCEs 26 confidentiality claim.

D-1

Location of Basis for SCEs Pages Description of Information Confidential Confidentiality (if available) that is Confidential Data Claim Exhibit SCE-03 8, 14, 20-21, 37-38 1. DGC Agreement California Gov.

contract terms, including Code § 6255 (the Appendix B, DCE, decommissioning plans and public interest pp. B-9, 18-19, 21, pricing terms contained served by not 23, 34-35, 45-47, 49, therein. disclosing the 60-63, 65, 68-72, 74, 2. Contingency and cost- information is

77. estimating information clearly outweighed pertaining to the DGC by the public Appendix C, p. C-1. Agreement and ISFSI interest served by Agreement. disclosure of the record).

Exhibit SCE-05 34 1. DGC Agreement California Gov.

contract terms, including Code § 6255 (the decommissioning plans and public interest pricing terms contained served by not therein. disclosing the information is clearly outweighed by the public interest served by disclosure of the record).

1 5. Both the DGC Agreement and ISFSI Agreement require SCE to make reasonable efforts 2 to protect the confidentiality of the terms and conditions in the agreements. The agreements require 3 confidentiality because they contain commercially sensitive pricing terms and proprietary 4 information, such as work sequencing and scope. If this information was publicly disclosed without 5 protection, competitors, including potential vendors for decommissioning sub-contract work and 6 other activities, could mis-use the information to the detriment of SCEs customers. For example, if 7 a vendor seeking to bid on a subcontract or another activity knew the DGC Agreement or ISFSI 8 Agreement pricing terms, the vendor would have an opportunity to adjust its bid prices (e.g., the 9 vendor could bid higher than it otherwise may have bid).

10 6. Public release of this information could also hinder SCEs ability to obtain favorable 11 contract terms for related decommissioning work not covered under the DGC Agreement and ISFSI 12 Agreement. For example, if a vendor (who SCE has not yet contracted with for SONGS 13 decommissioning) was aware of various terms in the DGC Agreement and ISFSI Agreement, the D-2

1 vendor could mis-use this information during contract negotiations to extract terms favorable to the 2 vendor that the vendor may not have otherwise sought.

3 7. Finally, it is also in the best interest of the long-term success of the SONGS 4 decommissioning project that SDS and Holtec remain commercially competitive throughout the 5 terms of the DGC Agreement and ISFSI Agreement, respectively. Both agreements are long-term 6 agreements that will require SDS and Holtecs continued performance for the next decade and 7 beyond. If information regarding the agreements was disclosed without protection, their competitors 8 could mis-use the information against them during the bidding process for other decommissioning 9 projects across the world and potentially threaten the financial health of both companies. This in 10 turn could threaten the companies ability to complete contractually required services for SONGS in 11 the future without interruption.

12 8. The other category of information that SCE seeks to maintain as confidential is 13 contingency. SCE has applied various contingency amounts on the remaining decommissioning 14 work identified in the 2017 SONGS 2&3 decommissioning cost estimate (DCE) submitted in this 15 proceeding, including work to be completed under the DGC Agreement and ISFSI Agreement.

16 The contingency reflects SCEs judgment of potential costs, based on the technical complexity, 17 contracting status, estimating approach, and timing, of the remaining work scope. It is in SCE 18 customers interest for contingency included for the DGC Agreement and ISFSI Agreement to be 19 protected as confidential, because the disclosure of the information without protection could allow 20 vendors to mis-use the information to the detriment of SCEs customers. For example, if a vendor 21 (including SDS, Holtec, or one of their competitors) knew the contingency SCE has applied in the 22 2017 DCE to work to be completed under the DGC Agreement and ISFSI Agreement, the vendor 23 would have an opportunity to manipulate its negotiating strategy pertaining to new contracts and/or 24 change orders regarding that work (e.g., the vendor could demand higher prices than it otherwise 25 would have demanded).

D-3

1 9. The confidential information identified in Paragraph 4 cannot be provided in a form that 2 can be further aggregated, redacted, summarized, masked, or otherwise protected in a manner that 3 would allow partial disclosure of the data while protecting confidential information.

