ML14269A034

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Site Specific Decommissioning Cost Estimate
ML14269A034
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 09/23/2014
From: Thomas J. Palmisano
Southern California Edison Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML14269A034 (93)


Text

SOUTHERN CALIFORNIA Thomas I. Palmisano EDISON" Vice President & Chief Nuclear Officer An EDISON INT-RNA DOINAL I Company 10 CFR 50.82(a)(4)(i)

September 23, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington D.C. 20555-0001

Subject:

Docket Nos. 50-361 and 50-362, San Onofre Nuclear Generating Station, Units 2 and 3 Site Specific Decommissioning Cost Estimate

References:

1. Letter from P. T. Dietrich (SCE) to the U.S. Nuclear Regulatory Commission dated June 12, 2013;

Subject:

Certification of Permanent Cessation of Power Operations San Onofre Nuclear Generating Station, Units 2 and 3

2. Letter from Thomas J. Palmisano (SCE) to the U.S. Nuclear Regulatory Commission dated February 13, 2014;

Subject:

Access to Nuclear Decommissioning Trust Funds, San Onofre Nuclear Station, Units 2 and 3

3. Letter from Richard C. Brabec (SCE) to the U.S. Nuclear Regulatory Commission dated March 12, 2014;

Subject:

Access to Decommissioning Trust Funds, San Onofre Nuclear Generating Station Units 2 and 3

4. Letter from Richard C. Brabec (SCE) to the U.S. Nuclear Regulatory Commission dated March 31, 2014;

Subject:

10 CFR 50.75(f)(1)

Decommissioning Funding Status Report, San Onofre Nuclear Generating Station Units 2 and 3

Dear Sir or Madam:

On June 12, 2013, in accordance with 10 CFR 50.82(a)(1)(i), Southern California Edison (SCE) submitted a letter to the U.S. Nuclear Regulatory Commission (NRC) (Reference 1) certifying the permanent cessation of operations at San Onofre Nuclear Generating Station (SONGS),

Units 2 and 3. In accordance with 10 CFR 50.54(bb) and 10 CFR 50.82(a)(4)(i), SCE is required to submit an Irradiated Fuel Management Plan (IFMP), Site Specific Decommissioning Cost Estimate (DCE) and Post-Shutdown Decommissioning Activities Report (PSDAR) within two years of permanent cessation of operations.

The SONGS, Units 2 and 3 DCE is attached. The SONGS, Units 2 and 3 IFMP and PSDAR are being concurrently submitted under separate cover letters. The DCE provides more current estimates of annual cash flow than were previously provided in the Nuclear Decommissioning Trust Fund Exemption Request (References 2 and 3) and annual funding assurance update (Reference 4). Future filings with the California Public Utilities Commission will be based on the SONGS, Units 2 and 3 DCE and subsequent revisions.

P.O. Box 128 San Clemente, CA 92672 (949) 368-6575 PAX 86575 Fax: (949) 368-6183 Tom. Pahnisano@sce.com

The descriptions of decommissioning activities and phases in the DCE are consistent with those described in the PSDAR. Both the DCE and PSDAR represent SCE's current plans and are subject to change as the project progresses. Much of the third-party contracting activities associated with decommissioning are underway but have not been finalized. As contracts are finalized and SCE progresses through the actual work of the decommissioning project, various risks will be realized or avoided and contingencies adjusted, accordingly.

Changes to significant details will be included in subsequent revisions to the DCE as required by 10 CFR 50.54(bb). Financial assurance information will be provided on an annual basis as required by 10 CFR 50.75(f)(1).

This letter does not contain any new commitments.

If there are any questions or if additional information is needed, please contact me or Ms. Andrea Sterdis at (949) 368-9985.

Sincerely,

Enclosure:

San Onofre Nuclear Generating Station Units 2 and 3 Site Specific Decommissioning Cost Estimate cc: M. L. Dapas, Regional Administrator, NRC Region IV T. J. Wengert, NRC Project Manager, San Onofre Units 2 and 3 Decommissioning R. E. Lantz, NRC Region IV, San Onofre Units 2 and 3 G. G. Warrick, NRC Senior Resident Inspector, San Onofre Units 2 and 3 S. Y. Hsu, California Department of Health Services, Radiologic Health Branch 2

ENERGYSOLUTIONS Document No. 164001-DCE-001 2014 Decommissioning Cost Analysis of the San Onofre Nuclear Generating Station Units 2 & 3 Project No. 164001 Rev 1 Prepared for:

Southern California Edison.

2244 Walnut Grove Avenue Rosemead, CA 91770 Prepared by:

EnergySolutions, LLC 100 Mill Plain Road Mailbox No. 106 Danbury, CT 06811 Authored By: September 5, 2014 Michael S. Williams, Project Manager Date Reviewed By: September 5, 2014 Barry S. Sims, Technical Advisor Date Approved By A-Md .'

Michael S. Williams, Project Manager September 5, 2014 Date New Report HTitle Change

[ Report Revision

]Report Rewrite Effective Sept 5, 2014 Date Electronic documents, once printed, are uncontrolled and may become outdated.

Refer to Document Control authority for the correct revision.

SONGS UNIT-2 AND UNIT-3 DECOMMISSIONING COST ESTIMATE DESCRIPTION OF REVISION MAJOR REVISION MINOR REVISION X REVISION NUMBER - 1 EFFECTIVE DATE 9/5/2014 The revisions contained in this MINOR REVISION to the SONGS Unit-2 and Unit-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 A new Appendix-F is added to the DCE at the request of San Diego Gas & Electric Company (SDG&E) in order to provide information regarding its internal decommissioning costs which it expects to incur and to fund on its own behalf in addition to its 20% share of the Decommissioning Cost Estimate.

ITEM-2 The APPENDICES section of the DCE Table of Contents is revised to include the new APPENDIX-F SDG&E SONGS Decommissioning Costs (100%)

ITEM-3 Within the narrative section of the DCE the various appearances of the term "utility staff' have been revised to include a parenthetic statement "(Licensee)" to clarify that the utility staff means the NRC Licensee.

ITEM-4 On Table 6-1 "Cost and Schedule Summary" the title block for SPENT FUEL is revised to include "(72.30)" since this section also contains cost elements associated with ISFSI decommissioning.

ITEM-5 Added new SDG&E footnote for Table 1-1 referring to Appendix F Electronic documents, once printed, are uncontrolled and may become outdated.

Refer to Document Control authority for the correct revision.

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 TABLE OF CONTENTS Section Page 1.0 EXECUTIVE

SUMMARY

........................................................................................... 5

2.0 INTRODUCTION

......................................................................................................... 8 2.1 Study Objective ................................................................................................... 8 2.2 Regulatory Framework .................................................................................... 10 3.0 STUDY METHODOLOGY ......................................................................................... 12 3.1 General Description ......................................................................................... 12 3.2 Schedule Analysis .............................................................................................. 12 3.3 Decommissioning Staff ..................................................................................... 13 3.4 W aste Disposal ................................................................................................... 13 3.5 Final Status Survey ........................................................................................... 16 3.6 Contingency ....................................................................................................... 16 3.7 Cost Reporting .................................................................................................. 17 4.0 SITE SPECIFIC TECHNICAL APPROACH ............................................................... 18 4.1 Facility Description ............................................................................................ 18 4.2 Decommissioning Periods ............................................................................... 18 4.3 Decommissioning Staff .................................................................................... 21 4.4 Spent Fuel M anagement Staff ........................................................................ 21 4.5 Spent Fuel Shipments ...................................................................................... 22 5.0 BASES OF ESTIM ATE AND KEY ASSUM PTIONS .............................................. 23 6.0 STUDY RESULTS ....................................................................................................... 28

7.0 REFERENCES

................................................................................................................. 37 FIGURES Figure 1-1 Summary Schedule ......................................................................................... 7 Figure 6-1 Summ ary Schedule ......................................................................................... 31 TABLES Table 1-1 Decommissioning Cost Summ ary ....................................................................... 6 Table 6-1 Cost and Schedule Summary ........................................................................... 32 Table 6-2 Utility Staff Levels ....................................................................................... 33 Table 6-3 DGC Staff Levels ................................. ..... .... 34 Table 6-4 W aste Disposal Volumes .................................................................................. 35 Page 2 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 APPENDICES Appendix A List of Systems and Structures Appendix B Spent Fuel Shipping Schedule Appendix C Detailed Project Schedule Appendix D Detailed Cost Table Appendix E Annual Cash Flow Table Appendix F SDG&E SONGS Decommissioning Costs (100%)

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2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 ACRONYMS AND ABBREVIATIONS AHSM Advanced Horizontal Storage Modules AIF Atomic Industrial Forum ALARA As Low As Reasonably Achievable ARO Asset Retirement Obligation CFR Code of Federal Regulations CPM Critical Path Method DAW Dry Active Waste DGC Decommissioning General Contractor DOE U.S. Department of Energy DSC Dry Shielded Canister ESS Essential System FEMA Federal Emergency Management Agency FSS Final Status Survey FTE Full Time Equivalent GSA U.S. General Services Administration GTCC Greater Than Class C HP Health Physics ISFSI Independent Spent Fuel Storage Installation LLRW Low-Level Radioactive Waste LLW Low Level Waste LLWPA Low-Level Waste Policy Act LOP Life-of-Plant MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MPC Multi-Purpose Canister MWt Megawatt thermal NON Non-Essential System NRC Nuclear Regulatory Commission NSSS Nuclear Steam Supply System ORISE Oak Ridge Institute for Science and Education PCB Polychlorinated Biphenyl PGE Pacific Gas & Electric PSDAR Post-Shutdown Decommissioning Activities Report PWR Pressurized Water Reactor RIF Reduction In Force SCE Southern California Edison SONGS San Onofre Nuclear Generating Station STRUCT Structure TCEQ Texas Commission on Environmental Quality WBS Work Breakdown Structure WCS Waste Control Specialists LLC UCF Unit Cost Factor Page 4 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 1.0 EXECUTIVE

SUMMARY

This report presents the 2014 Decommissioning Cost Estimate (DCE) Study of the San Onofre Nuclear Generating Station (SONGS) Units 2 & 3, hereinafter referred to as the 2014 Cost Study. The San Onofre Nuclear Generating Station is operated by the Southern California Edison Company (SCE).

On June 7, 2013, SCE announced its intention to permanently cease power generation operations and shut down SONGS Units 2 & 3. Units 2 & 3 had not produced power since January 9, 2012 and January 31, 2012, respectively. SCE now has the responsibility to decommission the site. In January 2014 SCE contracted with 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 CFR 50.82(a)(4)(i), which requires that a PSDAR be submitted within two years following the permanent cessation of operations.

This study has been performed to furnish an estimate of the costs for: (1) decommissioning SONGS Units 2 & 3 to the extent required to terminate the plant's operating license pursuant to 10 CFR 50.75(c); (2) post-shutdown management of spent fuel until acceptance by the U.S.

Department of Energy (DOE) pursuant to 10 CFR 50.54(bb); (3) demolition of uncontaminated structures and restoration of the site in accordance with the United States Department of Navy Grant of Easement (Ref. No. 14); and the California State Lands Commission Easement Lease (Ref. No. 15); and (4) Independent Spent Fuel Storage Installation (ISFSI) decommissioning pursuant to 10 CFR 72.30. This study includes SCE's actual costs incurred in the transitional periods following cessation of permanent operations on June 7, 2013 until December 31, 2013.

Costs presented herein commencing on January 1, 2014 are estimated.

SCE's December 2012 testimony to the CPUC provided the basis for the current spent fuel management costs. SCE is continuing to review available information from the DOE to determine if the DOE start date assumption of 2024 requires updating. The DCE will be revised accordingly as new information becomes available.

Accordingly, the costs and schedules for all activities are segregated for regulatory purposes as follows: costs for "License Termination" (10 CFR 50.75(c)); costs for "Spent Fuel Management" (10 CFR 50.54(bb)); costs for "Site Restoration" (clean removal and site restoration) final site conditions; and costs for "ISFSI Decommissioning" (10 CFR 72.30). EnergySolutions has established a Work Breakdown Structure (WBS) and cost accounting system to differentiate between these project accounts.

This study analyzes the following technical approach to decommissioning as defined by SCE:

" DECON methodology.

" Permanent cessation of operations on June 7, 2013.

" Termination of spent fuel pool operation six years after permanent shutdown.

" Spent fuel will be stored in Multi-Purpose Canisters (MPCs) at an on-site Independent Spent Fuel Storage Installation (ISFSI).

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2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3

" A dry transfer facility will not be necessary for transfer of SNF canisters for transport.

" DOE begins accepting spent fuel from the industry in 2024 and completes the removal of all SONGS spent fuel by 2049.

" Decommissioning will be performed by a Decommissioning General Contractor (DGC) with oversight by the SONGS participants.

" Incorporation of Life-of-Plant (LOP) Disposal Rates for Class A Low-Level Radioactive Waste (LLRW).

" Incorporation of disposal rates for Class B and C LLRW based on recent quotes for disposal at the Waste Control Specialists LLC (WCS) site in Andrews County, Texas.

The cost estimate results are provided in Table 1-1. Table 1-1 gives License Termination costs (which correspond to 10 CFR 50.75 (c) requirements); Spent Fuel Management costs (which correspond to 10 CFR 50.54 (bb) requirements); and Site Restoration costs (which correspond to activities such as clean building demolition and site grading and end-state preparation as required under the Site Easement).

Table 1-1 Decommissioning Cost Summary12 (2014 Dollars in Thousands)

License Termination 50.75(c) $1,034,230 $1,078,016 $2,112,246 Spent Fuel Management 50.54(bb) $623,209 $652,987 $1,276,196 Site Restoration $423,297 $599,507 $1,022,804 Totals $2,080,735 $2,330,511 $4,411,246 The estimate is based on site-specific plant systems and buildings inventories. These inventories, and EnergySolutions' proprietary Unit Cost Factors (UCFs), were used to generate required manhours, activity schedule hours and costs, and waste volume, weight, and classification. Based on the activity schedule hours and a decommissioning activities analysis, a Critical Path Method (CPM) analysis was performed to determine the decommissioning schedules. These schedules reflect the effects of sequenced activity-dependent or distributed decommissioning elements such as planning and preparations, major component removal, building decontamination, and spent fuel shipping. The schedules are divided into project phases (periods) and presented, as noted previously, by cost account "License Termination," "Spent Fuel Management," or "Site Restoration." The summary is shown in Figure 1-1, and may also be found in Section 6.0 of this report.

In addition, the Decommissioning Cost Summary in Table 1-1 does not include separate internal costs that San Diego Gas & Electric Company (SDG&E) has indicated that it expects to incur. SDG&E provides information regarding these costs in Appendix F 2 Rows and columns may not add correctly due to rounding.

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2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 Figure 1-1 Summary Schedule DECON with Dry Storage, 2013 Shutdown and DOE Acceptance in 2024 Tad, Namo PotSitonSp"n Fuel If Spam Fuel 51*1*1n Complete -Unit I Spam Fuel Si*V Co._mpls -Units 2 &3 ggemen I I~ slo  :

VU7l1M3 I ih W'201 1MO1M204. t1;31/2049 t12 1314 161&1715 If 110111 1121121141151161171t5115ue1i2l1223fMl4251a27128ue20121 3l2aI32I3I5l2I72I41

  • IW31 SNF Pd 1-Spent Fuel Manegenunt Transition o0w7r014 12r2112012 SNF Pd 2-Spen Fuel Tremelar to Dry Stwap 1711014 0&ii2Dt* *i MMMMW SNF Pd 3- Dry SWtrage During Decommissioning- Units 1, 2 and $ 064O1I201/ 121gt2*J0 1W SUF Pd 4.Dry Sto*pg Only- Units 1,2 ad 2 12/06=t 1212211M SNF Pd 5 -Dry Stamg 01* - Units 2 mnd 2 m2 =o1 12s21/049 ------------

SNF D&D PdI -FSI DAD Planning n fldar.. prnJ m.an gwune£- RWM uMW n ..

1211/2049 06/W20I

-vJl I~teqr- qP aRtSo License Termination 06107/2 i'2~N=

MA O[ *q*lEil*[*rl *1 *Jl*e*lIKPflS IJtalg Im*lJJ Deeon Pd 1 - Transition to Nouniesionifg 0610712012 12t1/2012 Decon Pd 2. Decomnissioning Plmnning an Sias Modiclions WM II2II4 1 5MS Deom Pd 2-Decommisaioning Proeration and Reacko InwnlsSegmentation o 12inoms o60&M1 YMM Deco Pd 4- Plant Systems and Lanp Component Removal 04111J 011241=21 Decan Pd 5- BuddingDo ion 0WMJA4M 0WIM 41 l a 1 i"It .

Il. 7 It..J . *OS-t Sits Reatoration - 067r201l2

  • 1.1...2..1 SR Pd i - Transition to Simt Re.t.a*_ion - 061O71201" -l SR Pd 2. Bu&&V Demolition Dufg Decomam*sion t 06o MS 071111201?

SR Pd 3. Si&awfa Oe nmolidan Enginsing anld Pem"n 1010=9 071212*24 SR Pd 4- Buiding Demolilion to S Feet Below Grae o7n6120124 1t412026 SR Pd e. Final Sit Reslomrion and Lease Teneuintion W0*06120 12W/16061 Fmal Easo*mo Tanmnatc i2'fIS11 12115I1201 121 Page 7 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3

2.0 INTRODUCTION

2.1 Study Objective This report presents the 2014 Decommissioning Cost Estimate Study of the San Onofre Nuclear Generating Station (SONGS) Units 2 & 3, hereinafter referred to as the 2014 Cost Study. The San Onofre Nuclear Generating Station is owned by the Southern California Edison Company (SCE), San Diego Gas & Electric Company, and the City of Riverside. A former owner, the City of Anaheim, also has liability for decommissioning. SCE has provided the following information regarding the liability by owner for SONGS decommissioning costs:

Cost Categories Owners 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% 75.7475%

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 Maintenanceand 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%

This study has been performed to support the development of a site-specific PSDAR and furnish an estimate of the costs for (1) decommissioning SONGS Units 2 & 3 to the extent required to terminate the plant's operating license, (2) post-shutdown management of spent fuel until acceptance by the U.S. Department of Energy (DOE), (3) demolition of uncontaminated structures and restoration of the site in accordance with the U.S. Department of Navy Grant of Easement (Ref. No. 14), and the California State Lands Commission Easement Lease (Ref. No.

15), and (4) Independent Spent Fuel Storage Installation (ISFSI) decommissioning. This study also includes SCE's actual costs incurred in the transitional periods following cessation of permanent operations until December 31, 2013. Estimated costs begin on January 1, 2014.

The study methodology follows the basic 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," (Ref. No. 2).

The report was prepared in accordance with Nuclear Regulatory Commission (NRC) Regulatory Guide 1.202, "Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors," (Ref. No. 3). The estimate is based on compliance with current regulatory requirements and proven decommissioning technologies.

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2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 NRC requirements, set forth in Title 10 of the Code of Federal Regulations (CFR), differentiate between the post-shutdown costs associated with the decommissioning of the nuclear plant facility, those associated with storage of spent fuel on-site, and those associated with the decommissioning of the spent fuel storage facility. The Code of Federal Regulations, however, does not address the entire scope of the decommissioning liability for each nuclear facility. 10 CFR 50.75(c) requires funding by the licensee(s) of the facility for the decommissioning program, but specifically excludes the cost of removal and disposal of spent fuel and structures that do not require disposal as radioactive material. 10 CFR 50.75(c) also excludes the cost of site restoration activities that do not involve the removal of residual radioactivity necessary to terminate the NRC license(s). 10 CFR 50.54 (bb) requires funding by the licensee(s) "for the management of all irradiated fuel at the reactor upon expiration of the reactor operating license(s) 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." 10 CFR 72.30 requires funding for decommissioning of the on-site spent fuel storage facility after the irradiated fuel is accepted by the DOE.

In addition to the NRC Decommissioning requirements described above, the Site Easements require the demolition and removal of all improvements installed on both the on-shore and off-shore sites, including all substructures regardless of depth, and site restoration to the satisfaction of the Grantors.

This study analyzes the following technical approach to decommissioning as defined by SCE and the co-owners:

" DECON methodology.

" Permanent cessation of operations and commencement of decommissioning planning on June 7, 2013.

" Termination of spent fuel pool operation within six years after permanent shutdown.

" Spent fuel will be stored in transportable Multi-Purpose Canisters (MPCs) at an on-site Independent Spent Fuel Storage Installation (ISFSI).

" A dry transfer facility will not be necessary for transfer of SNF canisters for transport.

" DOE begins accepting spent fuel from the industry in 2024 and completes the removal of all SONGS spent fuel by 2049.

" Decommissioning will be performed by a Decommissioning General Contractor (DGC) with oversight by the SONGS participants.

In addition, this study includes the following assumptions:

" Incorporation of EnergySolutions' Life-of-Plant (LOP) Disposal Rates for Class A Low-Level Radioactive Waste (LLRW), (Ref. No. 7).

" Incorporation of disposal rates for Class B and C LLRW based on recent quotes for disposal at the Waste Control Specialists LLC (WCS) site in Andrews County, Texas.

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2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 2.2 Regulatory Framework Provisions of current laws and regulations affecting decommissioning, waste management, and spent fuel management are as follows:

1. NRC regulations require a license for on-site storage of spent fuel. Wet storage in a spent fuel pool is authorized by a facility's 10 CFR Part 50 license. On-site dry storage of spent fuel at an Independent Spent Fuel Storage Installation (ISFSI) is licensed by either: (a) the general license set forth in 10 CFR 72.210, which requires that a Part 50 license be in place; or (b) a site-specific ISFSI license issued pursuant to 10 CFR Part 72.
2. 10 CFR 50.75(c) requires funding by the licensee(s) of the facility for decommissioning.
3. 10 CFR 50.54 (bb) requires the licensee(s), within two years following permanent cessation of operation of the reactor or five years before expiration of the operating license(s), whichever occurs first, to submit written notification to the NRC for its 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."
4. 10 CFR 961 (Ref. No. 4), Appendix E, requires spent fuel to be cooled for at least five years before it can be accepted by DOE as "standard spent fuel."
5. 10 CFR 72.30 requires funding by the licensee(s) for termination of the ISFSI license.

Decommissioning Alternatives The three basic methods for decommissioning are DECON, SAFSTOR, and ENTOMB, which are summarized as follows:

1. DECON: 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 license after cessation of operations.
2. SAFSTOR: The facility is placed in a safe, stable condition and maintained in that state (safe storage). The facility is decontaminated and dismantled at the end of the storage period to levels that permit license termination. NRC regulations require decommissioning to be completed within 60 years of cessation of operation.
3. ENTOMB: Radioactive structures, systems, and components are encased in a structurally long-lived substance, such as concrete. The entombed structure is appropriately maintained and monitored until radioactivity decays to a level that permits termination of the license. Since entombment will exceed the requirement Page 10 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 for decommissioning to be completed within 60 years of cessation of operation, NRC handles entombment requests on a case-by-case basis.

