Application No.: 16-03-XXX Exhibit No.: SCE-04 Witnesses: Jose L. Perez

(U 338-E)

Testimony On 2016 SONGS 1 Decommissioning Cost Estimate

Before the Public Utilities Commission of the State of California

Rosemead, CaliforniaMarch 1, 2016

SCE-04: Testimony on SONGS 1 Decommissioning Cost Estimate Table Of Contents

Section Page Witness

-i-

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

II.� SONGS 1 DECOMMISSIONING PROJECT OVERVIEW ............................2�

A.� Decommissioning Requirements ...........................................................2�

B.� Status ......................................................................................................2�

C.� 2016 SONGS 1 DCE .............................................................................3�

1.� Summary ....................................................................................3�

2.� Key Revisions ............................................................................4�

III.� 2016 SONGS 1 DCE .........................................................................................6�

A.� Major Assumptions ................................................................................6�

1.� Low-Level Radioactive Waste (LLRW) Disposal .....................6�

2.� Appropriateness and Conservatism of Contingency Factor .........................................................................................6�

B.� Cost Estimate For Remaining Decommissioning Work ........................7�

1.� License Termination Period .......................................................8�

a)� Decon PD 7 – Decommissioning During Fuel Storage – Unit 1 .....................................................8�

b)� Decon PD 8 – License Termination During Final Site Restoration – Unit 1 ......................................9�

2.� Spent Fuel Management Period .................................................9�

a)� SNF PD 2 – Dry Storage During Decommissioning – Unit 1 ............................................9�

b)� SNF PD 3 – Dry Storage During Decommissioning – Units 1, 2, & 3 ...............................9�

c)� SNF PD 4 – Dry Storage Only – Units 1, 2, & 3 .................................................................................9�

SCE-04: Testimony on SONGS 1 Decommissioning Cost Estimate Table Of Contents (Continued)

Section Page Witness

-ii-

d)� SNF D&D PD 1 – ISFSI License Termination ..................................................................10�

e)� SNF D&D PD 2 – ISFSI Demolition ...........................10�

3.� Site Restoration Period ............................................................10�

a)� SR PD 7 – Planning for Completion of Unit 1 Site Restoration .........................................................10�

b)� SR PD 8 – Final Site Restoration and Lease Termination – Unit 1 ....................................................10�

IV.� RECONCILIATION OF 2016 DCE TO THE 2012 DCE ...............................12�

A.� Reconciliation of the DCEs .................................................................12�

1.� Undistributed Costs ..................................................................13�

2.� Full Removal of Offshore Intake/Discharge Conduits ...................................................................................14�

3.� License Termination Activities ................................................15�

4.� Subsurface Structure Removal .................................................15�

Appendix 1 2016 SONGS 1 DCE�

Appendix 2 Witness Qualifications�

SCE-04: Testimony on SONGS 1 Decommissioning Cost Estimate List Of Tables

Table Page

-iii-

Table III-1 Cost Estimate for Remaining SONGS 1 Decommissioning Work

100% Share, 2014$ in Millions .............................................................................................................8�

Table IV-2 Increase in DCE 100% Share, $ in Millions ...........................................................................12�

Table IV-3 Changes in 2016 SONGS 1 DCE 100% Share, 2014 $ in Millions ........................................13�

Table IV-4 Undistributed Expenses 100% Share, 2014$ in Millions ........................................................14�

Table IV-5 License Termination Activities 100% Share, 2014$ in Millions ............................................15�

SCE-04: Testimony on SONGS 1 Decommissioning Cost Estimate List Of Figures

Figure Page

-iv-

Figure IV-1 2016 SONGS 1 DCE Compared to the 2012 SONGS 1 DCE 100% Share, $

in Millions ............................................................................................................................................13�

1

I. 1

INTRODUCTION 2

This testimony demonstrates the reasonableness of the 2016 San Onofre Nuclear Generating 3

Station Unit No. 1 (SONGS 1) Decommissioning Cost Estimate (DCE).1 The 2016 SONGS 1 DCE 4

will be utilized in Exhibit SCE-06 (Financial Testimony) to support the analysis regarding whether the 5

SONGS 1 nuclear decommissioning trusts (NDTs) are sufficiently funded and whether additional 6

customer contributions are required. The DCE will also serve as the basis for the Commission’s 7

reasonableness reviews of SONGS 1 decommissioning costs in the next NDCTP or reasonableness 8

review proceeding designated by the Commission. 9

In this testimony, SCE requests that the Commission approve the 2016 SONGS 1 DCE of 10

$239.4 million (100% share, 2014$) as reasonable. 11

1 Southern California Edison Company (SCE) and San Diego Gas & Electric Company (SDG&E) own 80%

and 20% interests in SONGS 1, respectively. SCE permanently retired SONGS 1 on November 30, 1992.