4 10. For the reasons described above, the confidential information should be protected from 5 public disclosure. Information regarding the DGC Agreement and ISFSI Agreement, including the 6 pricing terms of those agreements and contingency SCE applied in the 2017 DCE for work 7 remaining under those agreements, is market sensitive information that should remain confidential 8 under GO-66-C Section 2.2(b) (unfair business advantage) and GO 66-C Section 2.8 9 (Information obtained in confidence from other than a business regulated by this Commission 10 where the disclosure would be against the public interest).

11 I declare under penalty of perjury under the laws of the State of California that the foregoing 12 is true and correct.

13 Executed on March 13, 2018 at San Onofre Nuclear Generating Station, near San Clemente, 14 California.

15 /s/ Todd R. Adler 16 Todd R. Adler D-4

Appendix E SONGS Mesa Lease and Station Easement Boundaries

SONGS Mesa Lease and Station Easement Boundaries Parcel 5 Parcel 6 Parcel 7 Parcels 8 and 9 Plant Site 0 0.05 0.1 0.2 I Miles 1 in = 0.1 miles Date: 3/12/2018 File Name: SONGS_ParcelMap_bw.mxd Version #: 03 Created By: E. Garcia Real Properties Geospatial Analysis Features depicted herein are planning level accuracy, and intended for informational purposes only.

Distances and locations may be distorted at this scale. Always consult with the proper legal documents or agencies regarding such features. Real Properties Department Thomas Bros. Maps is a registered trademark of Rand McNally & Company.

Reproduced with permission granted by Rand McNally & Company. © Rand McNally & Company.

All rights reserved.

Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus Path: P:\Data\DataConfidential\SONGS\MiscMaps\20150203_EasementMaps\SONGS_ParcelMap_bw.mxd

(

Al Bates Manager, Regulatory Affairs &

Oversight An EDISON INTERNATIONALC!.' Compll.lly 10 CFR 50.82 10 CFR 72.30 March 20, 2018 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D. C. 20555-0001

Subject:

Docket Nos. 50-206, 50-361, 50-362, and 72-41 10 CFR 50.82(a){8)(v-vii) and 10 CFR 72.30(c)

Decommissioning Funding Status Report San Onofre Nuclear Generating Station Units 1, 2, and 3 and Independent Spent Fuel Storage Installation

Dear Sir or Madam:

As required by 10 CFR 50.82(a)(8)(v), 10 CFR 50.82(a)(8)(vii), and 10 CFR 72.30(c), this letter provides the status of the decommissioning funding for San Onofre Nuclear Generating Station (San Onofre) Units 1, 2, and 3 and the San Onofre Independent Spent Fuel Storage Installation (ISFSI) as of December 31, 2017 Based on the requirements in 10 CFR 50.82(a)(8)(v) and 10 CFR 50.82(a)(8)(vii), this information is reported on an annual basis for SONGS Units 1, 2, and 3 because the units were permanently shut down and site-specific decommissioning cost estimates (DCEs)have been submitted for each of these units. In addition, based on the requirements in 10 CFR 72.30(c),

information demonstrating the adequacy of funding for the San Onofre ISFSI is reported at intervals not to exceed three years, and is included. The required information for Southern California Edison, San Diego Gas & Electric, the City of Anaheim, and the City of Riverside is provided in the Enclosure.

There are no commitments contained in this letter or its enclosure.

If you have any questions regarding this matter, please contact me at (949) 368-6945.

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Enclosure:

San Onofre Nuclear Generating Station Units 1, 2, and 3 and ISFSI Decommissioning Funding Status Report for Calendar Year 2017 cc: K. Kennedy, Regional Administrator, NRC Region IV M. G. Vaaler, NRC Project Manager, San Onofre Units 1, 2, and 3 W. C. Allen, NRC Project Manager, San Onofre ISFSI

Enclosure San Onofre Nuclear Generating Station Units 1, 2, and 3 and Independent Spent Fuel Storage Installation (ISFSI)

Decommissioning Funding Status Report for Calendar Year 2017

San Onofre Nuclear Generating Station Units 1, 2, and 3 and Independent Spent Fuel Storage Installation (ISFSI)

Decommissioning Funding Status Report For Calendar Year 2017 San Onofre Unit 1 was a pressurized water reactor (PWR) rated at 1347 MWt. San Onofre Units 2 and 3 were pressurized water reactors (PWR) rated at 3438 MWt.