Post-Shutdown Spent Fuel Management Alternatives The options for long-term post-shutdown spent fuel management currently available to power plant operators are (1) wet storage consisting of continued maintenance and operation of the spent fuel pool, and (2) dry storage consisting of transfer of spent fuel from the fuel pool to on-site. dry storage modules after a cooling period or any combination of the two as is the present case at SONGS. Maintaining the spent fuel pool for an extended duration following cessation of operations prevents termination of the Part 50 license and typically has a higher annual maintenance and operating cost 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 completion of spent fuel transfer to DOE.

The spent fuel shipping schedules furnished by SCE for this study are based on projections that DOE will commence accepting spent fuel from domestic commercial nuclear power plants in 2024, and that the DOE will accept spent fuel at the rate published in DOE's July 2004 Acceptance Priority Ranking & Annual Capacity Report (DOE/RW-0567) (Ref. No. 12). These assumptions are in accordance with SCE testimony to the Public Utilities Commission of the State of California (Ref. No. 17). Additionally, SCE is reviewing available information from the DOE to determine if the DOE start date assumption requires updating. The DCE will be revised accordingly as new information becomes available.

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2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 3.0 STUDY METHODOLOGY 3.1 General Description EnergySolutions maintains a proprietary decommissioning cost model based upon the fundamental technical approach established in AIF/NESP-036, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," dated May 1986 (Ref. No.

2). The cost model has been updated frequently in accordance with regulatory requirements and industry experience. The cost model includes elements for estimating distributed and undistributed costs. Distributed costs are activity specific and include planning and preparation costs as well as costs for decontamination, packaging, disposal, and removal of major components and systems. For example, costs for the segmentation, packaging, and disposal of the reactor internals are distributed costs. Undistributed costs, sometimes referred to as collateral costs, are typically time dependent costs such as utility (Licensee) and decommissioning general contractor staff, property taxes, insurance, regulatory fees and permits, energy costs, and security staff.

The methodology for preparing cost estimates for a selected decommissioning alternative requires development of a site-specific detailed work activity sequence based upon the plant inventory. The activity sequence is used to define the labor, material, equipment, energy resources, and duration required for each activity. In the case of major components, individual work sequence activity analyses are performed based on the physical and radiological characteristics of the component, and the packaging, transportation, and disposal options available.

In the case of structures and small components and equipment such as piping, pumps, and tanks, the work durations and costs are calculated based on UCFs. UCFs are economic parameters developed to express costs per unit of work output, piece of equipment, or time. They are developed using decommissioning experience, information on the latest technology applicable to decommissioning, and engineering judgment. The total cost of a specific decommissioning activity can be determined by multiplying the total number of units associated with that activity by the UCF, expressed as $/unit, for that activity. For example, the estimated demolition cost of a non-contaminated concrete structure can be obtained by multiplying the volume of concrete in the structure by the UCF for non-contaminated reinforced concrete demolition, expressed in

$/unit volume. Each UCF has associated with it a man-hours/unit and schedule-hours/unit.

From these values, total man-hours and total schedule-hours can be estimated for a particular activity.

3.2 Schedule Analysis After the work activity durations are calculated for all distributed activities, a critical path schedule analysis is performed using MS Project. The schedule accounts for constraints such as spent fuel cooling periods and regulatory reviews. The schedule is typically delineated into phases or time periods (hereinafter referred to as period or periods) that differentiate manpower requirements and undistributed costs.

In order to differentiate between License Termination, Spent Fuel, and Site Restoration elements of the entire decommissioning scope of work, EnergySohltions has established a Work Breakdown Structure (WBS) and cost accounting system to treat each element as a subproject.

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2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 Accordingly, the overall project schedule is divided into interrelated periods with major milestones defining the beginning and ending of each period. The major milestones also serve as the basis for integrating the periods of the three subprojects.

3.3 Decommissioning Staff EnergySolutions has assumed that the SONGS Units 2 and 3 decommissioning project will be performed in an efficiently planned and executed manner using project personnel experienced in decommissioning. This DCE assumes that the decommissioning will be performed by a highly experienced and qualified DGC, with oversight and management of the decommissioning operations performed by the Licensee staff. It is also assumed that the Utility (Licensee) staff will be supplemented by a professional consulting engineering firm, particularly in the planning and preparation phase.

EnergySolutions analyzed the SONGS licensee staff and developed a site-specific staffing plan.

The SCE existing salary structure was then used as the basis for calculating Utility (Licensee) staff labor costs. EnergySolutions used industry data to develop DGC salary costs.

Staffing levels, for both staffing plans and for each project period, are based on the Atomic Industrial Forum (AIF) guidelines and industry experience. The sizes of the staffs are varied in each period in accordance with the requirements of the work activities. Staffing has been organized into the following departments or functional groups:

" Decommissioning

" Engineering

" Maintenance and Work Control

" Operations

" Oversight and Nuclear Safety

" Radiation Protection and Chemistry

" Regulatory and Emergency Planning

" Safety and Human Performance

" Security Administration

" Security Guard Force

" Site Management and Administration

" Additional Staff for Spent Fuel Shipping

" DGC Staff 3.4 Waste Disposal Waste management costs comprise a significant portion of the decommissioning cost estimate.

Additionally, limited future access to disposal sites licensed for receipt of Class B and C wastes introduces a significant level of uncertainty with respect to the appropriateness of using existing rate structures to estimate disposal costs of these wastes. EnergySolutions' approach to estimating waste disposal costs is discussed in the following paragraphs.

Waste Classification Regulations governing disposal of radioactive waste are stringent in order to ensure control of the waste and preclude adverse impact on public health and safety. At present, LLRW disposal Page 13 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 is controlled by 10 CFR 61, which went into effect in December 1983. This regulation stipulates the criteria for the establishment and operation of shallow-land LLRW burial facilities.

Embodied within this new regulation are criteria and classifications for packaging LLRW such that it is acceptable for burial at licensed LLRW disposal sites.

For each waste classification, 10 CFR 61 stipulates specific criteria for physical and chemical properties that the LLRW must meet in order to be accepted at a licensed disposal site. The LLRW disposal criteria of 10 CFR 61 require that LLRW generators determine the proportional amount of a number of specific radioactive isotopes present in each container of disposable LLRW. This requirement for isotopic analysis of each container of disposable LLRW is met by employing a combination of analytical techniques such as computerized analyses based upon scaling factors, sample laboratory analyses, and direct assay methods. Having performed an isotopic analysis of each container of disposable LLRW, the waste must then be classified according to one of the classifications (Class A, B, C, or Greater Than Class C (GTCC)) as defined in 10 CFR 61.

EnergySolutions' classification of LLRW resulting from decommissioning activities is based on AIF/NESP-036 (Ref. No. 2), NUREG/CR-0130 (Ref. No. 5), NUREG/CR-0672 (Ref. No. 6),

and recent industry experience. The estimated curie content of the reactor vessel and internals at shutdown is derived from NUREG/CR-0130 for Pressurized Water Reactors (PWRs) and NUREG/CR-0672 for Boiling Water Reactors (BWRs), and adjusted for the different mass of components and period of decay.

Packaging Selection of the type and quantity of containers required for Class B and C wastes is based on the most restrictive of either curie content, dose-rate, container weight limit, or container volume limit. GTCC wastes from segmentation of the reactor vessel internals is packaged in spent fuel canisters. The selection of container type for Class A waste is based on the transportation mode (rail, truck, barge, etc.) and waste form. The quantity of Class A waste containers is determined by the most restrictive of either container weight limit or container volume limit. Large components, such as steam generators, pressurizers, and reactor recirculation pumps, are shipped as their own containers with additional shielding as required.

Container costs are obtained from manufacturers specializing in the design and fabrication of storage containers for nuclear materials. Shielded transport cask and liner costs are obtained from the cask owners and operators.

Transportation Transportation routes to processing and disposal facilities are determined based on available transportation modes (truck, rail, barge, or combinations). Transportation costs for the selected routes and modes are obtained from vendor quotes or published tariffs whenever possible.

Class A Disposal Options and Rates In accordance with the existing Life-of-Plant Disposal Agreement (Ref. No. 7), all Class A waste that meets the waste acceptance criteria are to be disposed of at EnergySolutions' LLRW Page 14 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 disposal facility in Clive, Utah. All reported waste disposal costs include packaging, transportation, and any applicable surcharges.

Class B and C Disposal Options and Rates Currently, within the United States, there are only three operational commercial near-surface disposal facilities licensed to accept Class B and C LLRW: the Barnwell facility, operated by EnergySolutions in Barnwell, South Carolina; the U.S. Ecology facility in Richland, Washington; and the recently licensed facility in Andrews County, Texas operated by Waste Control Specialists. Barnwell only accepts waste from states within the Atlantic Compact and U.S. Ecology only accepts waste from states within the Northwest and Rocky Mountain Compacts. However, the WCS facility will accept waste from the Texas Compact (comprised of Texas and Vermont) and from non-Compact generators. The Texas Compact Commission on March 23, 2012 approved amendments to rules allowing the import of non-compact generator LLRW for disposal at the WCS Andrews County facility.

Greater Than Class C (GTCC)

Wastes identified as 10 CFR 61 Class A, B, and C may be disposed of at near-surface disposal facilities. Certain components are highly activated and may exceed the radionuclide concentration limitations for 10 CFR 61 Class C waste. In accordance with 10 CFR 61, these components, which are referred to as Greater Than Class C (GTCC) wastes, cannot be disposed of in a near-surface LLRW disposal facility and must be transferred to a geologic repository or a similar site approved by the NRC.

Highly activated sections of the reactor vessel internals will result in GTCC waste. Presently, a facility does not exist for the disposal of wastes exceeding 10 CFR 61 Class C limitations.

EnergySolutions assumes that the DOE will accept this waste along with spent fuel. Although courts have held that DOE is obligated to accept and dispose of GTCC, issues regarding potential costs remain potentially unsettled. Therefore, EnergySolutions conservatively estimates a GTCC waste disposal cost. EnergySolutions assumes that the GTCC waste will be packaged in spent fuel canisters and will be shipped to a storage or disposal facility operated by DOE along with the spent fuel. Additionally, EnergySolutions assumes shipping costs for GTCC waste to be equivalent to the commercial cost of shipping a Type B licensed, shielded cask such as the CNS 8-120B cask, which is owned and operated by EnergySolutions.

LLRW Volume Reduction Becasue current Class A LLRW disposal rates are significantly lower than LLRW volume reduction rates, EnergySolutions does not assume on-site volume reduction techniques such as waste compaction or an aggressive decontamination, survey and release effort.

Non-Radioactive Non-Hazardous Waste Disposal EnergySolutions assumes that recyclable, non-radioactive scrap metal resulting from the decommissioning program will be sold to a scrap metal dealer. However, no cost credit is assumed in the estimate for the value of the scrap metal. Clean (non-contaminated) concrete and demolition debris is assumed to be removed off site to an out of state Class III landfill consistent Page 15 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 with the Governor of the State of California Executive Order D-62-02 (Ref. No. 16). This study includes the costs of installation and operation of EnergySolutions' GAmma Radiation Detection and In-container ANalysis or GARDIAN System. The GARDIAN System performs radiological assays of bulk shipping containers. The GARDIAN System is a cost effective and efficient means to ensure all non-radiological waste and recyclable materials arising from the decommissioning and demolition of the SONGS' site comply with all applicable regulatory requirements.

Hazardous and Industrial Waste Disposal Uncontaminated lead shielding remaining after shutdown was assumed to be removed from its installed locations and shipped offsite by entities having a need for the material. The entities will receive the lead at no charge in return for providing the removal and shipping services. Non-Radioactive contaminated surfaces coated with tightly adhering and undamaged lead based paint will be removed as non-hazardous building demolition debris. All other chemicals and hazardous materials present at shutdown will be removed and properly disposed of during decommissioning.

3.5 Final Status Survey The cost of performing a final status survey (FSS) is based on NUREG-1575, "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)," (Ref. No. 8). Estimates of MARSSIM Class I, II, and III survey designations are based on radiological assumptions regarding contamination resulting from small and large component removal activities. The FSS activity cost calculation includes the in-place remote survey of underground metal and concrete pipe, soil, and groundwater sampling and analysis. Estimated costs for NRC and Oak Ridge Institute for Science and Education (ORISE) verification are also included, and the NRC review period is incorporated into the project schedule.

3.6 Contingency Contingencies are applied to cost estimates primarily to allow for unknown or unplanned occurrences during the actual program, e.g., increased radioactive waste materials volumes over that expected; equipment breakdowns, weather delays, and labor strikes. This is consistent with the definition provided in the DOE Cost Estimating Guide, DOE G 430.1-1, 3-28-97 (DOE G)

(Ref. No. 9). Contingency "covers costs that may result from incomplete design, unforeseen and unpredictable conditions, or uncertainties within the defined project scope. The amount of contingency will depend on the status of design, procurement, and construction; and the complexity and uncertainties of the component parts of the project. Contingency is not to be used to avoid making an accurate assessment of expected costs." EnergySolutions determines site-specific contingency factors to be applied to each estimate based on industry practices.

The DOE has established a recommended range of contingencies as a function of completeness of program design, DOE G. The ranges are:

Page 16 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 Contingency Range Type of Estimate as a % of Total Estimate Planning Phase Estimate 20-30 Budget Estimate 15-25 Title I (Preliminary Design Estimate) 10-20 Title II (Definitive Design Estimate) 5-15 Also, the Pacific Gas & Electric Company (PG&E) Technical Position Paper "Establishing an Appropriate Contingency Factor for Inclusion in the Decommissioning Revenue Requirements" (Ref. No. 13) was developed to review and determine a "conservative contingency factor" to be applied to decommissioning cost estimates. In that study it was determined that "based on an understanding of the level of project definition, and the extent and maturity of estimate input information used to develop decommissioning cost estimates, the 25 percent contingency factor is within the range of industry recognized cost engineering practices."

The contingencies presented in this study are consistent with the values presented in DOE G 430.1-1 for a Planning Phase estimate (Ref. No. 9) and the PG&E study (Ref. No. 13). As directed by SCE, EnergySolutions has applied a 25% contingency to all costs in this study, with the exception of following:

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%

A reactor decommissioning program will be conducted under an NRC-approved Quality Assurance Program which meets the requirements of 10 CFR 50, Appendix B. However, the development of the quality assurance program, the performance of work under that program, and the effort required to ensure compliance with the program, is already included in the detailed cost estimate. Therefore, EnergySolutions does not include quality assurance as an element of the contingency allowance. The same is true for contamination. Where radioactive contamination or activated materials are dealt with, the EnergySolutions UCFs and associated calculations fully reflect the cost impact of that material, and a separate contingency is not required specifically due to working with contamination.

3.7 Cost Reporting Total project costs are aggregated from the distributed activity and undistributed costs into the following categories - Labor, Materials and Equipment, Waste Disposal, and Other costs. Other costs include property taxes, insurance, license fees, permits, and energy. Waste Disposal costs are the summation of packaging, transportation, base disposal rate, and any applicable surcharges. Health physics (HP) supplies and small tool costs are calculated as a component of each distributed activity cost and included in the category of Material and Equipment, with the exception that HP supplies for the Utility HP staff are calculated and reported as an undistributed line item. A line item specific contingency is then calculated for each activity cost element.

Page 17 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 4.0 SITE SPECIFIC TECHNICAL APPROACH 4.1 Facility Description The San Onofre Nuclear Generating Station Units 2 & 3 site is located in southern California on the shore of the Pacific Ocean, about 62 miles Southeast of Los Angeles and approximately 51 miles Northwest of San Diego. The station is located entirely within the Camp Pendleton Marine Corps Base. The current Grant of Easement for the site from the United States Department of the Navy is currently scheduled to expire May 12, 2023 (Ref. No. 14). Units 2 & 3 occupy 52.8 acres of the 84 acre site. Approximately 16 acres are occupied by the North Industrial Area (formerly Unit 1), which is where the existing ISFSI is located.

The Nuclear Steam Supply System (NSSS) for both units are identical, with two independent loops, and utilizing pressurized light water cooled reactors (PWRs) supplied by Combustion Engineering, Inc. The construction permit was issued for an initial reactor power of 3,390 MWt with licensed Rated Thermal Power of 3,438 MWt.

The facility currently has an existing ISFSI containing spent fuel that was transferred into MPCs to maintain full core offload capability during operations and to facilitate decommissioning of Unit 1. This study also assumes that the MPCs will be licensed under a 10 CFR Part 72 general license, using the manufacturer's Certificate of Compliance. The 10 CFR Part 50 license will be maintained until decommissioning is complete and all spent fuel has been transferred to DOE.

Appendix A provides a list of the SONGS Unit 2 & 3 systems and structures included in the material inventory for this study.

4.2 Decommissioning Periods The project periods consist of six License Termination periods, seven Spent Fuel Management periods (two of which are ISFSI decontamination and demolition periods), and six Site Restoration periods. As shown in Figure 1-1 above, the periods for each of these project areas are independent from (do not compete with) the periods for the other project areas. The project periods defined for this site-specific study and the major activities performed during each period are as follows:

License Termination Periods Decon Pd 1 -Transition to Decommissioning

" Defuel Reactors

" Notification of Permanent Fuel Removal

" Disposition of LLRW Resins Decon Pd 2 -Decommissioning Planning and Site Modifications

" Preparation of Decommissioning License Documents

" Preparation of NRC Deliverables

" Submit PSDAR to NRC

" Perform Historical Site Assessment and Site Characterization

" Planning, Design, and Implementation of Cold & Dark (Site Repowering)

Page 18 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3

" Design and Implement Spent Fuel Pool Support System Modifications, Control Room Relocation, and Spent Fuel Security System Modifications

" Select Decommissioning General Contractor (DGC)

Decon Pd 3 - Decommissioning Preparations and Reactor Internal Segmentation

" DGC Mobilization and Planning

" System Decontamination

" Reactor Internals Removal Preparations

" Reactor Internals Segmentation Planning and Implementation

" Purchase Dry Storage Modules for GTCC Waste

" Segment and Package Reactor Internals for Storage in the ISFSI Decon Pd 4 - Plant Systems and Large Component Removal

" Upgrade Rail Spur on 'Owner Controlled Area' (does not affect spur connecting to CALTRANS).

" Install Large Array Radiation Detection System

" Remove, Package, and Dispose of Non-Essential Systems

" Asbestos and Lead Abatement

" Fuel Pool Closure

" Remove Spent Fuel Racks, Spent Fuel Pool Island Equipment, and Bridge Cranes

" Remove and Dispose of Legacy Class B & C Wastes

" Remove, Package, and Dispose of Essential Systems

" Removal and Disposal of Spent Resins, Filter Media, and Tank Sludge

" Large Component Removal

" Prepare License Termination Plan Decon Pd 5 - Building Decontamination

" Decon Containment Buildings - Units 2 & 3

" Decon Turbine Buildings - Units 2 & 3

" Decon Fuel Handling Buildings - Units 2 & 3

" Decon Auxiliary Radwaste Building

" Decon Auxiliary Control Building

" Decon Penetration Buildings - Units 2 & 3

" Decon Safety Equipment and Main Steam Isolation Valve Buildings - Units 2 &

3

" Radiological Survey of Structures During Decon Decon Pd 6 - License Termination During Decommissioning

" Final Status Survey

" ORISE Verification and NRC Approval Spent Fuel Management Periods SNF Pd 1 - Spent Fuel Transfer Management Transition

" Implementation of Security Enhancements Required for Reductions in Staff

" Cyber Security Modifications

" Post Fukushima Modifications - Unit 2

" Design and Fabricate Spent Fuel Canisters Page 19 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 SNF Pd 2 - Spent Fuel Transfer to Dry Storage

" Prepare Irradiated Fuel Management Plan

" Select Dry Storage System Canister Design and Vendor

" Design and Construct ISFSI Expansion

" Purchase, Deliver and Load Spent Fuel Canisters and Transfer to ISFSI SNF Pd 3 - Dry Storage During Decommissioning Units 1, 2, & 3 SNF Pd 4 - Dry Storage Only - Units 1, 2, & 3 SNF Pd 5 - Dry Storage Only - Units 2, & 3 SNF D&D Pd 1 - ISFSI License Termination N Preparation and NRC Review of License Termination Plan SNF D&D Pd 2 - ISFSI Demolition

" Verification Survey of Horizontal Storage Modules

" Clean Demolition of ISFSI AHSMs and Pads

" Clean Demolition of ISFSI Support Structures

" Restore ISFSI Site

" Preparation of Final Report on Decommissioning and NRC Review Site Restoration Periods SR Pd 1 -Transition to Site Restoration

" Severance Costs from Post-Shutdown Reduction in Staffing

" Phase I and II Environmental Assessment of the Mesa Site

" Disposition of Hazardous Waste at the Mesa Site

" Site Characterization of the Mesa Site SR Pd 2 -Building Demolition During Decommissioning

" Demolish South Access for Decommissioning, South Yard Facility, and Mesa Structures

" Finish Grade and Re-vegetate Mesa Site

" Mesa Lease Termination SR Pd 3 - Subsurface Demolition Engineering & Permitting

" Hydrogeologic Investigation and Outfall Conduit Survey

" Subsurface Structure Removal Analyses for Lease Termination Activities

" Final Site Grading and Shoreline Protection Engineering Planning and Design

" Obtain Permits and Approvals SR Pd 4 - Building Demolition to 3 Feet Below Grade

" Demolition Preparations

" De-Tension and Remove Containment Building Tendons - Units 2 & 3

" Demolish Diesel Generator Buildings - Units 2 & 3

" Demolish Condensate Buildings and Transformer Pads - Units 2 & 3 Page 20 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3

" Demolish Full Flow Areas and Turbine Buildings - Units 2 & 3

" Demolish Auxiliary Radwaste Building 0 Demolish Auxiliary Control Building

" Remove Systems and Demolish Make-up Demineralizer Structures

" Demolish Penetration Buildings - Units 2 & 3

" Demolish Safety Equipment and Main Steam Isolation Valve Buildings - Units 2

&3

" Demolish Fuel Handling Buildings to 3 Feet Below Grade - Units 2 & 3

" Demolish Containment Buildings to 3 Feet Below Grade - Units 2 & 3

" Demolish Intake and Discharge Structures to 3 Feet Below Grade SR Pd 5 - Subgrade Structure Removal Below - 3 Feet

" Install Sheet Piling and Excavation Shoring, Dewatering System, and Effluent Treatment and Discharge Controls

" Demolish and Backfill Unit 3 Subsurface Structures

" Demolish and Backfill Unit 2 Subsurface Structures

" Demolish and Backfill Common Subsurface Structures

" Demolish and Backfill Intake Structure Inside Seawall Below -3 Feet

" Remove Off Shore Intake and Outfall Conduits

" Remove Sheet Piling, Excavation Shoring, and Dewatering and Effluent Treatment

" Finish Grading and Re-vegetate Site SR Pd 6 - Final Site Restoration and Easement Termination

" Obtain Required Permits and Approvals

" Install Dewatering System and Effluent Treatment and Discharge Controls

" Remove and Stockpile Existing Seawall Erosion Protection

" Remove Unit 2 & 3 Seawall and Pedestrian Walkway

" Remove Remaining Intake Structure Beneath Seawall

" Backfill and Compaction of Excavation

" Remove Dewatering System & Effluent Treatment

" Remove Railroad Tracks, Gunite Slope Protection, Access Road, and North Parking Lot

" Finish Grading and Re-vegetate Site 4.3 Decommissioning Staff EnergySolutions developed staffing based on the assumption that decommissioning will be performed by an experienced and qualified DGC, with oversight and management of the decommissioning operations performed by the Utility (Licensee) staff. It is also assumed that the Utility staff will be supplemented by a professional consulting engineering firm, particularly in the planning and preparation phase. The sizes of the Utility (Licensee) and DGC staffs are varied in each period in accordance with the requirements of the work activities. Details on the staff levels, by functional group, during each period are provided in Section 6.0.