2

II. 1

SONGS 1 DECOMMISSIONING PROJECT OVERVIEW 2

A. Decommissioning Requirements 3

As one of the Nuclear Regulatory Commission (NRC) licensees for SONGS 1, SCE has an 4

obligation, under federal regulations, to decommission SONGS 1.2 SCE does not own the site upon 5

which SONGS 1, 2, & 3 are located. Instead, SCE is authorized to use the site under a grant of 6

easement from the U.S. Department of the Navy (Navy) and an easement-lease from the California State 7

Lands Commission (CSLC). These documents require SCE to decommission SONGS 1.3 8

B. Status 9

SCE has completed a large part of SONGS 1 decommissioning. With the permanent shutdown 10

of SONGS 2&3, the remaining decommissioning work for SONGS 1 will be completed concurrently 11

with SONGS 2&3 decommissioning. SCE plans to retain a decommissioning general contractor (DGC) 12

to complete major SONGS 1, 2, & 3 decommissioning activities. 13

2 According to 10 C.F.R. § 50.2, “Decommissioning means to remove a facility or site safely from service and

reduce residual radioactivity to a level that permits -- (1) Release of the property for unrestricted use and termination of the license….” 10 C.F.R. § 50.82(a)(3) provides that, “Decommissioning will be completed within 60 years of permanent cessation of operations….” The regulation allows for an extension of this period for multi-unit sites, such as SONGS.

3 Paragraph 12 of the Grant of Easement with the Navy for the onshore site provides, “That upon termination of the easement granted herein, the Grantees at their expense may remove, and if desired by the government, shall remove any and all improvements installed or constructed hereunder and shall restore the Premises to a condition satisfactory to the Director, Southwest Division, Bureau of Yards and Docks; except that the Grantees shall not be obligated to restore any natural material cut or filled in the necessary excavation and grading of the Premises. Upon termination of the easement, the Grantees shall also, if required by the Government, decontaminate the Premises and such surrounding area within the Reservation as may have been contaminated by the operation of the Nuclear Station.”

Paragraph 14 of the Easement Lease P.R.C. No. 3193.1 with the California State Lands Commission for the site of the offshore circulating water conduits was amended in 2005 to no longer require the complete removal of the conduits. Under the amended agreement, SCE is required to remove all vertical structures that protrude above the seafloor, and to install mammal barriers over each resulting opening. The remainder of the conduits located below the seafloor will remain in place. SCE retains the liability for any required future removal of the conduits.

3

C. 2016 SONGS 1 DCE 1

1. Summary 2

The 2016 SONGS 1 DCE identifies the remaining decommissioning work to be completed at 3

SONGS 1, as of January 1, 2016.4 The 2016 SONGS 1 DCE (Appendix 1) prepared by EnergySolutions 4

is based on updated reviews of the known physical work remaining to be completed on-site and 5

allowances for activities such as reactor pressure vessel (RPV) disposal for which detailed cost 6

information is not yet available. 7

SCE will continue to maintain and monitor the SONGS 1 spent fuel at the ISFSI until the spent 8

fuel is removed for shipment to a Department of Energy (DOE) repository. SCE also installed 15 wells 9

as part of the Nuclear Energy Institute (NEI) Ground Water Protection Initiative and will continue to 10

monitor the ground water beneath the SONGS 1 site for the presence of tritium. The SONGS 1 offshore 11

intake and discharge conduits have been modified and will remain in place consistent with an 12

amendment to its easement-lease with the CSLC.5 Notwithstanding, the DCE includes the cost for 13

completely removing the conduits, because SCE retains the liability for any required future removal of 14

the conduits. 15

The DCE also includes costs for removal and disposal of the SONGS 1 RPV package at a 16

licensed low level radioactive waste (LLRW) disposal facility. There are two LLRW disposal facilities 17

that may be available to accept the SONGS 1 RPV package, EnergySolutions’ facility in Clive, Utah and 18

Waste Control Specialists’ (WCS) facility in Andrews County, Texas. SCE, with the DGC, will 19

4 Phase I decommissioning activities were performed between July 1999 and December 2008, and included, (1)

the decontamination, dismantling, and disposal of all contaminated and non-contaminated SONGS 1 equipment, components, and structures that were either installed above-ground or below-ground but above the water table, (2) the installation of low-density concrete within void spaces in structures below the water table to ensure stability of the site, and (3) the licensing and construction of a SONGS 1 spent fuel dry storage facility on the SONGS 1 site, the fabrication of dry storage canisters, and the loading and placement of all SONGS 1 spent fuel stored at SONGS and one canister of Greater Than Class C (GTCC) waste from SONGS 1 into the spent fuel dry storage facility.