Provided below is the information required by 10 CFR 50.82(a)(8)(v) and (vii) for San Onofre Units 1, 2, and 3; and the information required by 10 CFR 72.30(b) for the San Onofre ISFSI. This information is reported every year for San Onofre Units 1, 2, and 3 because site-specific decommissioning cost estimates (DCEs) have been submitted for them and they are currently being decommissioned.

The San Onofre ISFSI is located on the partially decommissioned site of San Onofre Unit 1, and is operated under a 10 CFR 72 General License issued to the holders of a 10 CFR 50 license.

The SONGS Unit 1 co-owners are reported as follows:

Southern California Edison (SCE) 80.00 %

San Diego Gas & Electric (SDG&E) 20.00 %

100.00 %

The San Onofre Units 2 and 3 co-owners are reported as follows:

Southern California Edison (SCE) 78.21 %

San Diego Gas & Electric (SDG&E) 20.00 %

City of Anaheim (Anaheim) 0.00 %

City of Riverside (Riverside) 1.79 %

The decommissioning liability is shared between the current owners and former owner, Anaheim, as set forth below for each unit:

Unit 1 Unit 2 Unit 3 Owner Decommissioning Decommissioning Decommissioning Liabilit Liabilit Liability SCE 80.00% 75.7363% 75.7475%

SDG&E 20.00% 20.0000% 20.0000%

Anaheim 0.00% 2.4737% 2.4625%

Riverside 0.00% 1.7900% 1.7900%

All dollar amounts are in 100% share, 2017 dollars.

1) The estimated costs to decommission San Onofre Units 1, 2, and 3, and the San Onofre ISFSI, including all decommissioning and spent fuel storage costs estimated to be required pursuant to 10 CFR 50.75(b) and (c); 10 CFR 50.54(bb);

and 10 CFR 72.30(b) are shown below:

The site-specific estimates for decommissioning include the following radiological decommissioning costs associated with terminating the site license pursuant to 10 CFR 50. 75(b ); non-radiological site restoration costs; spent fuel storage costs pursuant to 10 CFR 50.54(bb ); and ISFSI decommissioning costs pursuant to 10 CFR 72.30(b):

San Onofre Unit 1(1>

Estimate of License Termination Costs $ 76.8 million Less: Lie. Term. Costs during 2017 $ 1.3 million "To Go" License Termination Costs $ 75.5 million Estimate of Site Restoration Costs $ 92.6 million Less: Site Restor. Costs during 2017 $ 0.3 million "To Go" Site Restoration Costs $ 92.3 million Estimate of Fuel Storage Costs $ 46.0 million Less: Fuel Storage Costs during 2017 $ 0.4 million "To Go" Fuel Storage Costs $ 45.6 million Estimate of ISFSI Decommissioning Costs $ 5.3 million Total Unit 1 "To Go" Costs as of 1/1/2018 $ 218.7 million San Onofre Unit 2(2>

Estimate of License Termination Costs $1,017.0 million Less: Lie. Term. Costs through 12/31/2017 $ 305.2 million "To Go" License Termination Costs $ 711.8 million Estimate of Site Restoration Costs $ 527.8 million Less: Site Restor. Costs through 12/31/2017 $ 90.5 million "To Go" Site Restoration Costs $ 437.3 million Estimate of Fuel Storage Costs $ 687.0 million Less: Fuel Storage Costs through 12/31/2017 $ 259.0 million "To Go" Fuel Storage Costs $ 428.0 million Estimate of ISFSI Decommissioning Costs $ 18.9 million Total Unit 2 "To Go" Costs as of 1/1/2018 $1,596.0 million

San Onofre Unit 3(2)

Estimate of License Termination Costs $1,007.5 million Less: LiG. Term. Costs through 12/31/2017 $ 302.5 million "To Go" License Termination Costs $ 705.0 million Estimate of Site Restoration Costs $ 7 46.6 million Less: Site Restor. Costs through 12/31/2017 $ 102.2 million "To Go" Site Restoration Costs $ 644.4 million Estimate of Fuel Storage Costs $ 724.6 million Less: Fuel Storage Costs through 12/31/2017 $ 254.7 million "To Go" Fuel Storage Costs $ 469.9 million Estimate of ISFSI Decommissioning Costs $ 18.9 million Total Unit 3 "To Go" Costs as of 1/1/2018 $1,838.2 million The site-specific decommissioning cost estimates for San Onofre Units 1, 2, and 3 and the San Onofre ISFSI include: (1) the cost to perform all decommissioning activities; (2) the cost of meeting the 10 CFR 20.1402 radiological criteria for unrestricted site use; and (3) adequate contingency factors for all costs.