4.4 Spent Fuel Management Staff The largest spent fuel staff is in place while the fuel pool is operational during the spent fuel cooling period and the fuel assemblies are being transferred to dry storage. After all spent fuel Page 21 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 has been removed from the spent fuel pool, the staff is reduced. During spent fuel pool operations and the dry storage period, the full-time spent fuel management staff is supplemented with part-time staff to support fuel movements. Details on the staff levels, by functional group, during each period are provided in Section 6.0.

4.5 Spent Fuel Shipments The spent fuel shipping schedules are based in part on the DOE's "Acceptance Priority Ranking

& Annual Capacity Report," dated July 2004. (Ref. No. 12). The information regarding existing fuel inventory, planned transfers to dry storage and DOE's projected date of 2024 for acceptance of spent fuel is based on information provided by SCE. The spent fuel shipping schedule is provided in Appendix B. The spent fuel shipment schedule is based upon best current information and assumptions, as qualified and described elsewhere in this study, including in Section 2.2 above.

Page 22 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 5.0 BASES OF ESTIMATE AND KEY ASSUMPTIONS The bases of, and key assumptions for, this site-specific decommissioning estimate are presented below:

1. SCE's actual decommissioning expenses incurred from the time of permanent cessation of operations on June 7, 2013 until December 31, 2013 are included in the estimate.

All other decommissioning cost data used in this study is current as of 2014. Totals and subtotals have been rounded to significant figures.

2. EnergySolutions developed a prompt dismantlement (DECON) project schedule based on a permanent shutdown date of June 7, 2013.
3. The decommissioning will be performed using currently available technologies.
4. DOE currently has no plans, program, or schedule in place for acceptance of utility spent fuel. However, for purposes of this decommissioning cost estimate, certain simplifying assumptions must be made regarding the schedule and rate of DOE performance. Therefore, while DOE's Standard Contract governing the acceptance of SCE's spent fuel allows for alternative removal schedules, including priority for shutdown reactors and exchanges of allocations, for purposes of this estimate DOE acceptance from the industry is assumed to commence in 2024 in accordance with SCE testimony to the Public Utilities Commission of the State of California (Ref. No. 17).

The spent fuel shipment schedules are based upon the assumption that the DOE will accept spent fuel at the rate published in DOE's July 2004 Acceptance Priority Ranking

& Annual Capacity Report (DOE/RW-0567) (Ref. No. 12). Additionally, SCE is reviewing available information from DOE to determine if the DOE start date assumption requires updating. The DCE will be revised accordingly as new information becomes available.

5. This estimate is based on site-specific building inventories and plant systems, as provided by EnergySolutions.
6. All transformers on site following shutdown are assumed to be polychlorinated biphenyl (PCB)-free, therefore, this study does not include costs for disposition of PCB contaminated transformers.
7. Cost for transportation of clean scrap metal to a recycler is included in the estimate; however, no credit is taken for the value of the scrap metal. Concrete debris and all other demolition debris is assumed to be removed from the site and disposed of at an out of state Class III landfill, consistent with the Governor of the State of California Executive Order D-62-02 (Ref. No. 16). The cost of installation and operation of EnergySolutions' GARDIAN system for bulk radiological assay of all wastes and recyclable materials leaving the SONGS site is included in the estimate. The purpose of the GARDIAN system is to ensure all materials not intended for disposal at a licensed facility meet all applicable requirements.

.Page 23 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3

8. The estimate is based on final site restoration, in which all existing and proposed structures, with the exception of the switchyard, will be removed. Clean demolition costs are based on the assumption that all site improvements will be removed in their entirety. Clean backfill will be imported and placed to re-establish grade. The entire disturbed area of the site is to be graded, to restore the natural grade to the extent possible, and seeded.
9. Uncontaminated lead shielding remaining is assumed to be removed from its installed locations and shipped offsite by entities having a need for the material. The entities receive the lead at no charge in return for providing the removal and shipping services.
10. Site-specific information regarding contaminated soil was used as a basis for calculation of current costs for their remediation. While no known radiological or chemical remediation is required at the switchyard or the Mesa, those areas will be addressed as part of the Baseline Characterization Survey and Historical Site Assessment. If the studies conclude that radiological or chemical remediation is required at the switchyard or the Mesa, the DCE will be amended. For radiological contamination found at either the switchyard or the Mesa, the DCE will be amended to include all subsequent cost estimates for the remediation, which will be paid for by the SONGS participants in accordance with their cost allocations for the 'Common Facilities'. Chemical remediation of the switchyards will be paid by either SCE or SDG&E owners of the respective switchyards.
11. Costs for hazardous waste disposal, as well as asbestos and lead abatement, are included in this study.
12. All Class A waste is assumed to be disposed of at EnergySolutions' facility in Clive, Utah, in accordance with the existing Life-of-Plant Disposal Agreement between EnergySolutions and Southern California Edison, dated January 18, 2014 (Ref. No. 7).

The following 2014 disposal rates will be applied:

Demolition Debris and Soil - $57.97/Cubic Foot plus 5% Utah taxes Oversized Debris - $111.3 1/Cubic Foot plus 5% Utah taxes Containerized Waste Facility - $214.50/Cubic Foot plus 12% Utah taxes Large Components - $289.87/Cubic Foot plus 5% Utah taxes Cask Shipments - $44,059/Cask plus 12% Utah taxes Class A waste includes Dry Active Waste (DAW) arising from the disposal of contaminated protective clothing and health physics supplies.

13. Class B, C, and GTCC waste disposal costs are based on recent quotes for disposal of activated hardware and resins at the WCS facility. All resins and filter waste is assumed to be Class B.
14. Shipping costs for the Class B and C waste are based on a distance of 1,079 miles one way from SONGS to the WCS site.

Page 24 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3

15. GTCC is not subject to the same storage and security requirements as spent fuel and therefore is not required to be stored on the ISFSI pad. But for purposes of this estimate and to facilitate decommissioning, GTCC waste generated from the segmentation of the reactor internals is assumed to be packaged in Dry Shielded Canisters (DSCs) and placed in Advanced Horizontal Storage Modules (AHSMs) in the ISFSI to await final disposition at a DOE repository.
16. It is assumed that a total of six DSCs per unit will be required for GTCC waste.
17. Reactor vessel and internals curie estimates were derived from the values for the Reference PWR vessel and internals in NUREG/CR-0130 (Ref. No. 5). These values were adjusted for decay period.
18. The EnergySolutions site-specific classification of radioactive wastes for the SONGS Plant identified that the spent fuel assemblies and two components within the reactor vessel (the Core Shroud Assembly and the Lower Core Grid Plate) will exceed Class C limitations.
19. The spent fuel shipments are based upon best current information and assumptions, as qualified and described elsewhere in this study, including in Section 2.2. above.
20. Spent fuel will remain in the spent fuel pool for six years before being transferred to the ISFSI.
21. The costs for ISFSI construction and transfer of spent fuel from Units 2 & 3 to dry storage were developed by SCE and furnished to EnergySolutions. Following completion of spent fuel transfers to dry storage the cost of maintenance and operation of the ISFSI is distributed between Units 1, 2 and 3 based on the relative percentages of spent fuel assemblies in storage. The percentages are 10, 45, and 45 for Units 1, 2, and 3, respectively. The exception is that all property taxes are solely the liability of Units 2 & 3. Following completion of SNF Pd 4 - Dry Storage Only Units 1, 2, and 3, all ISFSI maintenance and operating costs are assigned to Units 2 & 3 until the ISFSI D&D. During ISFSI D&D costs are distributed to all three units in the same percentages of 10, 45, and 45.
22. DOE has not committed to accept SCE's canistered spent fuel. But for purposes of this estimate, it is assumed that an SCE-funded dry storage facility will not be necessary.
23. Costs for ISFSI demolition are included in this estimate. SCE assumes that portions of the AHSM concrete will be activated.
24. EnergySolttions has assumed that the 10 CFR Part 50 license will be maintained until DOE has taken possession of the spent fuel.
25. SCE's annual ISFSI insurance premiums of $302,000 are assumed to be incurred until all fuel shipments have been completed and the structure is no longer in use.

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2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3

26. SCE's Emergency Preparedness (FEMA) fees of $500,000 per year and California Office of Emergency Services fees of $2,800,000 per year are applied until the spent fuel pool is empty. These fees were supplied by SCE.
27. SCE's current annual property taxes are assumed to be reduced to a constant

$1,500,000 per year. The property taxes are a license termination expense until the completion of decommissioning, and then a spent fuel management expense until completion of the ISFSI D&D.

28. EnergySolutions has included the annual NRC 10 CFR 171.15(c)(2) fees, for reactors in decommissioning of $231,000/yr per unit until decommissioning is completed as a license termination expense. Following completion of decommissioning, this expense is continued as a spent fuel management cost for maintenance of the 10 CFR Part 50 license.
29. EnergySolutions has included Environmental Permits and Fees of $1,900,000 per year as supplied by SCE.
30. EnergySolutions has included NRC inspection fees during each decommissioning period based on the type and level of activities being performed.
31. SONGS annual insurance premiums, in 2014 dollars as supplied by SCE, are as follows:

Nuclear Property Primary - $4,878,099 Nuclear Liability - $1,151,075 Additional Liability, Non-Nuclear - $3,576,519 Workers' Compensation - $180,335 Property Insurance - $353,286 The premium amounts have been adjusted by EnergySohltions in accordance with information furnished by SCE to meet the requirements of each period.

32. Site operating expenses expected to be incurred during decommissioning and spent fuel management are included in the estimate. These costs include materials and services, utilities (water, gas, phone), telecommunications equipment, non-process computers, personal computers and tools and equipment. These costs were calculated based on information provided by SCE and adjusted by EnergySolutions to match the requirements of each period, based on staffing levels.
33. Site Lease and Easement expenses of $2,300,000 per year until the Mesa lease is terminated are included in the estimate. Following termination of the Mesa lease the site lease and easement expenses are reduced to $299,920 per year. These costs are based on information provided by SCE.
34. Utility (Licensee) staff positions and average direct burdened salary (i.e. total compensation) data in 2014 dollars were supplied by SCE.

Page 26 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3

35. Severance costs for those employees terminated as a result of SONGS decommissioning, including those costs required under California law are included in the estimate. Severance costs for Reductions-in-Force (RIFs) that occurred immediately after shutdown, and during the course of spent fuel management and decommissioning are assumed to be a site restoration expense and are included in the estimate.
36. Severance costs per employee were provided by SCE.
37. DGC staff salaries, including overhead and profit, were determined by EnergySolutions and represent EnergySolutions' standard assumptions for these rates.
38. The professional personnel used for the planning and preparation activities, and DGC personnel, are assumed to be paid per diem at the rate of $204/day, based on per diem rates from U.S. General Services Administration (GSA) for Orange County, California.
39. Craft labor rates were taken from the CA Union Craft Rate Sheet, dated January 9, 2014. Craft labor rates for disciplines not provided in the rate sheet have been taken from the 2014 RS Means Labor Rates for the Construction Industry (Ref. No. 10), for Anaheim, CA. Since the skilled laborers are assumed to be supplied by the local union hall, they will not be paid per diem.
40. The security guard force included in this estimate has been sized in accordance with the current Design Basis Threat assessment.
41. This study follows the occupational exposure principles of As Low As Reasonably Achievable (ALARA) through the use of productivity loss factors that incorporate such items as the use of respiratory protection and personnel protective clothing. These factors increase the work duration and cost.
42. The costs of all required safety analyses and safety measures for the protection of the general public, the environment, and decommissioning workers are included in the cost estimates. This reflects the requirements of:

10 CFR 20 Standards for Protection Against Radiation 10 CFR 50 Domestic Licensing of Production and Utilization Facilities 10 CFR 61 Licensing Requirements for Land Disposal of Radioactive Waste 10 CFR 71 Packaging of Radioactive Material for Transport 10 CFR 72 Licensing Requirements for the Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste 29 CFR 1910 Occupational Safety and Health Standards Page 27 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 49 CFR 170-189 Department of Transportation Regulations Governing the Transport of Hazardous Materials Reg. Guide 1.159 Assuring the Availability of Funds for Decommissioning Nuclear Reactors

43. Activity labor costs do not include any allowance for delays between activities, nor is there any cost allowance for craft labor retained on site while waiting for work to become available.

Page 28 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 6.0 STUDY RESULTS This study analyzes the following technical approach to decommissioning as defined by SCE:

" Prompt DECON methodology.

" Permanent cessation of operations and commencement of decommissioning planning on June 7, 2013.

" Termination of spent fuel pool operation six years after permanent shutdown.

" Spent fuel will be stored in MPCs at an on-site ISFSI.

" A dry transfer facility will not be necessary for transfer of SNF for transport.

" Decommissioning will be performed by a DGC with oversight by the SONGS participants.

" LOP Disposal Rates are used for Class A LLRW.

" WCS Texas Disposal Rates are used for Class B and C LLRW.

" DOE begins accepting spent fuel from the industry in 2024.

Spent Fuel Shipping Schedule The spent fuel shipping schedule is provided in Appendix B. Spent fuel shipments from the industry to DOE will begin in 2024. The spent fuel shipment schedules are based upon best current information and assumptions, as qualified and described elsewhere in this study, including in Section 2.2 above.

Cost and Schedule Figure 6-1 is a summary project schedule. A detailed schedule is provided in Appendix C.

Table 6-1 summarizes the period durations and total costs, including contingency, for License Termination, Spent Fuel, and Site Restoration activities. A detailed cost table is provided in Appendix D, and a table of annual expenditures is provided in Appendix E.

Proiect Staffing This scenario is based on the assumption that decommissioning will be performed by an experienced and qualified DGC, with oversight and management of the decommissioning operations performed by the Licensee staff. Utility (Licensee) staffing levels, by organizational department and function, for each period are provided in Table 6-2. The DGC staffing levels, by organizational department and function, for each period are provided in Table 6-3.

Page 29 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 LLRW Disposal Volumes LLRW disposal is a significant element of the decommissioning project. The estimated cubic feet of waste are summarized as follows:

Waste Class Unit 2 Unit 3 Total Class A 1,832,961 1,819,680 3,652,641 Class B 7,600 7,600 15,200 Class C 4,095 4,095 8,190 GTCC 941 941 1,882 Waste disposal volumes and costs, itemized by packaging, transportation, surcharges and disposal costs by waste class and facility, are provided in Table 6-4. The waste disposal costs provided in Table 6-4 do not include contingency.

Page 30 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 Figure 6-1 Summary Schedule DECON with Dry Storage, 2013 Shutdown and DOE Acceptance in 2024 FPdoat BENlzw ;anb-ov 9 F PIMare nW I O&l 7013 2/ iMIM W Spami Fuel Shl~pin Cormplw - Unit 1 1 lV1W'122 In *12IM

  • 1241t Spent Fuel W4*pm CRO" et- Unks 2&3 1 !3t120491 12=2049 B

SWl d 1- Speam Fuel Melugenwot Transiion 0517/2012i 112211201

- .- -- - -t ~

1/1/WiC -I/WI.

SiUF Pd 2 - Spent Fual Transfer to Dry Storge 1/'1,201 U,"J01 t SNF Pd S- Dry Storage During Deomnisioning - Units 1, 2 and 3 01*0,`11M 12/062061 W000-.

SNF Pd 4 - Dry Storap Only - Unite 1, 2 md 2 12*/2 0 1/2112025 1Ww SNF Pd 5- Dry StoraW Only- Units 2 and 3 12*1/025 3112049 SNF DWDPd 1. ISFSI D&D Plamning 1241/2 06611 12M

  • rel" U&U '02- OIMBA"U&U Port 50 Licens Temnamtion I 6/7204 m26202 AIMMg~MnOn Of LO6SME1 01 L5opeatSIt .11(Jn7,2013) 06WIMMl3l OGW/2013 W &I Deoon Pd 1. Transi*ion to D*ecmisasion F*I WIII/ M "112013 up Decon Pd 2. Docounwnisioning Pl6an and Sie tione 1/trW0141 VModilice J-Decan Pd 3- Decommissoing Prepawtiona and Reacor Intenals Segm ntation 0 o1s 0et0m1 * ==W Decon Pd 4 - Plant Spaema and Lare Component n Removal 0601/019 0M24/2022 W=MW Decon Pd 5- Building Deoc, minaon I 24',' 071121024 wow Decon Pd 6- ILoente Termniation urig Demolition 07/If2/U4 S ite R et ratio n 06 / 012 1 X M15/2 1-- --

SR Pd I - Tra-,,-tion to Sie Restoration 06M..1I7 " 06*/2M0/20 sR Pd 2- Bi6ld*g o *06/2020 D o 8lonlngl 0/120171 SR Pd s- Subsaflsoe Demfolio Engiinering and P...*v 10101P019 0oMM2m4 pMMMW SA Pd 4- Bu*d*ing Demolition to 3 Feet Below Oracde 01202M 1141028 SI IilII SRqP:d a - Sub~tlo Sruetwe enmald Below .2qFeet 10/14* 12MM1 S Pd 6 - Finl Sit Restoration and lea6 Termination 050&2060 12M/1601 Final Easom Ti Torn**It6cn 2tI5-/2M 1 11211/2051 112/

Page 31 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 Table 6-13 Cost and Schedule Summary (2014 Dollars in Thousands)

License Termination (50.75(c))

DeconPd 1Transition to DeconP Decommissioning 6/7/2013 12/31/2013 0.56 $25,749 $26,566 $52,315 Decon Pd 2 Decommissioning Planning 1/1/2014 6/30/2015 1.49 $118,709 $122,430 $241,140 and Site Modifications Decommissioning Decon Pd 3 Preparations and Reactor 6/30/2015 6/1/2019 3.92 $262,210 $276,799 $539,009 Internals Segmentation Decon Pd 4 Plant Systems and Large 6/1/2019 9/24/2022 3.31 $392,029 $412,475 $804,504 Component Removal Decon Pd 5 Building Decontamination 9/24/2022 7/13/2024 1.80 $212,447 $216,659 $429,106 Decon Pd 6 License Termination During 7/13/2024 12/24/2032 8.44 $23,085 $23,085 $46,171 Demolition Account Total 19.52 $1,034,230 $1,078,016 $2,112,246 Spent Fuel (50.54(bb)) and (72.30)

SNF Pd 1 Spent Fuel Management SNF Pd 1 Transition 6/7/2013 12/31/2013 0.56 $63,891 $66,105 $129,997 SNF Pd 2 TSpnstiFelTrnsfrtr SNFPd2 Spent Fuel Transfer to Dry 1/1/2014 6/1/2019 5.41 $344,629 $372,193 $716,822 Storage Dry Storage During SNF Pd 3 Decommissioning - Units 1, 2 6/1/2019 12/5/2031 12.51 $61,425 $61,425 $122,849 and 3 SM~

Pd 4 Dry Storage Only - Units 1, 2 SNFPd4 and 3 12/5/2031 12/31/2035 4.07 $29,383 $29,383 $58,765 SNPd Dry Storage Only - Units 2 12/31/2035 12/31/2049 14.00 $107,326 $107,326 $214,653 and 3 SNF D&D ISFSI License Termination 12/31/2049 5/6/2050 0.34 $1,260 $1,260 $2,520 Pd I SNF D&D ISFSI Demolition 5/6/2050 9/8/2051 1.34 $15,295 $15,295 $30,590 Pd 2 Account Total 38.23 $623,209 $652,987 $1,276,196 Site Restoration SR Pd 1 Transition to Site Restoration 6/7/2013 6/30/2015 2.06 $64,280 $66,210 $130,489 SR Pd 2 Building Demolition During 6/30/2015 7/11/2017 2.03 $13,003 $37,242 $50,245 Decommissioning SR Pd 3 Subsurface Demolition Engineering and Permitting 10/1/2019 7/13/2024 4.78 $15,593 $22,319 $37,912 SR Pd 4 Building Demolition to 3 Feet 7/13/2024 10/14/2028 4.25 $124,953 $134,113 $259,066 Below Grade SRPd5 Subgrade Structure Removal 10/14/2028 12/5/2031 3.14 $171,987 $269,560 $441,547 Below - 3 Feet SR Pd 6 Final Site Restoration and 5/6/2050 12/15/2051 1.60 $33,482 $70,064 $103,545 Lease Termination Account Total 17.86 $423,297 $599,507 $1,022,804 Grand Total $2,080,735 $2,330,511 $4,411,246 3 Rows and columns may not add correctly due to rounding.

Page 32 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 Table 6-2 Utility Staff Levels Decommissioning 0 21 21 2) 18 U Engineering 0 49 14 14 12 0 Maintenance and Work Control 0 38 10 10 3 0 Operations 0 15 7 7 0 0 Oversight and Nuclear Safety 0 7 2 2 1 0 Radiation Protection and Chemistry 0 27 26 31 26 0 Regulatory and Emergency Planning 0 10 4 4 4 0.5 Safety and Human Performance 0 13 7 7 7 0 Security Admin 0 6 6 6 6 0 Security Guard Force 0 12 12 12 12 0 Site Management and Administration 0 13 13 13 9 1 Period Totals 0 211 122 131 98 1.5 S ent Fuel - 50.54(bb Utili Staff Spent Fuel Shipping 0 0 0 2 2 0 0 Decommissioning 0 0 0 0 0 1 1 Engineering 0 1 1 1 1 0 1 Maintenance and Work Control 0 31 0 0 0 0 0 Operations 0 45 1 1 1 0 0 Oversight and Nuclear Safety 0 1 0.25 0.25 0.25 0 0 Radiation Protection and Chemistry 0 6 4 4 4 1 2 Regulatory and Emergency Planning 0 0 0 0 0 1 1 Security Admin 0 14 10 8 8 1 1 Security Guard Force 0 178 35 35 35 5 5 Site Management and Administration 0 0 0 0 0 1 1 Period Total 0 276 51.25 54.25 54.25 10 12 Site Restoration - Utilit Staff Decommissioning 0 2 0 5 4 2 Engineering 0 1 0 2 1 0 Maintenance and Work Control 0 1 0 2 2 2 Regulatory and Emergency Planning 0 1 0 0 0 0 Safety and Human Performance 0 1 0 2 1 1 Security Admin 0 0 0 1 1 0 Security Guard Force 0 0 0 5 5 0 Site Management and Administration 0 0 0 4 3 3 Period Totals 0 6 0 21 17 8 Page 33 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 Table 6-3 DGC Staff Levels License Termination - 50.75(c) DGC Staff Administration 9 17 17 0 Engineering 15 29 14 0 Health Physics 16 73 73 2 Management 3 3 3 0 Quality Assurance 2 5 4 0 Waste Operations 7 16 16 0 Period Totals 52 143 127 2 Scent Fuel - 50.54tbbl - DGC Staff Administration I Engineering 2 Health Physics 3 Management I Quality Assurance 1 Waste Operations 4 Period Totals 12 Site Restoration DGC Staff Administration 0 0 0 10 5 4 Engineering 0 0 0 13 11 5 Health Physics 0 0 0 3 0 0 Management 0 0 0 2 2 1 Quality Assurance 0 0 0 2 1 0 Waste Operations 0 0 0 11 7 7 Period Totals 0 0 0 41 26 17 Page 34 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 Table 6-4 Waste Disposal Volumes (Cost Excludes Contingency - 2014 Dollars)

Class B and C Facility Class B 1,132,323 6,696 15,199 $1,199,186 $6,433,599 $72,635,570 $80,268,355 Class C 407,380 1,546 8,191 $2,064,309 $26,706,007 $39,142,870 $67,913,186 GTCC 92,861 190 1,882 $196,288 $1,680,000 $38,775,980 $40,652,268 1,632,564 8,431 25,272 $3,459,782 $34,819,606 $150,554,420 $188,833,808 EnergySolutions Class A - Debris 200,560,122 3,229,506 3,308,050 $3,804,262 $13,779,286 $211,423,909 $229,007,458 Class A - Oversize 9,967,521 146,943 184,730 $187,314 $784,285 $22,669,947 $23,641,545 Class A - Containerized Waste 1,053,914 12,287 16,303 $397,152 $364,322 $4,112,378 $4,873,851 Class A - Large Component 11,480,200 108,866 136,373 $6,313,568 $69,622,664 $43,582,464 $119,518,696 Class A- Mixed Waste 62,643 3,012 3,012 $67,887 $12,448 $801,226 $881,561 223,124,400 3,500,614 3,648,469 $10,770,182 $84,563,005 $282,589,924 $377,923,111 Other Out of State Class III Landfill 1,909,207,440 25,212,269 29,372,422 $0 $146,326,469 $43,929,750 $190,256,219 Scrap Metal Recycler 184,787,372 377,117 7,391,495 $0 $911,926 $0 $911,926 2,093,994,812 25,589,386 36,763,917 $0 $147,238,394 $43,929,750 $191,168,144 Grand Total 2,318,751,776 29,098,431 40,437,658 $14,229,964 $266,621,006 $477,074,094 $757,925,064 Page 35 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3

7.0 REFERENCES

1. U.S. Nuclear Regulatory Commission, "Domestic Licensing of Production and Utilization Facilities," 10 CFR Part 50, 2008, Available from hMp://www.nrc.gov/reading-rmndoc-collections/cfr/part050/full-text.html.
2. Atomic Industrial Forum, Inc., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986.
3. U.S. Nuclear Regulatory Commission, "Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors," Regulatory Guide 1.202, February 2005.
4. Federal Register, Vol. 4, "Standard Contract for Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste," NRC 10 CFR Part 961 (DOE), January 1, 1999.
5. U.S. Nuclear Regulatory Commission, "Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station," NUREG/CR-0130, June 1978.
6. U.S. Nuclear Regulatory Commission, "Technology, Safety and Costs of Decommissioning a Reference Boiling Water Reactor Power Station," NUREG/CR-0672, June 1980.
7. Life-of-Plant Disposal Agreement, between EnergySolutions, LLC and SCE effective January 1st, 2014.
8. U.S. Nuclear Regulatory Commission, "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)," NUREG-1575, Rev. 1, August 2000.
9. U.S. Department of Energy, "Cost Estimating Guide," DOE G 430.1-1, March 1997.
10. RS Means, "Labor Rates for the Construction Industry," 2014.
11. ABZ, Incorporated, "San Onofre Nuclear Generating Station Units 2 and 3 (SONGS 2/3)", December 14,2012
12. U.S. Department of Energy, "Acceptance Priority Ranking & Annual Capacity Report,"

DOE/RW-0567, July 2004.

13. Pacific Gas & Electric, "Establishing an Appropriate Contingency Factor for Inclusion in the Decommissioning Revenue Requirements", April 2009
14. Department of the Navy, "Grant of Easement," May 1964.
15. State of California State Lands Commission, "Lease P.R.C. No. 4862.1", dated November 19, 1984 Page 36 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3

16. State of California, Executive Order D-62-02, September 2002
17. Southern California Edison, "Testimony On the Nuclear Decommissioning Of SONGS 2

& 3 And Palo Verde Before the Public Utilities Commission of the State of California,"

December 21, 2012.

Page 37 of 37

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 Appendix A List of Systems and Structures

SONGS Plant System and Structure List Common Type System Name or Description Non Not Used Struct Administration Building (K-40/50)

Struct AWS Building Struct Building L-50 Struct Gunite Slope Protection Struct High Flow Make-Up Demineralizer Area Struct ISFSI Support Structures Struct Maintenance Building I (B-43/B-44)

Struct Maintenance Building 2 (B-49/B-50)

Struct Maintenance Building 4 (B-64/B-65)

Struct Maintenance Building 5 (B-62/B-63)

Struct Mesa Buildings Struct Not Used Struct Outage Control Center Building Struct REMS Staging Pad Struct Seawall - Units 2 & 3 Struct Security Access Building (A-80, 81, 82)

Struct Service Building (K-10, 20, 30)

Struct South Security Processing Facility (K-70)

Struct South Yard Facility Buildings (T-10, 20, 60 and Haz Mat.)

Struct Staging Warehouse Building Ess Auxilary Control Systems - Unit 2 Ess Fuel Handling Building Systems - Unit 2 Ess Radwaste Systems - Unit 2 Non Condenstate Storage Systems - Unit 2 Non Containment Building Systems - Unit 2 Non Diesel Generator Systems - Unit 2 Non Full Flow Areas Systems - Unit 2 Non Intake Systems - Unit 2 Non Penetration Building Systems - Unit 2 Non Safety Equipment Building Systems - Unit 2 Non Turbine Bldg Equip to 9 ft - Unit 2 Struct Condensate Storage Area - Unit 2 Struct Containment Building - Unit 2 Struct Control Building - Unit 2 Struct Diesel Generator Building - Unit 2 Struct Fuel Handling Building - Unit 2 Struct Full Flow Building - Unit 2 Struct Intake Structure - Unit 2 Struct Penetration Building - Unit 2 Struct Radwaste Building - Unit 2 Struct Safety Equipment Building - Unit 2 Struct Tunnels - Unit 2 Struct Turbine Building - Unit 2 Ess Auxilary Control Systems - Unit 3 Ess Fuel Handling Building Systems -Unit 3 Page 1 of 2

SONGS Plant System and Structure List Unit 3 Type System Name or Description Ess Radwaste Systems - Unit 3 Non Condenstate Storage Systems - Unit 3 Non Containment Building Systems - Unit 3 Non Diesel Generator Systems - Unit 3 Non Full Flow Areas Systems - Unit 3 Non Intake Systems - Unit 3 Non Penetration Building Systems - Unit 3 Non Safety Equipment Building Systems - Unit 3 Non Turbine Bldg Equip to 9 ft - Unit 3 Non Turbine Generator to 63 ft - Unit 3 Struct Condensate Storage Tank Area - Unit 3 Struct Containment Building - Unit 3 Struct Control Building - Unit 3 Struct Diesel Generator Building - Unit 3 Struct Fuel Handling Building - Unit 3 Struct Full Flow Building - Unit 3 Struct Intake Structure - Unit 3 Struct Penetration Building - Unit 3 Struct Radwaste Building - Unit 3 Struct Safety Equipment Building - Unit 3 Struct Tunnels - Unit 3 Struct Turbine Building - Unit 3 Page 2 of 2

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 Appendix B Spent Fuel Shipping Schedule

SONGS Unit 2 & Unit 3 Spent Fuel Shipping Schedule 2024 DOE Acceptance 2016 2668 792 3460 2015 2668 792 3460 33 0 0 0 0 0 0 2016 2668 792 3460 33 0 0 0 0 0 0 2017 2668 792 3460 33 768 24 0 0 0 0 2018 1900 1560 3460 57 1,536 48 0 0 0 0 2019 364 3096 3460 105 364 13 0 0 0 0 2020 0 3460 3460 118 0 0 0 0 0 0 2021 0 3460 3460 118 0 0 0 0 0 0 2022 0 3460 3460 118 0 0 0 0 0 0 2023 0 3460 3460 118 0 0 0 0 0 0 2024 0 3460 3460 118 0 0 0 0 0 0 2025 0 3460 3460 118 0 0 0 0 0 0 2026 0 3460 3460 118 0 0 0 0 0 0 2027 0 3460 3460 118 0 0 0 0 0 0 2028 0 3460 3460 118 0 0 0 0 0 0 2029 0 3460 3460 118 0 0 0 0 0 0 2030 0 3460 3460 118 0 0 48 48 96 4 2031 0 3364 3364 114 0 0 192 96 288 12 2032 0 3076 3076 102 0 0 120 120 240 10 2033 0 2836 2836 92 0 0 0 96 96 4 2034 0 2740 2740 88 0 0 112 120 232 8 2035 0 2508 2508 80 0 0 96 96 192 6 2036 0 2316 2316 74 0 0 128 96 224 7 2037 0 2092 2092 67 0 0 0 0 0 0 2038 0 2092 2092 67 0 0 96 128 224 7 2039 0 1868 1868 60 0 0 96 96 192 6 2040 0 1676 1676 54 0 0 96 96 192 6 2041 0 1484 1484 48 0 0 0 0 0 0 2042 0 1484 1484 48 0 0 96 96 192 6 2043 0 1292 1292 42 0 0 96 96 192 6 2044 0 1100 1100 36 0 0 96 96 192 6 2045 0 908 908 30 0 0 128 96 224 7 2046 0 684 684 23 0 0 96 128 224 7 2047 0 460 460 16 0 0 96 230 326 II 2048 0 134 134 5 0 0 0 0 0 0 2049 0 134 134 5 0 0 134 0 134 5 2050 0 0 0 0 0 0 0 0 0 0

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 Appendix C Detailed Project Schedule

SONGS 2 & 3 Detailed Project Schedule Prompt DECON, DOE Repository Opens 2024 ID Task Name Duration start 2 3 4 5 6 7 8 910111213 41516171819 0 1 2 3 4 5 7 8 9 1 7 9 1 1 Post-Shutdown Spent Fuel Management 9982 days 06107/20131 V

2 Spent Fuel Shipping Complete - Unit 1 0 days 12131/203 41k112/31 3 Spent fuel :Shipping Complete - Units 2 &3 0 days 12/31/2049 12131/2049 12/31 4 SNF Pd I - Spent Fuel Management Transition 149 days 0610712013 12/3112013w 5 SNF Pd 1 Begins 0 days 06/07/2013 06/07/20i-13 *e7 6 Security Enhancements 45 days 10/31/2013 12/31/2013 7 Design and Fabricate Spent Fuel Canisters 120 days 06/07/2013 11/21/2013 8 Post Fukushima Modifications - Unit 2 148 days 06/07/2013 12/31/2013 9 Post Fukushima Modifications - Unit 3 148 days 06/07/2013 12/31/2013 10 Cyber Security Modifications 148 daysl 06/07/2013 12/31/2013 11 SNF Pd 1 Ends 0 days 01/01/2014 01/01/2014 'Ah-t v

11 onr ~- op.n. rue. iranarur rr1 U)' inuring.

ru 2u i0 ainys 11 I..

SNFPdr - Spent Fum Transfer to Dry Storage I*I1 gayl -e 13 SNF Pd 2 Begins 0 days 01/01/2014 01/01/2014 .J~11 14 Security Enhancements 60 days 01/0212014 03/2612014 15 Prepare Irradiated Fuel Management Plan 118 days 01/0212014 0611412014 16 Decay Heat Analysis 85 days 01/02/2014 04/30/2014 17 Zirconium Fire and Shine Analysis 42 days 01/02/2014 0212812014 18 Issue Irradiated Fuel Management Plan 0 days 09/16/2014 0911612014 19 NRC Review of Irradiated Fuel Management Plan 82 days 09/17/2014 01/08/2015 20 ISFSI Expansion 513 days 01/02/2014 12119/2015 21 Select Dry Storage System Canister Design and Vendor 30 days 02/12/2014 22 ISFSI Pad Study 220 days 12/06/2014 Design IiSI-St xpansion 120 days 06/24/2014 12/0612014 24 ISFSI Permit Approved By California Coastal Commission 0 days 04/1112015 04/11/2015 25 Construct ISFSI Expansion 180 days 04114/2015 12/19/2015 26 Canister Purchase, Fabrication and Fuel Tranfer 1170 days 12/0912014 06/0112019 U UP 27 Purchase Spent Fuel Canisters and AHSMs - Unit 2 220 days 12/09/2014 10112015 28 Purchase Spent Fuel Canisters and AHSMs - Unit 3 220 days 12/09/2014 10/10/2015 29 Load Spent Fuel Canisters and Transfer to ISFSI - Unit 2 900 days 12/22/2015 06/01/2019 30 Load Spent Fuel Canisters and Transfer to ISFSI - Unit 3 900 days 12/22/2015 06/01/2019 31 Unit 2 Spent Fuel Pool Empty 0 days 06/01/2019 06/01/2019 32 Unit 3 Spent Fuel Pool Empty 0 days 06/01/2019 06/01/2019 33 SNF Pd 2 Ends 0 days 06/01/2019 06/01/2019 6121 34 SNF Pd 3 - Dry Storage During Decommissioning - Units 1, 2 and 3 3265 days 06/01/2019 12/05/2031 35 SNF Pd 3 Begins 0 days 06/01/2019 06/01/2019 36 SNF Pd 3 Ends 0 days 12/0512031 12/05/2031 37 SNF Pd 4 - Dry Storage Only - Units 1, 2 and 3 1061 days 12/05/2031 12/31/2035 38 SNF Pd 4 Begins 0 days 12/05/2031 12/05/2031 39 SNF Pd 4 Ends 0 days 12/31/2035 12/31/2035 12/31 40 SNF Pd 5 - Dry Storage Only - Units 2 and 3 3654 days 1213112035 12/31/2049 41 SNF Pd 5 Begins 0 days 12/31/2035 12/31/2035 12/31 42 SNF Pd 5 Ends 0 days 12/31/2049 12/31/2049 12/31 43 SNF D&D Pd I - ISFSI D&D Planning 90 days 12/31/2049 05/04/2050 44 SNF D&D Pd 1 Begins 0 days 12/31/2049 12/31/2049 12/31 45 Preparation and NRC Review of License Termination Plan 90 days 01/01/2050 05/06/2050 46 SNF D&D Pd 1 Ends 0 days 05/06/2050 05/06/2050 47 SNF D&D Pd 2 - ISFSI O&D 350 days 05/06/2050 09108/2051 Ft;

SONGS 2 & 3 Detailed Project Schedule Prompt DECON, DOE Repository Opens 2024 1121314 15 61718 191o0111I121t3114115lt6117118119120121122J231241251261271281291301311321333451361371839140114 IDrI5i(Name I& Duration~BY~

49 Install GARDIAN Bulk Assay System 30 days 05/07/20501 06117/2050 50 Decon AHSMs 90 days 05/0712050 09/0912050 51 Final Status Survey of ISFSI 120 days 05/28/2050 11/11/2050 52 Clean Demolition of ISFSI AHSMs and Pad 145 days 09/10/2050 03/31/2051 53 Clean Demolition of ISFSI Support Structures 120 days 10115/2050 03/31/2051 54 Restore ISFSI Site 55 days 04/01/2051 06/16/2051 55 Preparation of Final Report on Decommissioning and NRC Review 60 days 06/17/2051 09/08/2051 56 SNF D&D Pd 2 Ends - License Termination Complete 0 days 09108/20511 09/08/2051 57 Post-Shutdown Spent Fuel Management Complete 0 days 1 09108/2051 09/08/2051

-J 4 - - - 4 ~ 4 58 Part 0 License Termination 5102 days 06/07/2013 12/24/2032 M' 0

'-4 59 Announcement of Cessation of Operations (June 7, 2013) 0 days 1"'

60 Decon Pd 1 - Transition to Decommissioning 149 days w Decon Pd 1 tBegins 0 days 06/0712013 06/07/2013 &-An, 62 Certification of Permanent Cessation Submitted to NRC (June 12, 2013) 0 days 06/0712013 06/0712013 *,'

63 Defuel Unit 3 Reactor 15 days 06/0712013 06/2712013 64 Defuel Unit 2 Reactor 15 days 06/07/2013 06/27/2013 65 Notification of Permanent Fuel Removal (July 23, 2013) 0 days 06/27/2013 06/2712013 6/27 66 Disposition of Legacy Wastes 60 days 07/19/2013 10/1012013 67 Decon Pd 1 Ends 0 days 01/01/2014 01/0112014 11 68 Decon Pd 2 - Decommissioning Planning and Site Modifications 389 days 111/2014 06/30/2015 69 Decon Pd 2 Begins 0 wks 01/01/2014 01/0112014 111 70 Preparation of Decommissioning License Documents 340 days 01/02/2014 04/22/2015 71 Develop Certified Fuel Handler Program 340 days 01/02/2014 04/22/2015 72 Prepare Post-Shutdown QA Plan 340 days 01/02/2014 04/22/2015 73 Prepare Post-Shutdown Security Plan 340 days 01/02/2014 04122/2015 74 Prepare Post-Shutdown Fire Protection Plan 340 days 01/02/2014 04/22/2015 75 Prepare Defueled Radiation Protection Manual 340 days 0110212014 04/22/2015 76 Prepare Preliminary Defueled Technical Specifications 63 days 01/02/2014 03/29/2014 77 NRC Deliverables 364 days 01/02/2014 05/26/2015 78 Prepare Defueled Safety AnalysisReport (OSAR) 311days 01/021201403/1212015 79 Submit DSAR to NRC 0 days 03/12/2015 03/12/2015 3/12 80 Implement Technical Specification Modifications 30 days 03/1312015 04/2312015 81 Prepare Post-Shutdown Emergency Preparedness Plan 304 days 01/02/2014 03/03/2015 82 Submit Emergency Plan to NRC 0 days 03/03/2015 03/0312015 83 NRC Review of Emergency Plan 60 days 03/04/2015 05/2612015 84 Prepare Post-Shutdown Decommissioning Activities Report (PSDAR) 121 days 01/02/2014 06/19/2014 85 Submit PSDAR to NRC 0 days 06/19/2014 06/19/2014 19 86 NRC Review ofPSDAR 90 days 06120/2014 10/23/2014 87 Public Meeting on PSDAR 30 days 08/01/2014 09/11/2014 88 Prepare Decommissioning Cost Estimate (DCE) 160 days 01/02/2014 08/13/2014 89 Submit DCE to NRC 0 days 06/13/2014 08/1312014 13 90 NRC Review of Decommissioning Cost Estimate 90 days 08/14/2014 12/17/2014 91 Commencement of Major Decommisisoning Activities Allowable 0 days 10123/2014 10/23/2014 0/23 92 Respond to NRC quesitons on PSDAR 220 days 06/20/2014 04/23/2015 93 Disposition of Legacy Wastes 220 days 01/02/2014 11/0512014 94 Contract Award for Historic Site Assessment and Site Characterization 0 wks 01/1612014 01/16/2014 1116

SONGS 2 & 3 Detailed Project Schedule Prompt DECON, DOE Repository Opens 2024 ID ITask Name DurationI Start I Finish 3334135136137138139140*1 1112 31415 1 6171 191101111121t3114115116117118119120121122123124l25t26127128129130131132 95 Perform Historic Site Assessment and Site Characterization 180 days 01/17/2014 09/25/2014 96 Planning and Design For Cold and Dark 90 days 02101/2014 06/06/2014 97 Implement Cold and Dark (Repower Site) 275 days 06107/2014 06/26/2015 98 Install 12kV Service Line to Power Temporary Power Ring 90 days 02/21/2015 06/2612015 I 99 Drain and De-Energize Non-Essential Systems (DEC Process) 260 days 01/02/2014 12/3112014 100 Select Decommissioning General Contractor (DGC) 318 days 04/1112014 06/30/2015 101 Spent Fuel Pool Isolation 318 days 04/1112014 06/3012015 I 102 Design Spent Fuel Pool Support System Modifications 160 days 04/11/2014 11/20/2014 103 Design Control Room Relocation 125 days 04/1112014 10/02/2014 104 Design Spent Fuel Security System Modifications 130 days 04/111/2014 10/09/2014 105 Install Spent Fuel Pool System Modifications - Unit 2 66 days 11/21/2014 02/20/2015 106 Install Spent Fuel Pool System Modifications - Unit 3 66 days 02/21/2015 05/23/2015 107 Spent Fuel Pool Island System Training 10 days 05126/2015 06/0612015 108 Implement Control Room Modifications 185 days 10/03/2014 06/18/2015 109 Implement Spent Fuel Pool Security Modifications 180 days 10/10/2014 06/1812015 110 Transition Project Modifictations 262 days 06/28/2014 06/30/2015 111 DGC Contract Award 0 days 06/30/2015 06/30/2015 6/30 112 Decon Pd 2 Ends 0 wks 06/30/2015 06/30/2015 0 113 Decon Pd 3 - Decommissioning Preparations and Reactor Internals Segments 1024 days 06/3W2015 0610112019 114 Decon Pd 3 Begins 0 days 06/3012015 06/30/2015 0 115 DGC Mobilization and Planning 160 days 0710112015 02/09/2016 116 Prepare Integrated Work Sequence and Schedule for Decommissioning 90 days 07/01/2015 11/0312015 117 Prepare Detailed Work Procedures for Decommissioning 160 days 07/01/2015 02/09/2016 118 Planning and Design of Primary System Decontamination 135 days 07/01/2015 01/05/2016 119 Planning and Design of Infrastructure Improvements 60 days 07/0112015 09/22/2015 120 Design Containment Access Modifications 60 days 07/01/2015 09/22/2015 121 System Decon 400 days 01/0612016 07118/2017 122 Perform Primary System Decon- Unit 2 140 days 01/0612016 07/19/2016 123 Perform Primary System Decon- Unit 3 140 days 07/20/2016 01/31/2017 124 Hot Spot Decontamination - Unit 2 60 days 02/01/2017 04/25/2017 125 Hot Spot Decontamination - Unit 3 60 days 0412612017 07/18/2017 126 Rx Internals Removal Preparations 255 days 09123/2015 09113/2016 127 Modify Containment Access- Unit 2 90 days 09/2312015 01/26/2016 128 Modify Containment Access- Unit 3 90 days 01/27/2016 05/31/2016 129 Remove and Dispose of Missle Shields - Unit 2 30 days 01/27/2016 03/08/2016 130 Remove and Dispose of Reactor Head - Unit 2 45 days 03/0912016 05/10/2016 131 Remove and Dispose of Missle Shields - Unit 3 30 days 06/01/2016 07/12/2016 132 Remove and Dispose of Reactor Head - Unit 3 45 days 07/13/2016 09/13/2016 133 Reactor Internals Segmentation Planning and Implementation 1020 days 07/01/2015 0S/28/2019 134 Finalize Residual Radiation Inventory (Rx Vessel & Internals) 65 days 07/01/2015 09/29/2015 135 Prepare Activity Specification for Rx Vessel and Internals Segmentation 120 days 09/30/2015 03/15/2016 136 Select Shipping Casks and Obtain Shipping Permits 60 days 03/16/2016 06/07/2016 137 Design, Specify, and Procure Special Items and Materials 175 days 03/16/2016 11115=2016 138 Purchase Dry Storage Modules for GTCC Waste - Unit 2 90 days 07/01/2015 11/03/2015 139 Purchase Dry Storage Modules for GTCC Waste - Unit 3 90 days 1 07/01/2015 11103/2015 I iI1 r .- ~. osys r -~1--~w~-l