2) Each San Onofre co-owner has established one or more external sinking trust fund accounts as provided in 10 CFR 50.75(e)(1 )(ii) for their respective shares of the San Onofre Units 1, 2, and 3 decommissioning obligation, which also includes the San Onofre ISFSI. The Decommissioning Trust Fund amounts remaining at the end of calendar year 2017 (net of pending Trust Fund withdrawals and estimated capital gains taxes) are:(3)( 4)(5 )

Co-Owner San Onofre Unit 1 San Onofre Unit 2 San Onofre Unit 3 SCE $ 303.5 million $ 1, 180.4 million $ 1,370.9 million SDG&E (5) $ 150.5 million $ 357.5 million $ 412.5 million Anaheim (5) N/A $ 52.2 million $ 52.2 million Riverside (5) N/A $ 27.9 million $ 30.8 million TOTAL $ 454.0 million $ 1,618.0 million $ 1,866.4 million

3) Each San Onofre co-owner deposits its decommissioning fund contributions into their respective external sinking fund accounts as provided in 10 CFR 50.75(e)(1)(ii). The annual amounts projected to be collected in 2018 are:

Co-Owner San Onofre Unit 1 San Onofre Unit 2 San Onofre Unit 3 SCE $ 0.0 million $ 0.0 million $ 0.0 million SDG&E (5) $ 0.0 million $ 0.0 million $ 0.0 million Anaheim (5) N/A $ 0.0 million $ 0.0 million Riverside (5) N/A $ 0.0 million $ 0.0 million TOTAL $ 0.0 million $ 0.0 million $ 0.0 million

4) The amounts spent on San Onofre Units 1, 2, and 3 decommissioning work performed during 2017 are summarized below:

Cost Category San Onofre Unit 1 San Onofre Unit 2 San Onofre Unit 3 License Term. $ 1.5 million $ 91. 7 million $ 88.9 million Site Restoration $ 0.9 million $ 5.5 million $ 11.3 million Spent Fuel Storage $ 0.6 million $ 52.3 million $ 53.3 million ISFSI Decom. $ 0.0 million $ 0.0 million $ 0.0 million TOTAL $ 3.0 million $ 149.5 million $ 153.5 million

5) The composite escalation rate and after tax investment rates of return for San Onofre Units 1, 2, and 3 Decommissioning are summarized below:

Composite Rate San Onofre Unit 1 San Onofre Unit 2 San Onofre Unit 3 Rate of Return 3.17% 3.32% 3.32%

Escalation 2.69% 2.91% 2.91%

Real Earnings Rate 0.48% 0.41% 0.41%

The composite investment rates of return less the composite escalation rates yield composite real earnings rates less than the 2% real rate of return allowed under 10 CFR 50.75(e)(1)(ii).

6) None of the co-owners of San Onofre Units 1, 2, and 3 or the San Onofre ISFSI is relying on any contracts for the purposes of providing decommissioning funding pursuant to 10 CFR 50. 75(e)(1 )(v). There have been no modifications to the method of providing financial assurance.

7) The amounts of decommissioning funds available as of December 31, 2017 for San Onofre Units 1, 2, and 3 License Termination, Site Restoration, Spent (Irradiated) Fuel Management, and ISFSI Decommissioning costs are shown in the tables below:(4)

Estimated "To Go" Cost 12/31/2017 San Onofre Unit 1 Decommissioning Ratios Net Trust Balance Cost License Termination Costs $ 75.5 million 34.5% $ 156.7 million Site Restoration Costs $ 92.3 million 42.2% $ 191. 7 million Spent Fuel Management Costs $ 45.6 million 20.8% $ 94.6 million ISFSI Decommissioning Costs $ 5.3 million 2.4% $ 11.0 million TOTAL $ 218.7 million 100.0% $ 454.0 million