-i 1,ioiLu]o I F I 02/07/2017 I

- - -....... ou 140 Test Special Cutting and Handling Equipment and Irain uperators 60udays 11I/16/2016I i mnremais rinauze Internals yasser Segmenting ana Vessel uerass oegmenung Details - Unit 2

- Unix I 31.) uays - -U/*UI I U-11IIvUI1 141 Finalize and ,30udays

SONGS 2 & 3 Detailed Project Schedule Prompt DECON, DOE Repository Opens 2024 ID Task Name [.Duration Start Finish [112131415 6 7 8 9 5 1I 01 1121314115116117118119b'0121122123124t25271281291301311321331341351367138139 142 Segment, Package and Ulspose or Reactor Internals - Unit 2 24u days U,03Zzuu I/ U02L0/2U18 L 143 Transfer Internals Segmentation Equipment to Unit 3 60 days 02/21/2018 05/15/2018 144 Finalize Internals and Vessel Segmenting Details - Unit 3 30 days 05/16/2018 06/26/2018 145 Segment, Package and Dispose of Reactor Internals - Unit 3 240 days 06/27/2018 05/28/2019 146 Construct new change rooms, hot laundry, in-plant laydown areas 90 days 01/29/2019 06/01/2019 147 Procure Non-Engineered Standard Equipment 120 days 12/18/2018 06/01/2019 148 Decon Pd 3 Ends 0 wks 06/01/2019 06101/2019 oil 149 Decon Pd 4 - Plant Systems and Large Component Removal 865 days 06/01/2019 09124/2022 150 Decon Pd 4 Begins 0 days 06/01/2019 06/01/2019 6/11 151 Upgrade Rail Spur 120 days 06/04/2019 11/16/2019 152 Install GARDIAN Bulk Assay System 30 days 06/04/2019 07/13/2019 153 Non Essential System Removal 640 days 07/16/2019 12/25/2021 154 Scaffolding for Non-Essential System Removal 120 wks 07/16/2019 10/30/2021 155 Asbestos Abatement for Non-Essential Systems Removal - Unit 2 60 wks 07/16/2019 09/05/2020 156 Lead Abatement for Non-Essential Systems Removal - Unit 2 60 wks 07/30/2019 09/19/2020 157 Remove, Package and Dispose of Non-Essential Systems - Unit 2 60 wks 09/10/2019 10/31/2020 158 Asbestos Abatement for Non-Essential Systems - Unit 3 60 wks 09/08/2020 10/30/2021 159 Lead Abatement for Non-Essential Systems - Unit 3 60 wks 09/22/2020 11/13/2021 160 Remove, Package and Dispose of Non-Essential Systems - Unit 3 60 wks 11/03/2020 12/25/2021 161 Remove Underground Diesel Tank - Unit 2 30 days 07/16/2019 08/24/2019 162 Remove Underground Diesel Tank - Unit 3 30 days 08/27/2019 10/05/2019 163 Fuel Pool Closure 300 days 06/0412019 07126/2020 164 Remove and Dispose of Spent Fuel Storage Racks - Unit 2 90 days 06/04/2019 10/05/2019 165 Remove and Dispose of Spent Fuel Storage Racks - Unit 3 90 days 10/08/2019 02/08/2020 166 Remove and Dispose of Legacy Class B and C Waste - Unit 2 30 days 10/08/2019 11/16/2019 167 Remove and Dispose of Legacy Class B and C Waste - Unit 3 30 days 11/19/2019 12t28/2019 168 Drain Spent Fuel Pool and Process Liquid Waste - Unit 2 24 wks 11119/2019 05/02/20201 169 Drain Spent Fuel Pool and Process Liquid Waste - Unit 3 24 wks 12/31/2019 06/13/2020 170 Segment, Package and Dispose of Spent Fuel Pool Island Equipment 30 days 06/16/2020 07/25/2020 171 Segment and Dispose of Fuel Pool Bridge Crane - Unit 2 30 days 10/08/2019 11/16/2019 172 Segment and Dispose of Fuel Pool Bridge Crane - Unit 3 30 days 11/19/2019 12/28/2019 173 Essential Systems Removal 180 days 00/16/2020 02/20/2021 I 174 Flush and Drain Essential Systems Following Fuel Pool Closure 30 days 06116/2020 07/25/2020 175 Scaffolding for Essential System Removal 30 wks 07/28/2020 02/20/2021 176 Asbestos Abatement for Essential Systems 30 wks 07/28/2020 02/20/2021 0

177 178 Lead Abatement for Essential Systems Removal Remove, Package and Dispose of Essential Systems 30 wks 30 wks 07/28/2020 07/28/2020 02/20/2021 02/20/2021 0

179 Removal and Disposal of Spent Resins, Filter Media and Tank Sludge 30 days 01/12/2021 02/20/2021 180 Large Component Removal 865 days 06/04/2019 09/24/2022 181 Reactor Vessel Insulation Removal and Disposal - Unit 2 90 days 06/04/2019 10/05/2019 182 Segment, Package and Dispose of Reactor Pressure Vessel - Unit 2 260 days 06/04/2019 05/30/2020 183 Transfer Rx Vessel Segmentation Equipment to Unit 3 45 days 06/02/2020 08/01/2020 184 Procure Replacement Non-Engineered Standard Equipment 30 days 06/02/2020 07/11/2020 185 Reactor Vessel Insulation Removal and Disposal - Unit 3 90 days 08/04/2020 12/0&/2020 186 Segment, Package and Dispose of Reactor Pressure Vessel - Unit 3 260 days 08/04/2020 07/31/2021 187 Remove and Dispose of Steam Generators - Unit 2 240 days 06/02/20201 05/01/2021 emve andl Dispose of Pressurizer - Unit 2 60 days 1 05/4/Z2021 07/24r2021

SONGS 2 & 3 Detailed Project Schedule Prompt DECON, DOE Repository Opens 2024 iD !Task Name Duration Start Finish 11121:14151617181 SITi I1,[1213114115116117118119120121 I

Ih3 I

7319t041 22123t1245126l271281291013132133134b35131 189 Remove ana uDspose of Steam tienerators - Unit 3 24U days U1u0/03/22I U11U07/02r, 190 Remove and Dispose of Pressurizer - Unit 3 60 days 07/05/2022 09/24/2022 191 Remove and Dispose of Turbine Gantry Crane - Unit 2 140 days 05/04/2021 11/13/2021 192 Remove and Dispose of Turbine Gantry Crane - Unit 3 140 days 11/16/2021 05/28/2022 193 Prepare License Termination Plan 26 wks 03101/2022 08/27/2022 194 Decon Pd 4 Ends 0 days 09/24/2022 09/24/2022 9/124 195 Decon Pd 5 - Building Decontamination 470 days 09124/2022 07/13/2024 196 Decon Pd 5 Begins 0 days 09/24/2022 09/24/2022 197 Unit 3 305 days 09/27/2022 11/25/2023 198 Decon Containment Building - Unit 3 150 days 09/27/2022 04/22/2023 199 Decon Penetration Building - Unit 3 85 days 04/25/2023 08/19/2023 200 Decon Safety Equipment and MSIV Building - Unit 3 70 days 08/22/2023 11/25/2023 201 Decon Fuel Handling Building - Unit 3 65 days 09/27/2022 12/24/2022 202 Decon Turbine Building - Unit 3 30 days 09/27/2022 11/05/2022 203 Unit 2 425 days 11/08/2022 06122/2024 204 Decon Containment Building - Unit 2 150 days 04/25/2023 11/18/2023 205 Decon Penetration Building - Unit 2 85 days 11/21/2023 03116/2024 206 Decon Safety Equipment and MSIV Building - Unit 2 70 days 03119/2024 06/22/2024 207 Decon Fuel Handling Building - Unit 2 65 days 12/27/2022 03/25/2023 208 Decon Turbine Building - Unit 2 30 days 11/08/2022 12/17/2022 209 Common 470 days 09/27/2022 07113/2024 210 Decon Auxiliary Radwaste Building - Common 120 days 03/28/2023 09/09/2023 211 Decon Auxiliary Control Building - Common 20 days 09/12/2023 10/07/2023 212 Decon Condensate Area and Tunnels - Units 2 and 3 80 days 09112/2023 12/30/2023 213 Excavate. Remove and Dispose of Yard Area Drains 60 days 01/02/2024 03/23/2024 214 Remove and Dispose of Contaminated Sumps, Trenches and Pavement 60 days 01/02/2024 03/23/2024 215 Remove and Dispose of Radiologically Contaminated Soil 30 days 03/26/2024 05/04/2024 216 Dispose of Contaminated Decon Equipment and Tooling 15 days 06/25/2024 07/13/2024 217 Radiological Survey of Structures During Decon 410 days 09/2712022 04/20/2024 218 Decon Pd 5 Ends 0 days 07/13/2024 07/13/2024 219 Decon Pd 6 - License Termination During Demolition 2206 days 07/13/2024 12/24/2032 220 Decon Pd 6 Begins 0 days 07/13/2024 07/13/2024 7/14 221 Final Status Survey 1771 days 07/13/2024 04/25/2031 222 ORISE Verification and NRC Approval 18 mons 05/17/2031 10/01/2032 223 Prepare Final Report of Dismantling Program 60 days 10/02/2032 12/24/2032 224 Decon Complete - Partial License Termination 0 days 12/24/2032 12/24/2032 225 I Decon Pd 6 Ends 0 days 12/24/2032 12/24/2032 226 227 Site Restoration SK Pd I -Transition to Site Restorauon 10052 daysI 38daaysl 0810712013 OW07120131 12/16/2051 1I:

W3020 15uI p.It p

__________ II i I..

228 SR Pd 1 Begins 0 days 06/07/2013 06/07/2013 229 Mesa Site Phase I and II Site Assessment 60 days 04/11/2014 07/03/2014 230 Disposition Hazardous Waste from Mesa Site 30 days 07/04/2014 08/14/2014 231 Mesa Site Characterization Survey 120 days 11/07/2014 04/23/2015 232 Fuel Cancellation Expense 60 days 01/21/2014 04/12/2014 233 SR Pd 1 Ends 0 days 06/30/2015 06/30/2015 , /30 234 SR Pd 2 - Building Demolition During Decommissioning 530 days 06/30/20151 0711/2017 S5RPit 2 Begins o daysl OW/0/2U1,5 06/r=/015

SONGS 2 & 3 Detailed Project Schedule Prompt DECON, DOE Repository Opens 2024

/D-TaskNarne_ .. Duration S,tan I Fi..nish^i 1 23J4 5 617189 1121314151617l119*1*2O2l 23124125726L27281291301[32[33134135361373813941 Prepare Site Restoration Uemolition I-an ano scneouie 12U days 07/U0/2015 12Y15120~15 237 Obtain Required Permits For Mesa, South Access and South Yard 90 days 12/1612015 04/19/2016 238 South Access for Decommissioning 150 days 04/2012016 11115/2016 239 Demolish Service Building (K-10, 20, 30) 60 days 04/20/2016 07/12/2016 240 Demolish South Security Processing Facility (K-70) 30 days 07113/2016 08/23/2016 241 Demolish Staging Warehouse 30 days 08/24/2016 10/04/2016 242 Demolish Administration Building (K-40/50) 30 days 10/05/2016 11115/2016 243 South Yard Facility 105 days 04120/2016 09/13/2016 244 Demolish South Yard Area Buildings T-10, 20, 60 and Haz Mat. 90 days 04/20/2016 08/23/2016 245 Demolish REMS Staging Pad 15 days 08/24/2016 09/13/2016 246 Mesa 320 days 04/20/2016 07/11/2017 247 Demolish Mesa Buildings 140 days 04120/2016 11/01/2016 248 Remove Underground Fuel Storage Tanks 30 days 11/02/2016 12/13/2016 249 Demolish Mesa Roads and Parking Lots 60 days 12/14/2016 03/07/2017 250 Finish Grading and Re-vegetate Mesa Site 90 days 03/08/2017 07/11/2017 251 Mesa Area Cleared for Easement Termination 0 days 07/11/2017 07/11/2017 7111 252 SR Pd 2 Ends 0 days 07/11/2017 07/11/2017 1,7111 253 SR Pd 3 - Subsurface Demolition Engineering and Permitting 1250 days 10101/2019 07/13/2024 254 SR Pd 3 Begins 0 days 10/01/2019 10/01/2019 255 Hydrogeologic Investigation and Outfall Conduit Survey 120 days 10/01/2019 03/14/2020 256 Subsurface Structure Removal Engineering Planning and Design 120 days 03/17/2020 08/29/2020 257 Environmental Impacts Analyses for Lease Termination Activities 700 days 09/01/2020 05/06/2023 258 Final Site Grading and Shoreline Protection Engineering Planning and Design 90 days 05/09/2023 09/09/2023 259 Obtain Required Permits and Approvals 220 days 09/12/2023 07/13/2024 260 SR Pd 3 Ends 0 days 07/13/2024 07/13/2024 261 SR Pd 4 - Building Demolition to 3 Feet Below Grade 1110 days 07/13/2024 10/14/2028 262 SR Pd 4 Begins 0 days 07/13/2024 07/13/2024 114 263 Procure Building Demolition Equipment 1080 days 07/16/2024 09/02/2028 264 Demolition Preparations 80 days 0711612024 11/02/2024 265 Install Temporary Structures 30 days 07/16/2024 08/24/2024 266 Install Erosion and Sediment Controls 20 days 07/16/2024 08/1012024 267 Remove Cathodic Protection Trench 60 days 08/13/2024 11/02/2024 268 Remove Protected Area Security Fencing 45 days 08/13/2024 10/12/2024 269 Remove Protected Area Pavement 20 days 08/13/2024 09/07/2024 270 Unit 3 870 days 07/16/2024 11113/2027 271 Detension and Remove Unit 3 Containment Builidng Tendons 240 days 07/16/2024 06/14/2025 272 Demolish Diesel Generator Building - Unit 3 60 days 07/16/2024 10/05/2024 273 Demolish Condensate Building and Transformer Pads - Unit 3 60 days 10/08/2024 12/28/2024 274 Demolish Full Flow Area and Turbine Building - Unit 3 140 days 12/31/2024 07/12/2025 275 Demolish Unit 3 Fuel Handling Building to 3-Feet Below Grade 120 days 06/30/2026 12/12/2026 276 Demolish Penetration Building - Unit 3 60 days 06/30/2026 09/19/2026 277 Demolish Safety Equipmentand MSIV Building - Unit 3 60 days 07/15/2025 10104/2025 278 Demolish Unit 3 Containment Building to 3-Feet Below Grade 240 days 12/15/2026 11/13/2027 279 Unit 2 1020 days 11119/2024 10114/2028 280 Detension and Remove Unit 2 Containment Builidng Tendons 240 days 05/16/2026 281 Demolish Diesel Generator Building - Unit 2 60 days 1 02/08/2025 282 Demolish Condensate Building and Transformer Pads - Unit 2 60 days I

SONGS 2 & 3 Detailed Project Schedule Prompt DECON, DOE Repository Opens 2024 iO Task Name Duration Start Finish 11213 14 1516171819110111112113114115t 6117]tI 0Ol2t1221231412512612718L2913o0313213313413513371381914114; 283 uemolish iull i-ow Area and I urbine Uuilding - Uni 2 140 days U5I11OILU2O 1]11ii ULO 284 Demolish Unit 2 Fuel Handling Building to 3-Feet Below Grade 120 days 12/1512026 05r29/2027 285 Demolish Penetration Building - Unit 2 60 days 06/01/2027 08/21/2027 286 Demolish Safety Equipment and MSIV Building - Unit 2 60 days 08124/2027 11113/2027 287 Demolish Unit 2 Containment Building to 3-Feet Below Grade 240 days 11/16/2027 10114/2028 288 Common 510 days 07116/2024 06127/2026 I 289 Demolish AWS Building 90 days 07/16/2024 11/16/2024 290 Demolish Building L-50 60 days 11/19/2024 02/08,2025 291 Demolish Building B-64/B-65 45 days 07/16/2024 09/14/2024 292 Demolish Building B-62/B-63 45 days 09/17/2024 11/16/2024 293 Demolish Outage Control Center 45 days 02/11/2025 04/12/2025 294 Demolish Building B-49/B-50 45 days 04/15/2025 06/14/2025 295 Demolish Building B-43/B-44 45 days 06/17/2025 08/16/2025 296 Demolish Auxiliary Radwaste Building - Common 160 days 05/06/2025 12/13/2025 297 Demolish Auxiliary Control Building - Common 160 days 11/18/2025 06127/2026 298 Remove Systems and Demolish Make-Up Demineralizer Structures 120 days 07/16/2024 12/28/2024 299 300 301 Install Concrete Plugs in Intake and Discharge Structures Demolish Intake and Discharge Structures to 3-Feet Below Grade SR Pd 4 Ends 90 days 60 days 0 days 08/27/2024 11/18/2025 10/14/2028 12/28/2024 02/07/2026 10/14/2028 q **N 18s 302 SR Pd 5 - Subgrade Structure Removal Below -3 Feet 820 days 10/14/2028 12/05/2031 P 303 SR Pd 5 Begins 0 days 10/14/2028 10114/2028 304 Procure Subsurface Structure Demolition Equipment 520 days 10/17/2028 10/11/2030 305 Install Sheet Piling and Excavation Shoring 120 days 10/17/2028 03/31/2029 306 Install Dewatering System and Effluent Treatment and Discharge Controls 60 days 04/01/2029 06/22/2029 307 Unit 3 Subsurface Structures 480 days 06/23/2029 0412612031 308 Demolish and Backfill Unit 3 Condensate Storage Area Below -3 Feet 30 days 06/23/2029 08/03/2029 309 Demolish and Backfill Unit 3 Diesel Generator Builidng Below -3 Feet 30 days 08/04/2029 09114/2029 310 Demolish and Backfill Unit 3 Fuel Handling Building Below -3 Feet 120 days 09/15/2029 03/01/2030 311 Demolish and Backfill Unit 3 Radwaste Building Below -3 Feet 120 days 03/02/2030 08/16/2030 312 Demolish and Backfill Unit 3 Turbine Building Structure Below 9 Ft Elevatiot 120 days 06/23/2029 12/07/2029 313 Demolish and Backfill Unit 3 Safety Equipment Building Below -3 Feet 90 days 12/08/2029 04/12/2030 314 Demolish and Backfill Unit 3 Penetration Area Below -3 Feet 60 days 04113/2030 07/05/2030 315 Demolish and Backfill Unit 3 Full Flow Building Below -3 Feet 60 days 07/06/2030 09/27/2030 316 Demolish and Backfill Unit 3 Containment Building Below -3 Feet 180 days 08/17/2030 04/25/2031 317 Unit 2 Subsurface Structures 480 days 06/23/2029 04/25/2031 318 Demolish and Backfill Unit 2 Condensate Storage Area Below -3 Feet 30 days 06/23/2029 08/03/2029 319 Demolish and Backfill Unit 2 Diesel Generator Builidng Below -3 Feet 30 days 08/04/2029 09/14/2029 I

320 Demolish and Backfill Unit 2 Fuel Handling Building Below -3 Feet 120 days 09/15/2029 03/01/2030 321 Demolish and Backfill Unit 2 Radwaste Building Below -3 Feet 120 days 03/02/2030 08/16/2030 322 Demolish and Backfill Unit 2 Turbine Building Structure Below 9 Ft Elevatiol 120 days 06/23/2029 12/07/2029 323 Demolish and Backfill Unit 2 Safety Equipment Building Below -3 Feet 90 days 12/08/2029 04/12/2030 I

324 Demolish and Backfill Unit 2 Penetration Area Below -3 Feet 60 days 04/13/2030 07/05/2030 325 Demolish and Backfill Unit 2 Full Flow Building Below -3 Feet 60 days 07/06/2030 09/27/2030 Demolish and Backfill Unit 2 Containment Building Below -3 Feet 180 days 08/17/2030 04/25/2031 327 Common Subgrade Structures 432 days 10/11/2030 328 Demolish and Backfill Intake Structure Inside Seawall Below -3 Feet 220 days 1 10/11/2030 Remove Off :Shore Intake and Outlall C~onduits 432 days 10/11/2036

SONGS 2 & 3 Detailed Project Schedule Prompt DECON, DOE Repository Opens 2024 ID ITask Name I Duration start Finish 112 3 14 1516 17 18 19110111112113114115116117118119 0131132133134[35136 01222123 24125126127128t29 7138139101114.

330 Remove Sheet Piling and Excavation Shoring 120 days 04/2612031 1011012031 331 Remove Dewatering System and Effluent Treatment 90 days 04/26/2031 08/29/2031 332 Finish Grading and Re-Vegetate Site 140 days 04/26/2031 11/07/2031 12/

333 Remove Temporary Structures 20 days 11/08/2031 12/05/2031 334 SR Pd 5 Ends 0 days 12/05/2031 12/05/2031 335 SR Pd 6 - Final Site Restoration and Lease Termination 420 days 05/06/2050 12/1512051 I 336 SR Pd 6 Begins 0 days 05/06/2050 05/06/2050 337 Obtain Required Permits and Approvals 60 days 05/07/2050 07/29/2050 338 Install Temporary Structures 10 days 07/30/2050 08/12/2050 339 Procure Site Restoration Equipment 265 days 07/30/2050 08/04/2051 340 Install Temporary Seawall or Coffer Dam 120 days 07/30/2050 01113/2051 341 Install Dewatering System and Effluent Treatment and Discharge Controls 45 days 11/12/2050 01/13/2051 342 Remove and Stockpile Existing Seawall Erosion Protection 10 days 07/30/2050 08/12/2050 343 Remove Unit 2 and 3 Seawall and Pedestrian Walkway 90 days 01/14/2051 05/19/2051 344 Remove Remaining Intake and Outfall Box Culvert 60 days 01/14/2051 04/0712051 345 Remove Temporary Seawall or Coffer Dam 90 days 04/08/2051 08/11/2051 346 Backfill and Compaction of Excavation 30 days 08/12/2051 09/22/2051 347 Remove Dewatering System and Effluent Treatment 20 days 05/20/2051 06/16/2051 348 Install Shoreline Erosion Control and Restoration Features 20 days 09/23/2051 10/20/2051 349 Remove Railroad Tracks, Rails and Ballast 60 days 05/20/2051 08/11/2051 350 Remove Gunite Slope Protection 110 days 07130/2050 12/30/2050 351 Remove Access Roads and Parking Lots 30 days 10/21/2051 12101/2051 352 Finish Grading and Re-Vegetate Site 60 days 09/23/2051 12/15/2051 353 Remove Temporary Structures 10 days 12/02/2051 12/15/2051 354 SR Pd 6 Ends 0 days 12/15/2051 12/15/2051 S12115 3 It-inal Easement i erminatlon Uoays 12/15/25u1 12 12./Z051 12115

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 Appendix D Detailed Cost Table

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total A. License Termination Decon Pd 1 Transition to Deconunissioning Distributed 1.05 Disposition of Legacy Wastes $0 $0 $9,153 $735 $0 $9,888 Distributed Subtotal $0 $0 $9,153 $735 $0 $9,888 Undistributed 1.01 Utility Staff $30,049 $0 $0 $0 $0 $30.049 1.05 Insurance $0 $0 $0 $5,352 $0 $5,352 1.07 NRC Decommissioning Fees $0 $0 $0 $1,349 $0 $1,349 1.08 Materials and Services $0 $0 $0 $1,007 $0 $1,007 1.10 Energy $0 $0 $0 $2,422 $0 $2,422 1.17 Association Fees and Expenses $0 $0 $0 $315 $0 $315 1.18 Utilities (Water, gas, phone) $0 $0 $0 $840 $0 $840 1.20 Non-Process Computers $0 $0 $0 $224 $0 $224 1.21 Telecommunications $0 $0 $0 $41 $0 $41 1.22 Personal Computers $0 $0 $0 $9 $0 $9 1.24 Environmental Permits and Fees $0 $0 $0 $818 $0 $818 Undistributed Subtotal $30,049 $0 $0 $12,378 $0 $42,426 Decon Pd I Subtotal $30,049 $0 $9,153 $13,113 $0 $52,315 Page 1 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Decon Pd 2 Decommissioning Planning and Site Modifications Distributed 2.01 Develop Certified Fuel Handler Program $143 $1 $0 $0 $36 $180 2.02 Prepare Post-Shutdown QA Plan $427 $1 $0 $0 $107 $535 2.03 Prepare Post-Shutdown Security Plan $427 $1 $0 $0 $107 $535 2.04 Prepare Post-Shutdown Fire Protection Plan $427 $1 $0 $0 $107 $535 2.05 Prepare Defueled Radiation Protection Manual $427 $1 $0 $0 $107 $535 2.06 Prepare Preliminary Defueled Technical Specifications $0 $0 $0 $135 $34 $169 2.07 Prepare Defueled Safety Analysis Report (DSAR) $1,279 $5 $0 $0 $321 $1,605 2.08 Implement Technical Specification Modifications $1,332 $5 $0 $0 $334 $1,671 2.09 Prepare Post-Shutdown Emergency Preparedness Plan $634 $1 $0 $0 $159 $793 2.10 NRC Review of Emergency Preparedness Plan $0 $0 $0 $105 $26 $131 2.11 Prepare Post-Shutdown Decommissioning Activities Report (PSDAR) $550 $1 $0 $0 $138 $688 2.12 NRC Review of Post-Shutdown Decommissioning Activities Report (PSDAR) $0 $0 $0 $105 $26 $131 2.13 Respond to NRC quesitons on PSDAR $34 $1 $0 $0 $9 $43 2.14 Prepare Decommissioning Cost Estimate (DCE) $1,429 $4 $0 $0 $358 $1,791 2.15 NRC Review of Decommissioning Cost Estimate $0 $0 $0 $105 $26 $131 2.16 Disposition of Legacy Wastes $0 $0 $16,457 $0 $4,114 $20,571 2.17 Perform Historic Site Assessment and Site Characterization $6,784 $838 $0 $0 $1,143 $8,765 2.18 Planning and Design For Cold and Dark $9.716 $90 $0 $0 $2,451 $12,257 2.19 Implement Cold and Dark (Repower Site) $16,141 $17,860 $0 $0 $8,500 $42,501 2.20 Install 12kV Service Line to Power Temporary Power Ring $0 $0 $0 $5,250 $1,313 $6,563 2.21 Drain and De-Energize Non-Essential Systems (DEC Process) $822 $183 $1,485 $0 $623 $3,114 2.22 Select Decommissioning General Contractor $645 $8 $0 $0 $163 $817 2.23 Design Spent Fuel Pool Support System Modifications $622 $8 $0 $0 $157 $787 2.24 Design Control Room Relocation $601 $7 $0 $0 $152 $760 2.25 Design Spent Fuel Security System Modifications $459 $5 $0 $0 $116 $580 2.26 Install Spent Fuel Pool System Modifications - Unit 2 $1,863 $4,101 $0 $0 $1,491 $7,456 2.27 Install Spent Fuel Pool System Modifications - Unit 3 $1,863 $4,101 $0 $0 $1,491 $7,456 2.28 Spent Fuel Pool System Modification Training $0 $0 $0 $273 $68 $341 2.29 Implement Control Room Modifications $1,004 $1,519 $0 $0 $631 $3,153 2.30 Implement Spent Fuel Pool Security Modifications $525 $795 $0 $0 $330 $1,650 2.31 Transition Project Modifications $0 $0 $0 $105 $26 $131 Page 2 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Distributed Subtotal $48,154 $29,538 $17,942 $6,077 $24,665 $126,376 Undistributed 1.01 Utility Staff $56,478 $0 $0 $0 $14,119 $70,597 1.02 Utility Staff HP Supplies $0 $1,781 $0 $0 $445 $2,226 1.03 Security Guard Force $2,087 $0 $0 $0 $522 $2,609 1.04 Security Related Expenses $77 $0 $0 $0 $19 $96 1.05 Insurance $0 $0 $0 $4,446 $1,111 $5,557 1.06 Site Lease and Easement Expenses $0 $0 $0 $470 $70 $540 1.07 NRC Decommissioning Fees $0 $0 $0 $2,390 $598 $2.988 1.08 Materials and Services $0 $3,208 $0 $0 $802 $4,010 1.09 DAW Disposal $0 $0 $295 $0 $74 $369 1.10 Energy $0 $0 $0 $6,338 $1,584 $7,922 1.13 Craft Worker Training $234 $0 $0 $0 $58 $292 1.14 Workers Compensation Insurance $0 $0 $0 $283 $71 $353 1.15 Community Outreach $1,638 $0 $0 $1,830 $867 $4,335 1.16 Property Tax $0 $0 $0 $2,350 $588 $2,938 1.17 Association Fees and Expenses $0 $2,350 $0 $0 $588 $2,938 1.18 Utilities (Water, gas, phone) $0 $738 $0 $0 $185 $923 1.20 Non-Process Computers $0 $157 $0 $0 $39 $196 1.21 Telecommunications $0 $157 $0 $0 $39 $196 1.24 Environmental Permits and Fees $0 $0 $0 $2,977 $744 $3,721 1.25 Decommissioning Advisor $0 $0 $0 $1,567 $392 $1,958 Undistributed Subtotal $60,513 $8,391 $295 $22,650 $22,915 $114,764 Decon Pd 2 Subtotal $108,667 $37,928 $18,237 $28,727 $47,581 $241,140 Page 3 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Decon Pd 3 Deconunissioning Preparations and Reactor Internals Segmentation Distributed 3.01 Prepare Integrated Work Sequence and Schedule for Decommissioning $952 $0 $0 $0 $238 $1,190 3.02 Prepare Detailed Work Procedures and Activity Specifications for Decommissioning $14,920 $70 $0 $0 $3,748 $18,738 3.03 Planning and Design of Primary System Decontamination $516 $4 $0 $0 $130 $649 3.04 Planning and Design Site Infrastructure Improvements $341 $4 $0 $0 $86 $431 3.05 Design Containment Access Modifications $557 $6 $0 $0 $141 $705 3.06 Primary System Decontamination - Unit 2 $1,447 $1,857 $2,228 $0 $1,383 $6,914 3.07 Primary System Decontamination - Unit 3 $1,447 $1,857 $2,228 $0 $1,383 $6,914 3.08 Hot Spot Decontamination - Unit 2 $580 $887 $743 $0 $552 $2,761 3.09 Hot Spot Decontamination - Unit 3 $580 $913 $743 $0 $559 $2,794 3.10 Modify Containment Access- Unit 2 $315 $611 $0 $0 $231 $1,157 3.11 Modify Containment Access- Unit 3 $315 $611 $0 $0 $231 $1,157 3.12 Remove and Dispose of Missle Shields - Unit 2 $206 $30 $81 $0 $79 $395 3.13 Remove and Dispose of Reactor Head - Unit 2 $879 $453 $2,463 $0 $949 $4,744 3.14 Remove and Dispose of Missile Shields - Unit 3 $437 $178 $3,375 $0 $997 $4,987 3.15 Remove and Dispose of Reactor Head - Unit 3 $879 $453 $2,463 $0 $949 $4,744 3.16 Finalize Residual Radiation Inventory $125 $0 $0 $287 $103 $516 3.17 Prepare Activity Specifications $7,328 $696 $0 $0 $2,006 $10,031 3.18 Select Shipping Casks and Obtain Shipping Permits $49 $0 $0 $0 $12 $62 3.19 Design, Specify, and Procure Special Items and Materials $972 $5,379 $0 $0 $1,588 $7,938 3.22 Test Special Cutting and Handling Equipment and Train Operators $1,157 $148 $0 $0 $326 $1,631 3.23 Finalize Internals and Vessel Segmenting Details - Unit 2 $212 $16 $0 $0 $57 $284 3.24 Segment, Package and Dispose of Reactor Internals - Unit 2 $5,669 $2,036 $62,661 $0 $17,591 $87,957 3.25 Transfer Internals Segmentation Equipment to Unit 3 $131 $19 $0 $0 $37 $187 3.26 Finalize Internals and Vessel Segmenting Details - Unit 3 $212 $16 $0 $0 $57 $284 3.27 Segment, Package and Dispose of Reactor Internals - Unit 3 $5,669 $2,036 $62,661 $0 $17,591 $87,957 3.28 Construct New Change Rooms, Hot Laundry, In-Plant Laydown Areas $0 $1,290 $0 $0 $194 $1,484 3.29 Procure Non-Engineered Standard Equipment $0 $5,454 $0 $0 $1,364 $6,818 Distributed Subtotal $45,893 $25,024 $139,643 $287 $52,583 $263,431 Undistributed 1.01 Utility Staff $79,350 $0 $0 $0 $19,837 $99,187 Page 4 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total 1.02 Utility Staff HP Supplies $0 $2,693 $0 $0 $673 $3,366 1.03 Security Guard Force $5,484 $0 $0 $0 $1,371 $6,855 1.04 Security Related Expenses $326 $0 $0 $0 $82 $408 1.05 Insurance $0 $0 $0 $8,000 $2,000 $10,000 1.06 Site Lease and Easement Expenses $0 $0 $0 $1,235 $185 $1,420 1.07 NRC Decommissioning Fees $0 $0 $0 $6,281 $1,570 $7,851 1.08 Materials and Services $0 $4,582 so $0 $1,145 $5.727 1.09 DAW Disposal $0 $0 $424 $0 $106 $529 1.10 Energy $0 $0 $0 $10,226 $2,556 $12,782 1.11 Decommissioning General Contractor Staff $62,219 $0 $0 $0 $15,555 $77,773 1.12 DGC HP Supplies $0 $1,558 $0 $0 $389 $1,947 1.13 Craft Worker Training $1,842 $0 $0 $0 $460 $2.302 1.14 Workers Compensation Insurance $0 $0 $0 $742 $186 $928 1.15 Community Outreach $4,303 $0 $0 $4,808 $2,278 $11,390 1.16 Property Tax $0 $0 $0 $6,175 $1,544 $7,719 1.17 Association Fees and Expenses $0 $6,175 $0 $0 $1,544 $7,719 1.18 Utilities (Water, gas, phone) $0 $1,106 $0 $0 $277 $1,383 1.19 Tools and Equipment $0 $182 $0 $0 $45 $227 1.20 Non-Process Computers $0 $412 $0 $0 $103 $515 1.21 Telecommunications $0 $412 $0 $0 $103 $515 1.22 Personal Computers $0 $0 $0 $89 $22 $111 1.24 Environmental Permits and Fees $0 $0 $0 $7,822 $1,955 $9,777 1.25 Decommissioning Advisor $0 $0 $0 $4,117 $1,029 $5,146 Undistributed Subtotal $153,524 $17,119 $424 $49,495 $55,017 $275,579 Decon Pd 3 Subtotal $199,417 $42,144 $140,067 $49,782 $107,600 $539,009 Page 5 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/20 13 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/20 13 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Decon Pd 4 Plant Systems and Large Component Removal Distributed 4.01 Upgrade Rail Spur $0 $0 $0 $3.277 $819 $4,096 4.02 Install GARDIAN System $0 $0 $0 $525 $131 $656 4.03 Scaffolding for Non-Essential System Removal $3,516 $1,144 $200 $0 $1,215 $6,075 4.04 Asbestos Abatement and Hazardous Waste Disposal for Non-Essential Systems - Unit $0 $0 $0 $1,050 $525 $1,575 4.05 Lead Abatement for Non-Essential Systems Removal - Unit 2 $2,287 $23 $411 $0 $1,361 $4,082 4.06 Remove, Package and Dispose of Non-Essential Systems - Unit 2 $33,512 $5,597 $31,969 $0 $17,769 $88,847 4.07 Asbestos Abatement and Hazardous Waste Disposal for Non-Essential Systems - Unit $0 $0 $0 $1,050 $525 $1,575 4.08 Lead Abatement for Non-Essential Systems - Unit 3 $2,287 $399 $411 $0 $1,549 $4,647 4.09 Remove, Package and Dispose of Non-Essential Systems - Unit 3 $36,851 $6,313 $36,610 $0 $19,944 $99,718 4.10 Remove Underground Diesel Tank - Unit 2 $111 $45 $0 $41 $49 $247 4.11 Remove Underground Diesel Tank - Unit 3 $111 $45 $0 $41 $49 $247 4.12 Remove and Dispose of Spent Fuel Storage Racks - Unit 2 $42 $36 $4.922 $0 $1.250 $6,250 4.13 Remove and Dispose of Spent Fuel Storage Racks - Unit 3 $42 $36 $4,922 $0 $1,250 $6,250 4.14 Remove and Dispose of Legacy Class B and C Waste - Unit 2 $0 $0 $500 $0 $125 $625 4.15 Remove and Dispose of Legacy Class B and C Waste - Unit 3 $0 $0 $500 $0 $125 $625 4.16 Drain Spent Fuel Pool and Process Liquid Waste - Unit 2 $557 $703 $0 $0 $315 $1,575 4.17 Drain Spent Fuel Pool and Process Liquid Waste - Unit 3 $557 $703 $0 $0 $315 $1,575 4.18 Segment. Package and Dispose of Spent Fuel Pool Island Equipment $11 $2 $107 $0 $30 $150 4.19 Segment and Dispose of Fuel Pool Bridge Crane -Unit 2 $85 $12 $168 $0 $66 $332 4.20 Segment and Dispose of Fuel Pool Bridge Crane - Unit 3 $85 $12 $168 $0 $66 $332 4.21 Flush and Drain Essential Systems Following Fuel Pool Closure $226 $181 $2,970 $0 $844 $4,221 4.22 Scaffolding for Essential System Removal $989 $322 $56 $0 $342 $1,708 4.23 Asbestos Abatement and Hazardous Waste Disposal for Essential Systems $0 $0 $0 $788 $394 $1,181 4.24 Lead Abatement for Essential Systems Removal $332 $58 $59 $0 $225 $674 4.25 Remove, Package and Dispose of Essential Systems $33,774 $5,869 $17,264 $0 $14,227 $71,134 4.26 Removal and Disposal of Spent Resins. Filter Media and Tank Sludge $90 $40 $7,425 $0 $1,889 $9,445 4.27 Reactor Vessel Insulation Removal and Disposal - Unit 2 $105 $12 $147 $0 $66 $331 4.28 Segment. Package and Dispose of Reactor Pressure Vessel - Unit 2 $1,044 $2,834 $29,313 $0 $8,298 $41,489 4.29 Transfer Rx Vessel Segmentation Equipment to Unit 3 $122 $18 $0 $0 $35 $175 4.30 Procure Replacement Non-Engineered Standard Equipment $0 $454 $0 $0 $114 $568 4.31 Reactor Vessel Insulation Removal and Disposal - Unit 3 $105 $12 $147 $0 $66 $331 Page 6 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total 4.32 Segment, Package and Dispose of Reactor Pressure Vessel - Unit 3 $1,044 $2,834 $29,313 $0 $8,298 $41.489 4.33 Remove and Dispose of Steam Generators - Unit 2 $2,789 $1,288 $18,154 $0 $5,558 $27,788 4.34 Remove and Dispose of Pressurizer - Unit 2 $462 $70 $2,620 $0 $788 $3,940 4.35 Remove and Dispose of Steam Generators - Unit 3 $2,789 $1,288 $18,154 $0 $5,558 $27,788 4.36 Remove and Dispose of Pressurizer - Unit 3 $462 $70 $2,620 $0 $788 $3,940 4.37 Remove and Dispose of Turbine Gantry Crane - Unit 2 $445 $229 $0 $4 $170 $848 4.38 Remove and Dispose of Turbine Gantry Crane - Unit 3 $445 $229 $0 $4 $170 $848 4.39 Prepare License Termination Plan $1,646 $149 $0 $0 $449 $2,244 Distributed Subtotal $126,926 $31,029 $209,131 $6,779 $95,755 $469,620 Undistributed 1.01 Utility Staff $71,956 $0 $0 $0 $17,989 $89,945 1.02 Utility Staff HP Supplies $0 $2,715 $0 $0 $679 $3,394 1.03 Security Guard Force $4,638 $0 $0 $0 $1,159 $5,797 1.04 Security Related Expenses $1,007 $0 $0 $0 $252 $1,259 1.05 Insurance $0 $0 $0 $3,653 $913 $4,566 1.06 Site Lease and Easement Expenses $0 $0 $0 $1,044 $157 $1,201 1.07 NRC Decommissioning Fees $0 $0 $0 $5,312 $1,328 $6,639 1.08 Materials and Services $0 $4,204 $0 $0 $1,051 $5,255 1.09 DAW Disposal $0 $0 $1,568 $0 $392 $1,960 1.10 Energy $0 $0 $0 $7,568 $1,892 $9,460 1.11 Decommissioning General Contractor Staff $125,798 $0 $0 $0 $31,449 $157,247 1.12 DGC HP Supplies $0 $5,834 $0 $0 $1,458 $7,292 1.13 Craft Worker Training $7,788 $0 $0 $0 $1,947 $9,735 1.14 Workers Compensation Insurance $0 $0 $0 $628 $157 $785 1.15 Community Outreach $3,639 $0 $0 $4,066 $1,926 $9,632 1.16 Property Tax $0 $0 $0 $5,222 $1,306 $6,528 1.18 Utilities (Water. gas, phone) $0 $1,007 $0 $0 $252 $1,258 1.19 Tools and Equipment $0 $423 $0 $0 $106 $529 1.20 Non-Process Computers $0 $348 $0 $0 $87 $435 1.21 Telecommunications $0 $348 $0 $0 $87 $435 1.24 Environmental Permits and Fees $0 $0 $0 $6,615 $1,654 $8,268 1.25 Decommissioning Advisor $0 $0 $0 $2,611 $653 $3,264 Page 7 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Undistributed Subtotal $214,826 $14,879 $1,568 $36,718 $66,893 $334,884 Decon Pd 4 Subtotal $341,752 $45,908 $210,699 $43,497 $162,649 $804,504 Page 8 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Decon Pd 5 Building Decontamination Distributed 5.01 Decon Containment Building - Unit 3 $6,056 $3,318 $54,825 $0 $16,050 $80,249 5.02 Decon Penetration Building - Unit 3 $1,065 $351 $2,933 $0 $1,087 $5,437 5.03 Decon Safety Equipment and MSIV Building - Unit 3 $905 $390 $5,562 $0 $1,715 $8,573 5.04 Decon Fuel Handling Building - Unit 3 $1,275 $577 $16,101 $0 $4,488 $22,442 5.05 Decon Turbine Building - Unit 3 $100 $95 $3,925 $0 $1,030 $5,150 5.06 Decon Containment Building - Unit 2 $6,056 $3,318 $54,825 $0 $16,050 $80,249 5.07 Decon Penetration Building - Unit 2 $1,065 $351 $2.933 $0 $1,087 $5,437 5.08 Decon Safety Equipment and MSIV Building - Unit 2 $911 $396 $5,777 $0 $1,771 $8,854 5.09 Decon Fuel Handling Building - Unit 2 $1,275 $577 $16,101 $0 $4,488 $22,442 5.10 Decon Turbine Building - Unit 2 $100 $95 $3,925 $0 $1,030 $5,150 5.11 Decon Auxiliary Radwaste Building - Common $943 $691 $17,999 $0 $4,908 $24,541 5.12 Decon Auxiliary Control Building- Common $198 $163 $38 $0 $100 $499 5.13 Decon Condensate Area and Tunnels - Units 2 & 3 $375 $316 $403 $0 $274 $1,368 5.14 Excavate, Remove and Dispose of Yard Area Drains $1,159 $128 $240 $0 $382 $1,908 5.15 Remove and Dispose of Contaminated Sumps, Trenches and Pavement $185 $21 $746 $0 $238 $1,191 5.16 Remove and Dispose of Radiologically Contaminated Soil $192 $216 $1,158 $0 $392 $1,958 5.17 Segment, Package and Dispose of Contaminated Decon Equipment and Tooling $38 $6 $92 $0 $34 $170 5.18 Radiological Survey of Structures During Decon $4,702 $3,666 $0 $0 $1,255 $9,623 Distributed Subtotal $26,600 $14,676 $187,585 $0 $56,379 $285,240 Undistributed 1.01 Utility Staff $29,516 $0 $0 $0 $7,379 $36,895 1.02 Utility Staff HP Supplies $0 $997 $0 $0 $249 $1,247 1.03 Security Guard Force $2,520 $0 $0 $0 $630 $3,150 1.04 Security Related Expenses $560 $0 $0 $0 $140 $701 1.05 Insurance $0 $0 $0 $1,985 $496 $2,481 1.06 Site Lease and Easement Expenses $0 $0 $0 $567 $85 $652 1.07 NRC Decommissioning Fees $0 $0 $0 $2,886 $722 * $3,608 1.08 Materials and Services $0 $1,668 $0 $0 $417 $2,086 1.09 DAW Disposal $0 $0 $464 $0 $116 $580 1.10 Energy $0 $0 $0 $2.336 $584 $2,920 Page 9 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total 1.11 Decommissioning General Contractor Staff $56,286 $0 $0 $0 $14,071 $70,357 1.12 DGC HP Supplies $0 $3,170 $0 $0 $792 $3,962 1.13 Craft Worker Training $1,693 $0 $0 $0 $423 $2,116 1.14 Workers Compensation Insurance $0 $0 $0 $341 $85 $426 1.15 Community Outreach $862 $0 $0 $964 $457 $2,283 1.16 Property Tax $0 $0 $0 $2,837 $709 $3,547 1.18 Utilities (Water, gas, phone) $0 $413 $0 $0 $103 $517 1.19 Tools and Equipment $0 $204 $0 $0 $51 $255 1.20 Non-Process Computers $0 $189 $0 $0 $47 $236 1.21 Telecommunications $0 $189 $0 $0 $47 $236 1.22 Personal Computers $0 $0 $0 $71 $18 $88 1.24 Environmental Permits and Fees $0 $0 $0 $3,594 $899 $4,493 1.25 Decommissioning Advisor $0 $0 $0 $825 $206 $1,031 Undistributed Subtotal $91,437 $6,832 $464 $16,406 $28,728 $143,866 Decon Pd 5 Subtotal $118,037 $21,508 $188,049 $16,406 $85,106 $429,106 Page 10 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Decon Pd 6 License Termination During Demolition Distributed 6.01 Final Status Survey $9,613 $3,088 $0 $2,360 $2,259 $17,320 6.02 Prepare Final Report of Dismantling Program $164 $4 $0 $0 $42 $210 Distributed Subtotal $9,777 $3,091 $0 $2,360 $2,301 $17,530 Undistributed 1.01 Utility Staff $1,378 $0 $0 $0 $345 $1,723 1.04 Security Related Expenses $4 $0 $0 $0 $1 $5 1.07 NRC Decommissioning Fees $0 $0 $0 $13,535 $3,384 $16,919 1.08 Materials and Services $0 $47 $0 $0 $12 $58 1.09 DAW Disposal $0 $0 $62 $0 $16 $78 1.10 Energy $0 $0 $0 $1,872 $468 $2,340 1.11 Decommissioning General Contractor Staff $651 $0 $0 $0 $163 $814 1.12 DGC HP Supplies $0 $301 $0 $0 $75 $376 1.15 Community Outreach $2,386 $0 $0 $2,666 $1,263 $6,315 1.18 Utilities (Water, gas, phone) $0 $10 $0 $0 $3 $13 Undistributed Subtotal $4,420 $357 $62 $18,074 $5,728 $28,641 Decon Pd 6 Subtotal $14,197 $3,449 $62 $20,434 $8,029 $46,171 A. License Termination Subtotal $812,119 $150,936 $566,266 $171,959 $410,965 $2,112,246 Page 11 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total B. Spent Fuel SNF Pd 1 Spent Fuel Management Transition Distributed 7.01 Security Shut Down Strategy $0 $0 $0 $8.388 $0 $8,388 7.02 Design and Fabricate Spent Fuel Canisters $0 $0 $0 $8,842 $0 $8,842 7.03 Post Fukushima Modifications - Unit 2 $0 $0 $0 $126 $0 $126 7.05 Cyber Security Modifications so $0 $0 $1,901 $0 $1,901 Distributed Subtotal $0 $0 $0 $19,258 $0 $19,258 Undistributed 2.01 Utility Spent Fuel Staff $38,478 $0 $0 $0 $0 $38,478 2.04 Security Guard Force $69,889 $0 $0 $0 $0 $69,889 2.09 Emergency Preparedness Fees $0 $0 $0 $2,340 $0 $2,340 2.10 Spent Fuel Maintenance $0 $0 $0 $32 $0 $32 Undistributed Subtotal $108,367 $0 $0 $2,372 $0 $110,739 SNF Pd 1 Subtotal $108,367 $0 $0 $21,630 $0 $129,997 Page 12 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Deconmmissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total SNF Pd 2 Spent Fuel Transfer to Dry Storage Distributed 8.01 Security Shut Down Strategy $0 $0 $0 $2,855 $714 $3,569 8.02 Decay Heat Analysis $0 $0 $0 $105 $26 $131 8.03 Zirconium Fire/ Shine Analysis $0 $0 $0 $105 $26 $131 8.05 NRC Review of Irradiated Fuel Management Plan $0 $0 $0 $105 $26 $131 8.07 ISFSI Pad Study $0 $0 $0 $103 $26 $129 8.08 Design ISFSI Expansion $0 $0 $0 $3,150 $788 $3,938 8.09 Construct ISFSI Expansion $0 $0 $0 $33,600 $8,400 $42,000 8.10 Purchase and Fabrication of Spent Fuel Canisters and AHSMs - Unit 2 $0 $49,613 $0 $0 $12,403 $62,016 8.11 Purchase and Fabrication Spent Fuel Canisters and AHSMs - Unit 3 $0 $50,794 $0 $0 $12,698 $63,492 8.12 Deliver and Load Spent Fuel Canisters and Transfer to ISFSI - Unit 2 $71,338 $17,478 $0 $0 $22,204 $111,021 8.13 Deliver and Load Spent Fuel Canisters and Transfer to ISFSI - Unit 3 $73,037 $17,894 $0 $0 $22,733 $113,664 Distributed Subtotal $144,375 $135,779 $0 $40,023 $80,044 $400,221 Undistributed 2.01 Utility Spent Fuel Staff $90,824 $0 $0 $0 $22,706 $113,530 2.02 Utility Staff HP Supplies $0 $6,590 $0 $0 $1,647 $8,237 2.04 Security Guard Force $112,313 $0 $0 $0 $28,078 $140,391 2.05 Security Related Expenses $1,334 $0 $0 $0 $333 $1,667 2.06 Insurance $0 $0 $0 $4,408 $1,102 $5,510 2.08 NRC Spent Fuel Fees $0 $0 $0 $1,107 $277 $1,383 2.09 Emergency Preparedness Fees $0 $0 $0 $18,756 $4,689 $23,445 2.10 Spent Fuel Maintenance $0 $0 $0 $2,131 $533 $2,664 2.11 Materials and Services $0 $5,848 $0 $0 $1,462 $7,310 2.12 DAW Disposal $0 $0 $275 $0 $69 $343 2.13 Energy $0 $0 $0 $3,991 $998 $4,989 2.15 Craft Worker Training $2,119 $0 $0 $0 $530 $2,649 2.18 Utilities (Water, gas, phone) $0 $3,572 $0 $0 $893 $4,465 2.22 Personal Computers $0 $0 $0 $14 $3 $17 Undistributed Subtotal $206,590 $16,010 $275 $30,406 $63,320 $316,601 SNF Pd 2 Subtotal $350,965 $151,789 $275 $70,429 $143,364 $716,822 Page 13 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total SNF Pd 3 Dry Storage During Decommnissioning - Units 1, 2 and 3 Undistributed 2.01 Utility Spent Fuel Staff $39,894 $0 $0 $0 $9,973 $49,867 2.02 Utility Staff HP Supplies $0 $1,487 $0 $0 $372 $1,859 2.04 Security Guard Force $45,944 $0 $0 $0 $11,486 $57,430 2.05 Security Related Expenses $2,556 $0 $0 $0 $639 $3,195 2.08 NRC Spent Fuel Fees $0 $0 $0 $2,302 $576 $2,878 2.10 Spent Fuel Maintenance $0 $0 $0 $1,478 $370 $1,848 2.11 Materials and Services $0 $2,017 $0 $0 $504 $2,522 2.13 Energy $0 $0 $0 $1,209 $302 $1,511 2.18 Utilities (Water, gas, phone) $0 $1,380 $0 $0 $345 $1,725 2.22 Personal Computers $0 $0 $0 $12 $3 $15 Undistributed Subtotal $88,393 $4,884 $0 $5,001 $24,570 $122,849 SNF Pd 3 Subtotal $88,393 $4,884 $0 $5,001 $24,570 $122,849 Page 14 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total SNF Pd 4 Dry Storage Only - Units 1, 2 and 3 Undistributed 2.01 Utility Spent Fuel Staff $12,687 $0 $0 $0 $3,172 $15,859 2.02 Utility Staff HP Supplies $0 $882 $0 $0 $220 $1,102 2.03 Additional Staff for Spent Fuel Shipping $1,119 $0 $0 $0 $280 $1,398 2.04 Security Guard Force $14,949 $0 $0 $0 $3,737 $18,687 2.05 Security Related Expenses $2,506 $0 $0 $0 $626 $3,132 2.06 Insurance $0 $0 $0 $2,538 $634 $3,172 2.07 Site Lease and Easement Expenses $0 $0 $0 $1,154 $173 $1,327 2.08 NRC Spent Fuel Fees $0 $0 $0 $1,638 $409 $2,047 2.10 Spent Fuel Maintenance $0 $0 $0 $481 $120 $601 2.11 Materials and Services $0 $778 $0 $0 $194 $972 2.13 Energy $0 $0 $0 $393 $98 $492 2.16 Workers Compensation Insurance $0 $0 $0 $694 $173 $867 2.17 Property Tax $0 $0 $0 $6,412 $1,603 $8,015 2.18 Utilities (Water, gas, phone) $0 $475 $0 $0 $119 $594 2.20 Non-Process Computers $0 $192 $0 $0 $48 $240 2.21 Telecommunications $0 $192 $0 $0 $48 $240 2.22 Personal Computers $0 $0 $0 $15 $4 $18 Undistributed Subtotal $31,261 $2,519 $0 $13,325 $11,661 $58,765 SNF Pd 4 Subtotal $31,261 $2,519 $0 $13,325 $11,661 $58,765 Page 15 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total SNF Pd 5 Dry Storage Only - Units 2 and 3 Undistributed 2.01 Utility Spent Fuel Staff $48,480 $0 $0 $0 $12,120 $60,601 2.02 Utility Staff HP Supplies $0 $3,369 $0 $0 $842 $4,211 2.03 Additional Staff for Spent Fuel Shipping $4,275 $0 $0 $0 $1,069 $5,344 2.04 Security Guard Force $57,126 $0 $0 $0 $14,281 $71,407 2.05 Security Related Expenses $4,124 $0 $0 $0 $1,031 $5,155 2.06 Insurance $0 $0 $0 $9,698 $2,425 $12,123 2.07 Site Lease and Easement Expenses $0 $0 $0 $4,409 $661 $5,071 2.08 NRC Spent Fuel Fees $0 $0 $0 $6,259 $1,565 $7,823 2.10 Spent Fuel Maintenance $0 $0 $0 $1,838 $459 $2,297 2.11 Materials and Services $0 $2,972 $0 $0 $743 $3,715 2.13 Energy $0 $0 $0 $1,503 $376 $1,879 2.16 Workers Compensation Insurance $0 $0 $0 $2,651 $663 $3,314 2.17 Property Tax $0 $0 $0 $22,053 $5,513 $27,566 2.18 Utilities (Water, gas, phone) $0 $1,816 $0 $0 $454 $2,270 2.20 Non-Process Computers $0 $735 $0 $0 $184 $919 2.21 Telecommunications $0 $735 $0 $0 $184 $919 2.22 Personal Computers $0 $0 $0 $32 $8 $40 Undistributed Subtotal $114,005 $9,627 $0 $48,443 $42,578 $214,653 SNF Pd 5 Subtotal $114,005 $9,627 $0 $48,443 $42,578 $214,653 Page 16 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total SNF D&D Pd 1 ISFS1 License Ternination Distributed 12.01 Preparation and NRC Review of License Termination Plan $116 $0 $0 $163 $70 $349 Distributed Subtotal $116 $0 $0 $163 $70 $349 Undistributed 2.01 Utility Spent Fuel Staff $366 $0 $0 $0 $91 $457 2.02 Utility Staff HP Supplies $0 $11 $0 $0 $3 $14 2.04 Security Guard Force $181 $0 $0 $0 $45 $226 2.05 Security Related Expenses $70 $0 $0 $0 $18 $88 2.06 Insurance $0 $0 $0 $215 $54 $269 2.07 Site Lease and Easement Expenses $0 $0 $0 $98 $15 $112 2.08 NRC Spent Fuel Fees $0 $0 $0 $75 $19 $94 2.11 Materials and Services $0 $17 $0 $0 $4 $21 2.13 Energy $0 $0 $0 $102 $26 $128 2.16 Workers Compensation Insurance $0 $0 $0 $59 $15 $73 2.17 Property Tax $0 $0 $0 $543 $136 $679 2.18 Utilities (Water, gas, phone) $0 $7 $0 $0 $2 $9 Undistributed Subtotal $617 $36 $0 $1,092 $426 $2,172 SNF D&D Pd 1 Subtotal $733 $36 $0 $1,255 $496 $2,520 Page 17 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total SNF D&D Pd 2 ISFSI Demolition Distributed 13.01 Install GARDIAN Bulk Assay System $0 $0 $0 $525 $131 $656 13.02 Decon AHSMs $339 $147 $443 $0 $232 $1,161 13.03 Final Status Survey of ISFSI $1,589 $256 $0 $0 $277 $2,122 13.04 Clean Demolition of ISFSI AHSMs and Pad $4,094 $2,590 $3,333 $0 $2,504 $12,521 13.05 Clean Demolition of ISFSI Support Structures $1,126 $458 $1,372 $0 $739 $3,696 13.06 Restore ISFSI Site $246 $161 $0 $0 $102 $509 13.07 Preparation of Final Report on Decommissioning and NRC Review $52 $0 $0 $0 $13 $65 Distributed Subtotal $7,446 $3,612 $5,148 $525 $3,998 $20,729 Undistributed 2.01 Utility Spent Fuel Staff $1,801 $0 $0 $0 $450 $2,251 2.02 Utility Staff HP Supplies $0 $72 $0 $0 $18 $90 2.04 Security Guard Force $704 $0 $0 $0 $176 $880 2.05 Security Related Expenses $37 $0 $0 $0 $9 $46 2.11 Materials and Services $0 $93 $0 $0 $23 $116 2.12 DAW Disposal $0 $0 $7 $0 $2 $8 2.13 Energy $0 $0 $0 $268 $67 $334 2.14 Decommissioning General Contractor Staff $4,525 $0 $0 $0 $1,131 $5,656 2.15 Craft Worker Training $189 $0 $0 $0 $47 $236 2.18 Utilities (Water, gas, phone) $0 $35 $0 $0 $9 $43 2.24 DGC HP Supplies $0 $159 $0 $0 $40 $199 Undistributed Subtotal $7,255 $359 $7 $268 $1,972 $9,861 SNF D&D Pd 2 Subtotal $14,701 $3,972 $5,154 $793 $5,970 $30,590 B. Spent Fuel Subtotal $708,425 $172,826 $5,429 $160,876 $228,639 $1,276,196 Page 18 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total C. Site Restoration SR Pd 1 Transition to Site Restoration Distributed 14.01 Mesa Site Phase I and H Site Assessment $0 $0 $0 $42 $11 $53 14.02 Disposition Hazardous Waste from Mesa Site $0 $0 $0 $211 $106 $317 14.03 Mesa Site Characterization Survey $988 $261 $0 $0 $312 $1,561 14.04 Fuel Cancellation Expense $0 $0 $0 $17,679 $0 $17,679 Distributed Subtotal $988 $261 $0 $17,932 $428 $19,610 Undistributed 3.05 Site Lease and Easement Expenses $0 $0 $0 $1,030 $0 $1,030 3.11 Severance $0 $0 $0 $109,850 $0 $109,850 Undistributed Subtotal $0 $0 $0 $110,880 $0 $110,880 SR Pd 1 Subtotal $988 $261 $0 $128,812 $428 $130,489 Page 19 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total SR Pd 2 Building Demolition During Deconmmissioning Distributed 15.01 Prepare Site Restoration Demolition Plan and Schedule $684 $10 $0 $0 $173 $866 15.02 Obtain Required Permits For Mesa, South Access and South Yard $209 $4 $0 $0 $53 $266 15.03 Demolish Service Building (K-10, 20, 30) $250 $189 $481 $0 $230 $1,150 15.04 Demolish South Security Processing Facility (K-70) $46 $44 $122 $0 $53 $264 15.05 Demolish Staging Warehouse $67 $55 $126 $0 $62 $311 15.06 Demolish Administration Building (K-40/50) $367 $258 $565 $0 $297 $1,487 15.07 Demolish South Yard Area Buildings T-10, 20, 60 and Haz Mat. $670 $590 $1,370 $0 $658 $3,288 15.08 Demolish REMS Staging Pad $98 $184 $549 $0 $208 $1,038 15.09 Demolish Mesa Buildings $2,788 $1,879 $6,006 $0 $2,668 $13,341 15.10 Remove Underground Fuel Storage Tanks $56 $22 $0 $21 $25 $123 15.11 Demolish Mesa Roads and Parking Lots $582 $400 $0 $0 $245 $1,227 15.12 Finish Grading and Re-vegetate Mesa Site $299 $404 $0 $0 $176 $878 Distributed Subtotal $6,114 $4,038 $9,219 $21 $4,848 $24,239 Undistributed 3.01 Utility Staff $2,563 $0 $0 $0 $641 $3,204 3.03 Security Related Expenses $898 $0 $0 $0 $224 $1,122 3.05 Site Lease and Easement Expenses $0 $0 $0 $4,266 $640 $4,906 3.06 Materials and Services $0 $134 $0 $0 $34 $168 3.08 Decommissioning General Contractor Staff $4,248 $0 $0 $0 $1,062 $5,310 3.09 Craft Worker Training $318 $0 $0 $0 $80 $398 3.11 Severance $0 $0 $0 $8,688 $2,172 $10,860 3.13 Utilities (Water, gas, phone) $0 $29 $0 $0 $7 $36 Undistributed Subtotal $8,027 $164 $0 $12,955 $4,860 $26,005 SR Pd 2 Subtotal $14,141 $4,201 $9,219 $12,975 $9,708 $50,245 Page 20 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: I/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total SR Pd 3 Subsurface Demolition Engineering and Permitting Distributed 16.01 Hydrogeologic Investigation and Outfall Conduit Survey $297 $131 $0 $105 $133 $667 16.02 Subsurface Structure Removal Engineering Planning and Design $1,264 $33 $0 $0 $324 $1,621 16.03 Environmental Impacts Analyses for Lease Termination Activities $581 $50 $0 $525 $289 $1,445 16.04 Final Site Grading and Shoreline Protection Engineering Planning and Design $242 $13 $0 $0 $64 $319 16.05 Obtain Required Permits and Approvals $1,856 $20 $0 $263 $535 $2,673 Distributed Subtotal $4,240 $248 $0 $893 $1,345 $6,726 Undistributed 3.03 Security Related Expenses $275 $0 $0 $0 $69 $344 3.11 Severance $0 $0 $0 $24,674 $6,168 $30,842 Undistributed Subtotal $275 $0 $0 $24,674 $6,237 $31,186 SR Pd 3 Subtotal $4,516 $248 $0 $25,566 $7,582 $37,912 Page 21 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total SR Pd 4 Building Demolition to 3 Feet Below Grade Distributed 17.01 Procure Clean Building Demolition Equipment $0 $10,691 $0 $0 $2,673 $13,363 17.02 Install Temporary Structures $11 $190 $0 $0 $30 $230 17.03 Install Erosion and Sediment Controls $123 $14 $0 $0 $34 $172 17.04 Remove Cathodic Protection Trench $1,813 $1,527 $22 $0 $840 $4,201 17.05 Remove Protected Area Security Fencing $57 $18 $0 $0 $19 $95 17.06 Remove Protected Area Pavement $139 $97 $755 $0 $248 $1,239 17.07 Detension and Remove Unit 3 Containment Builidng Tendons $0 $0 $0 $4.200 $1,050 $5,250 17.08 Demolish Diesel Generator Building - Unit 3 $618 $245 $794 $0 $414 $2,072 17.09 Demolish Condensate Building and Transformer Pads - Unit 3 $1,067 $1,755 $3,183 $0 $1,501 $7,505 17.10 Demolish Full Flow Area and Turbine Building - Unit 3 $3,221 $1,149 $3,444 $0 $1,953 $9,767 17.11 Demolish Unit 3 Fuel Handling Building to 3-Feet Below Grade $306 $354 $1,470 $0 $533 $2,663 17.12 Demolish Penetration Building- Unit 3 $293 $167 $642 $0 $275 $1,377 17.13 Demolish Safety Equipment and MSIV Building - Unit 3 $336 $403 $1,858 $0 $649 $3,246 17.14 Demolish Unit 3 Containment Building to 3-Feet Below Grade $2,418 $1,351 $6,198 $0 $2,492 $12,459 17.15 Detension and Remove Unit 2 Containment Builidng Tendons $0 $0 $0 $4,200 $1,050 $5,250 17.16 Demolish Diesel Generator Building - Unit 2 $128 $168 $787 $0 $271 $1,353 17.17 Demolish Condensate Building and Transformer Pads - Unit 2 $1,067 $1,755 $3,183 $0 $1,501 $7,505 17.18 Demolish Full Flow Area and Turbine Building - Unit 2 $3,734 $1,186 $3,447 $0 $2,092 $10,458 17.19 Demolish Unit 2 Fuel Handling Building to 3-Feet Below Grade $306 $354 $1,470 $0 $533 $2,663 17.20 Demolish Penetration Building - Unit 2 $99 $136 $639 $0 $219 $1,093 17.21 Demolish Safety and MSIV Equipment Building - Unit 2 $336 $403 $1,859 $0 $649 $3,247 17.22 Demolish Unit 2 Containment Building to 3-Feet Below Grade $2,418 $1,351 $6,198 $0 $2,492 $12,459 17.23 Demolish AWS Building $1,108 $1,050 $2,925 $0 $1,271 $6,354 17.24 Demolish Building L-50 $59 $33 $67 $0 $40 $198 17.25 Demolish Maintenance Building 4 (B-64/B-65) $24 $13 $25 $0 $16 $78 17.26 Demolish Maintenance Building 5 (B-62/B-63) $35 $20 $37 $0 $23 $115 17.27 Demolish Outage Control Center $98 $57 $148 $0 $76 $378 17.28 Demolish Maintenance Building 2 (B-49/B-50) $49 $32 $82 $0 $41 $205 17.29 Demolish Maintenance Building I (B-43/B-44) $163 $196 $857 $0 $304 $1,520 17.30 Demolish Auxilary Radwaste Building - Common $1,521 $1,984 $9.214 $0 $3,180 $15,898 17.31 Demolish Auxilary Control Building - Common $1,491 $811 $3.219 $0 $1,380 $6.901 Page 22 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total 17.32 Remove Systems and Demolish Make-Up Demineralizer Structures $737 $122 $471 $0 $332 $1,662 17.33 Install Concrete Plugs in Intake and Discharge Structures $272 $1,614 $0 $0 $472 $2,358 17.34 Demolish Intake and Discharge Structures to 3-Feet Below Grade $82 $114 $535 $0 $183 $914 Distributed Subtotal $24,128 $29,358 $53,530 $8,400 $28,834 $144,249 Undistributed 3.01 Utility Staff $12,553 $0 $0 $0 $3,138 $15,691 3.02 Security Guard Force $2,480 $0 $0 $0 $620 $3,100 3.03 Security Related Expenses $1,158 $0 $0 $0 $290 $1,448 3.04 Insurance $0 $0 $0 $3,995 $999 $4,993 3.05 Site Lease and Easement Expenses $0 $0 $0 $1,340 $201 $1,541 3.06 Materials and Services $0 $751 $0 $0 $188 $938 3.07 Energy $0 $0 $0 $1,184 $296 $1,480 3.08 Decommissioning General Contractor Staff $50,906 $0 $0 $0 $12,727 $63,633 3.09 Craft Worker Training $1,999 $0 $0 $0 $500 $2,498 3.10 Workers Compensation Insurance $0 $0 $0 $806 $201 $1,007 3.11 Severance $0 $0 $0 $7,273 $1,818 $9,091 3.12 Property Tax $0 $0 $0 $6,701 $1,675 $8,377 3.13 Utilities (Water, gas, phone) $0 $214 $0 $0 $53 $267 3.14 Tools and Equipment $0 $156 $0 $0 $39 $195 3.15 Non-Process Computers $0 $223 $0 $0 $56 $279 3.16 Telecommunications $0 $223 $0 $0 $56 $279 Undistributed Subtotal $69,096 $1,567 $0 $21,298 $22,856 $114,817 SR Pd 4 Subtotal $93,224 $30,924 $53,530 $29,698 $51,690 $259,066 Page 23 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total SR Pd 5 Subgrade Structure Removal Below - 3 Feet Distributed 18.01 Procure Subsurface Structure Demolition Equipment $0 $6,630 $0 $0 $1,658 $8,288 18.02 Install Sheet Piling and Excavation Shoring $8,468 $17,219 $0 $0 $6,422 $32,109 18.03 Install Dewatering System and Effluent Treatment and Discharge Controls $0 $0 $0 $9,651 $2,413 $12,064 18.04 Demolish and Backfill Unit 3 Condensate Storage Area Below -3 Feet $179 $305 $912 $0 $349 $1,746 18.05 Demolish and Backfill Unit 3 Diesel Generator Builidng Below -3 Feet $130 $173 $442 $0 $186 $932 18.06 Demolish and Backfill Unit 3 Fuel Handling Building Below -3 Feet $271 $696 $1,170 $0 $534 $2,671 18.07 Demolish and Backfill Unit 3 Radwaste and Control Building Below -3 Feet $1,367 $3,268 $5,249 $0 $2,471 $12,355 18.08 Demolish and Backfill Unit 3 Turbine Building Structure Below 9 Ft Elevation $3,956 $9,277 $12,551 $0 $6,446 $32,231 18.09 Demolish and Backfill Unit 3 Safety Equipment Building Below -3 Feet $717 $1,883 $2,713 $0 $1,328 $6,641 18.10 Demolish and Backfill Unit 3 Penetration Area Below -3 Feet $294 $586 $1,285 $0 $541 $2,706 18.11 Demolish and Backfill Unit 3 Full Flow Building Below -3 Feet $167 $527 $411 $0 $276 $1,382 18.12 Demolish and Backfill Unit 3 Containment Building Below -3 Feet $1,211 $2,214 $4,636 $0 $2.015 $10,077 18.13 Demolish and Backfill Unit 2 Condensate Storage Area Below -3 Feet $179 $305 $912 $0 $349 $1,746 18.14 Demolish and Backfill Unit 2 Diesel Generator Builidng Below -3 Feet $130 $173 $442 $0 $186 $932 18.15 Demolish and Backfill Unit 2 Fuel Handling Building Below -3 Feet $271 $696 $1,170 $0 $534 $2,671 18.16 Demolish and Backfill Unit 2 Radwaste and Control Building Below -3 Feet $1,415 $3,308 $5,249 $0 $2,493 $12,466 18.17 Demolish and Backfill Unit 2 Turbine Building Structure Below 9 Ft Elevation $3,959 $9,277 $12,551 $0 $6,447 $32,234 18.18 Demolish and Backfill Unit 2 Safety Equipment Building Below -3 Feet $717 $1,883 $2,713 $0 $1,328 $6,641 18.19 Demolish and Backfill Unit 2 Penetration Area Below -3 Feet $294 $586 $1,285 $0 $541 $2,706 18.20 Demolish and Backfill Unit 2 Full Flow Building Below -3 Feet $167 $527 $411 $0 $276 $1,382 18.21 Demolish and Backfill Unit 2 Containment Building Below -3 Feet $1,211 $2,214 $4,636 $0 $2,015 $10,077 18.22 Demolish and Backfill Intake Structure Below -3 Feet $6,664 $12,970 $36,706 $0 $14,085 $70,426 18.23 Remove Off Shore Intake and Outfall Conduits $12,406 $44,308 $19,580 $0 $19,073 $95,367 18.24 Remove Sheet Piling and Excavation Shoring $11,776 $0 $0 $0 $2,944 $14,721 18.25 Remove Dewatering System and Effluent Treatment $0 $0 $0 $2,308 $577 $2,885 18.26 Finish Grading and Re-Vegetate Site $945 $813 $0 $0 $440 $2,198 18.27 Remove Temporary Structures $58 $48 $0 $0 $16 $122 Distributed Subtotal $56,952 $119,889 $115,025 $11,959 $75,946 $379,772 Undistributed 3.01 Utility Staff $7,082 $0 $0 $0 $1,771 $8,853 Page 24 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total 3.02 Security Guard Force $1,830 $0 $0 $0 $458 $2,288 3.03 Security Related Expenses $139 $0 $0 $0 $35 $173 3.04 Insurance $0 $0 $0 $2,948 $737 $3,685 3.05 Site Lease and Easement Expenses $0 $0 $0 $989 $148 $1,137 3.06 Materials and Services $0 $415 $0 $0 $104 $519 3.07 Energy $0 $0 $0 $814 $204 $1,018 3.08 Decommissioning General Contractor Staff $26,176 $0 $0 $0 $6,544 $32,720 3.09 Craft Worker Training $983 $0 $0 $0 $246 $1,229 3.10 Workers Compensation Insurance $0 $0 $0 $595 $149 $743 3.11 Severance $0 $0 $0 $2,050 $513 $2,563 3.12 Property Tax $0 $0 $0 $4,946 $1,237 $6,183 3.13 Utilities (Water, gas, phone) $0 $128 $0 $0 $32 $160 3.14 Tools and Equipment $0 $73 $0 $0 $18 $91 3.15 Non-Process Computers $0 $165 $0 $0 $41 $206 3.16 Teleconmunications $0 $165 $0 $0 $41 $206 Undistributed Subtotal $36,211 $946 $0 $12,343 $12,276 $61,775 SR Pd 5 Subtotal $93,163 $120,834 $115,025 $24,302 $88,222 $441,547 Page 25 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total SR Pd 6 Final Site Restoration and Lease Termination Distributed 19.01 Obtain Required Permits and Approvals $404 $20 $0 $131 $139 $693 19.02 Install Temporary Structures $6 $35 $0 $0 $6 $48 19.03 Procure Site Restoration Equipment $0 $404 $0 $0 $101 $505 19.04 Install Temporary Seawall or Coffer Dam $8,551 $17,624 $0 $0 $6,544 $32,718 19.05 Install Dewatering System and Effluent Treatment and Discharge Controls $0 $0 $0 $1,427 $357 $1,784 19.06 Remove and Stockpile Existing Seawall Erosion Protection $6 $11 $0 $0 $4 $21 19.07 Remove Unit 2 and 3 Seawall and Pedestrian Walkway $3,206 $3,060 $4,558 $0 $2,706 $13,530 19.08 Remove Remaining Intake and Outfall Box Culvert $336 $468 $2,188 $0 $748 $3.739 19.09 Remove Temporary Seawall or Coffer Dam $11,791 $143 $0 $0 $2,983 $14,917 19.10 Backfill and Compaction of Excavation $1,471 $2,238 $0 $0 $556 $4,265 19.11 Remove Dewatering System and Effluent Treatment $0 $0 $0 $592 $148 $740 19.12 Install Shoreline Erosion Control and Restoration Features $10 $144 $0 $0 $38 $192 19.13 Remove Railroad Tracks, Rails and Ballast $63 $35 $0 $0 $24 $122 19.14 Remove Gunite Slope Protection $262 $366 $1,710 $0 $585 $2,923 19.15 Remove Access Roads and Parking Lots $240 $181 $0 $0 $105 $527 19.16 Finish Grading and Re-Vegetate Site $27 $28 $0 $0 $14 $68 19.17 Remove Temporary Structures $8 $7 $0 $0 $2 $18 Distributed Subtotal $26,380 $24,763 $8,456 $2,151 $15,061 $76,810 Undistributed 3.01 Utility Staff $2,219 $0 $0 $0 $555 $2,773 3.04 Insurance $0 $0 $0 $605 $151 $756 3.05 Site Lease and Easement Expenses $0 $0 $0 $507 $76 $583 3.06 Materials and Services $0 $142 $0 $0 $35 $177 3.07 Energy $0 $0 $0 $418 $104 $522 3.08 Decommissioning General Contractor Staff $8,062 $0 $0 $0 $2,016 $10,078 3.09 Craft Worker Training $504 $0 $0 $0 $126 $630 3.10 Workers Compensation Insurance $0 $0 $0 $305 $76 $381 3.11 Severance $0 $0 $0 $6,077 $1,519 $7,596 3.12 Property Tax $0 $0 $0 $2,536 $634 $3,169 3.13 Utilities (Water, gas, phone) $0 $31 $0 $0 $8 $38 Page 26 of 27

Table 1 SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage License Status POL Unit 2 Shut Down: 6/7/2013 Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013 Spent Fuel Alternative Dry Repository Opening Date: 1/1/2024 2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total 3.14 Tools and Equipment $0 $24 $0 $0 $6 $31 Undistributed Subtotal $10,785 $197 $0 $10,446 $5,307 $26,735 SR Pd 6 Subtotal $37,165 $24,960 $8,456 $12,597 $20,367 $103,545 C. Site Restoration Subtotal $243,198 $181,428 $186,230 $233,951 $177,997 $1,022,804 Total $1,763,742 $505,191 $757,925 $566,786 $817,601 $4,411,246 Page 27 of 27

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 Appendix E Annual Cash Flow Table

SONGS Annual Cost By Account Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage Unit No: Unit 2 2014 Dollars in Thousands Year License Spent Fuel Site Restoration Total Termination 2013 $25,749 $63,891 $49,067 $138,706 2014 $79,799 $35,719 $15,089 $130,607 2015 $69,196 $106,308 $7,439 $182,943 2016 $54,541 $59,308 $3,730 $117,579 2017 $111,903 $59,308 $1,957 $173,168 2018 $47,520 $59,308 $0 $106,828 2019 $108,328 $27,554 $13,539 $149,420 2020 $185,482 $4,908 $36 $190,426 2021 $79,081 $4,908 $36 $84,026 2022 $54,785 $4,908 $1,927 $61,621 2023 $158,207 $4,908 $36 $163,151 2024 $37,930 $4,908 $16,848 $59,687 2025 $2,922 $4,908 $44,621 $52,451 2026 $2,922 $4,908 $19,412 $27,243 2027 $2,922 $4,908 $22,469 $30,299 2028 $2,922 $4,908 $31,688 $39,518 2029 $2,922 $4,908 $66,873 $74,704 2030 $2,922 $4,908 $71,867 $79,697 2031 $2,055 $5,089 $23,181 $30,325 2032 $2,122 $7,214 $0 $9,336 2033 $0 $7,214 $0 $7,214 2034 $0 $7,214 $0 $7,214 2035 $0 $7,228 $0 $7,228 2036 $0 $7,665 $0 $7,665 2037 $0 $7,665 $0 $7,665 2038 $0 $7,665 $0 $7,665 2039 $0 $7,665 $0 $7,665 2040 $0 $7,665 $0 $7,665 2041 $0 $7,665 $0 $7,665 2042 $0 $7,665 $0 $7,665 2043 $0 $7,665 $0 $7,665 2044 $0 $7,665 $0 $7,665 2045 $0 $7,665 $0 $7,665 2046 $0 $7,665 $0 $7,665 2047 $0 $7,665 $0 $7,665 2048 $0 $7,665 $0 $7,665 Page 1 of 4

SONGS Annual Cost By Account Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage Unit No: Unit 2 2014 Dollars in Thousands Year License Spent Fuel Site Restoration Total Termination 2049 $0 $7,667 $0 $7,667 2050 $0 $9,974 $20,177 $30,151 2051 $0 $6,573 $11,928 $18,500 2052 $0 $0 $1,377 $1,377 Total $1,034,230 $623,209 $423,297 $2,080,735 Page 2 of 4

SONGS Annual Cost By Account Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage Unit No: Unit 3 2014 Dollars in Thousands Year License Spent Fuel Site Restoration Total Termination 2013 $26,566 $66,105 $49,067 $141,739 2014 $78,964 $40,156 $15,969 $135,089 2015 $74,096 $112,024 $9,390 $195,509 2016 $61,451 $64,405 $25,227 $151,083 2017 $40,631 $64,405 $3,799 $108,835 2018 $86,348 $64,405 $0 $150,753 2019 $96,521 $29,675 $13,908 $140,104 2020 $120,873 $4,908 $2,135 $127,916 2021 $194,090 $4,908 $575 $199,574 2022 $135,313 $4,908 $2,467 $142,688 2023 $114,581 $4,908 $1,511 $121,000 2024 $26,874 $4,908 $36,778 $68,560 2025 $2,922 $4,908 $40,655 $48,485 2026 $2,922 $4,908 $21,676 $29,507 2027 $2,922 $4,908 $25,848 $33,678 2028 $2,922 $4,908 $20,945 $28,776 2029 $2,922 $4,908 $117,321 $125,151 2030 $2,922 $4,908 $116,672 $124,503 2031 $2,055 $5,089 $25,501 $32,645 2032 $2,122 $7,214 $0 $9,336 2033 $0 $7,214 $0 $7,214 2034 $0 $7,214 $0 $7,214 2035 $0 $7,228 $0 $7,228 2036 $0 $7,665 $0 $7,665 2037 $0 $7,665 $0 $7,665 2038 $0 $7,665 $0 $7,665 2039 $0 $7,665 $0 $7,665 2040 $0 $7,665 $0 $7,665 2041 $0 $7,665 $0 $7,665 2042 $0 $7,665 $0 $7,665 2043 $0 $7,665 $0 $7,665 2044 $0 $7,665 $0 $7,665 2045 $0 $7,665 $0 $7,665 2046 $0 $7,665 $0 $7,665 2047 $0 $7,665 $0 $7,665 2048 $0 $7,665 $0 $7,665 Page 3 of 4

SONGS Annual Cost By Account Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage Unit No: Unit 3 2014 Dollars in Thousands Year License Spent Fuel Site Restoration Total Termination 2049 $0 $7,667 $0 $7,667 2050 $0 $9,974 $23,120 $33,094 2051 $0 $6,573 $45,566 $52,139 2052 $0 $0 $1,377 $1,377 Total $1,078,016 $652,987 $599,507 $2,330,511 Page 4 of 4

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3 Appendix F SDG&E SONGS Decommissioning Costs (100%)

Appendix F SDG&E SONGS Decommissioning Costs (100%)

San Diego Gas & Electric Company (SDG&E) provides the following information regarding its internal decommissioning costs, which it expects to incur and to fund on its own behalf (100%) in addition to its 20% share of the Decommissioning Cost Estimate.

I. BACKGROUND As the 20% minority owner, SDG&E is contractually obligated to pay its 20% ownership share of decommissioning expenses for SONGS. These costs, outlined in the DCE, will be incurred by the decommissioning agent and SDG&E will receive invoicing for its proportional share.

II. SDG&E COSTS Table F-1 SDG&E SONGS DECOMMISSIONING COSTS (1,000's,

$2014)

Total SDG&E Other/ Total Units 2 & 3 Labor Non-Labor Costs License Termination $3,832 $1,047 $4,879 Spent Fuel Management $2,729 $417 $3,147 Management Site Re $1,904 $401 $2,305 Restoration Total $8,465 $1,865 $10,330 In addition to SDG&E's 20% share of the costs outlined in the DCE, SDG&E also incurs internal costs related to its SONGS ownership. SDG&E incurs 100% of these Labor and Non-Labor costs related to SDG&E's oversight activities. These costs are apportioned into SCE's DCE categories of License Termination, Spent Fuel Management, and Site Restoration by determining the percentage of costs SCE allocated to each category and multiplying SDG&E's Page 1 of 5

Appendix F SDG&E SONGS Decommissioning Costs (100%)

costs by that same percentage for each category. SDG&E estimates that its total internal costs over the decommissioning period to be $10.33 million (2014$).

a. SDG&E LABOR The first category, "SDG&E Labor" includes SDG&E staff who provide oversight of SONGS costs and activities. SDG&E's internal staffing efforts are expected to mirror site staffing where the three (3) full-time equivalents ("FTEs") are reduced after 2016 to two (2)

FTEs, then to one (1) FTE after 2025, and eventually to zero (0) FTEs after 2032. After 2032, invoicing and oversight activities are anticipated to be minor during this period. Once ISFSI decommissioning is initiated on or around 2049, SDG&E plans to identify one (1) full-time equivalent through 2052.

These costs are shown in Table F-1 under the column heading of "SDG&E Labor" and are apportioned into SCE's categories of License Termination, Spent Fuel Management, and Site Restoration.

b. OTHER/NON-LABOR The second type of SDG&E-specific costs are "Other/Non-Labor", which consist of outside decommissioning consultants and direct costs related to oversight activities.

To provide oversight of decommissioning activities, SDG&E has retained an external decommissioning consultant who has the expertise SDG&E requires. The external consultant is utilized to a greater extent through 2016 and then the consultant services are tapered off annually through 2025.

SDG&E also incurs direct costs related specifically to SDG&E's oversight activities at SONGS. These costs, which include travel reimbursement, phone services, training, and wireless Page 2 of 5

Appendix F SDG&E SONGS Decommissioning Costs (100%)

communication from SONGS, will coincide with the number of SDG&E SONGS oversight personnel FTEs.

These costs are shown in Table F- 1 under the column heading of Other/Non-labor and are apportioned into SCE's categories of License Termination, Spent Fuel Management, and Site Restoration.

III. CONCLUSION All of SDG&E's internal decommissioning costs presented in Table F-1 are separate and distinct from the costs incurred by the decommissioning agent and invoiced to SDG&E.

SDG&E will seek authority to access its nuclear decommissioning trust funds to pay for its proportional share of SONGS related decommissioning expenses and for its internal decommissioning costs incurred through a Commission-approved advice letter process consistent with the terms of the SDG&E Master Trust Agreement, and relevant rules and regulations of the Internal Revenue Service and the Nuclear Regulatory Commission.

Page 3 of 5

SDG&E SONGS Detailed Annual Expenditures Base Case:Prompt DECON, Time Reasonable Schedule, DOE Repository Opening 2024, Utility and DGC, Dry Storage (2014 Dollars in Thousands)

Account Totals Unit 2 UnitI T.1al S pent Fuel Ma rtagamoot 3491 so 01 Site Restoration 1 $7611 "01 13 $1.14304-.94 $ 41 $235

$4,016 $0 $823 $4,450 $0 $1,041 $8,465 $0 $1,86S $10,330 Unit 2 Unit 3

-. Fort 58.OW-Oý Oo 5715 213 085 $0 4 0 08 01.1 50$Do 0 W; 12 $08 $08 581 08 15 0 8 so S $08 08 0 2014 $24Q $0 $41 $122 $0 1 so 0. 128 $0 $5 SO 235 so $41 $122 so s3 S2 $0' $28 08 so $0 201 1.25, $0 020 $S233 10 088o t $5 so, 03

$0B 1 23 $123 so$01 $71 $15 $0 $5 $08 08 s

$1133 so 141 120 0o $ $10 so 308 1134 so3 10 85 5200 $0 5 so 3 0 so $0 20S1 see so $77 $130 SO $23 $4 0 12 10 $6 so' 171 so 533 $138 $0 534 $0 so $4 S0 so so 2010 $74 0o 34 $144 08 $24 so $0 $0 so! 0so So $13 so 567 $145 $0 036 50 so s0 so $0 s0 2019 $162 $0 $47 178 so 57 $0 so $21' s0 so $127 0 546$79 $0 $10 $1 0 121 50 0 so 2020 S24 s0 $8 I11 s0 $1 so 08 so sot $01 s0 $174 so0 s0 11' $0 $1 $5 s0 50 so so $0 2021 $19 so $35 $13 08: $ 08 s0 so 08 08 $X12 $0 594 $13 $0 $1 $1 s0 so so so 0 20224 08 $M 12 $1 so so $5 so 08 so so 03 120 $0 $1 $1 so $0 $0 $0 $0 20 13 $0 $57 $

$52 $0- Sso

$0o 118 51 -12 2024 1139 0. $14 so 139! 1 54.... $21 so SO' 8 $125, so $13 $20' $7' $08 so 2025 2ozq1

$0 so $51 123 so! so $so7s*so 50 S 8 so $0O SO 7 o s:

$0 $' $23 $0 *08 $79

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$030 $0 $20

$0 so so $0 27 $ 1 so 930 08 so 574

$$1 so 17 $.0 0 so9 7 5s: 08 I 130 21O 2"$ so So $0 50

$7 so SoS $0

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Page 4 of 5

SDG&E SONGS Detailed Annual Expenditures Base Cal Prompt DECON, Time Reasonable Schedule, DOE Repository Opening 2024, Utility end DGC, Dry Storage (2014 Dollars in Thousands)

Account Totals unit 2 Unit 3 Toed Uoeýs Termination1!3sI see.Resoratasion 1 7611 153 1.431 Sol $241 1 1,9041 N

$"I1 $0 $523 S4,450 $0 $1,041 $8,466 $0 sI866 $10,360 Unit 2 and 3 Total Unit 2 and 3 Project Totals 20M3 1-0 SO 01 10S O1 0182: $3 $236 2014 0474 $0 1243 12 SO so 1$6 SI 0 so 1007 5294 106 $906 2015 5453 10 14 0240 $0 $137 $21 0 S10 1 0 10 s 0 W, 2 531 "M 2016 26 *5 u 0 '

66 00 553 144 so1 541 10 SO so 532 0462 SO0 $0 201,7 $19 so $100 1 S0 s 7 $0o so S1 SO $0 10 12 34 $15 5610 201 $157 so $101 52 s0 s 1 so 10 10 10 10 10 $258 134' 10 06 21 86 10 503 $107 80 SI1 $1 10 042 10 10. 10 $ $5173 543 1000 2020 146 10s $130 523 so S2 $5 10 so 10 10 s0 1007 525 10 1508 2021 S41$ 10 129 $260 0 $2 S1 S1 10 so 10 so $548 620 82 1076 202 2022 S309 W,

$404 10 $107 ..

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10 111 so 10' 10 ý 'S 10 S5011 S"

$511 so3 . ...

$13 10656.

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Page 5 of 5