5 Amendment of an Easement Lease P.R.C. 3196.3, California State Lands Commission to Southern California Edison Company and San Diego Gas & Electric Company, effective on November 1, 2005.

4

evaluate the possibility of shipping the SONGS 1 RPV package for permanent disposal at one of these 1

facilities. 2

The 2016 SONGS 1 DCE generally includes a 25% contingency for the remaining 3

decommissioning work. The 25% contingency follows the 2012 SONGS 1 DCE adopted by the 4

Commission in the 2012 NDCTP.6 5

2. Key Revisions 6

In prior decommissioning estimates, SONGS 1 decommissioning comprised a phased approach 7

with: (1) Phase 1 involving major decommissioning activities, including the construction of the 8

Independent Spent Fuel Storage Installation (ISFSI) and placing all SONGS 1 spent fuel on the ISFSI; 9

(2) Phase II involving the maintenance and monitoring of the SONGS 1 spent fuel stored at the SONGS 10

ISFSI and disposition of the offshore conduits; and (3) Phase III involving the removal of any remaining 11

residual radioactivity required for SONGS 1 license termination with the NRC, and termination of the 12

Navy easement, including final site restoration. With the commencement of SONGS 2&3 13

decommissioning, EnergySolutions conformed the 2016 SONGS 1 DCE to the format and methodology 14

used for the more-recent 2014 SONGS 2&3 DCE,7 including the same decommissioning cost categories 15

and periods. Therefore, EnergySolutions used license termination, spent fuel management, and site 16

restoration as the cost categories rather than the phased approach used in the 2012 DCE. Going forward, 17

the decommissioning of SONGS 1, 2, & 3 will be coordinated as one decommissioning project with a 18

DGC performing major decommissioning activities. 19

Decommissioning of the ISFSI and termination of the licenses will occur once the DOE has 20

removed all SONGS 1, 2, & 3 spent fuel from the ISFSI. As discussed in Exhibit SCE-01, the DCE 21

includes an updated assumption that the DOE will commence removing spent fuel from the industry in 22

2028 with no impact to the completion of site restoration in 2051. 23

Consistent with the 2028 assumption, and based on SCE’s studies developed from the DOE 24

Acceptance Priority Ranking & Annual Capacity Report (DOE/RW-0567), dated July 2004, SCE 25

6 D.14-12-082, Conclusion of Law No. 10, p. 137. 7 A.14-12-007, SCE-01 Testimony on the Nuclear Decommissioning of SONGS 2&3

5

projects that the DOE will remove the last SONGS 1 spent fuel from the ISFSI in 2034. By 2049, all the 1

SONGS 2&3 spent fuel would have been removed from the ISFSI and the remaining activities of the 2

spent fuel management and site restoration periods to complete SONGS 1 decommissioning can be 3

performed. These activities include: (1) removing and disposing of all remaining above-ground 4

structures, except any the Navy requests be left in place; (2) dismantling and disposing of the ISFSI; (3) 5

excavating and disposing of all remaining SONGS 1 below-grade appurtenances and structural 6

foundations, including any remaining radioactively contaminated materials that exceed the NRC 7

standard for license termination; (4) backfilling and compacting the void spaces left after removal of all 8

below-grade structures and foundations; (5) submitting a license termination plan to the NRC and 9

terminating the NRC license; (6) completing the final site restoration work; and (7) terminating the grant 10

of easement from the Navy for the plant site. SCE projects that all decommissioning activities will be 11

completed by 2051, approximately two years after the removal of all SONGS spent fuel from the 12

SONGS ISFSI. As noted in Exhibit SCE-01, the projected dates discussed above are utilized only for 13

the purpose of financial analysis and determining the sufficiency of the NDTs and customer contribution 14

levels. It may be appropriate to adopt different assumptions for other planning purposes. 15

6

III. 1

2016 SONGS 1 DCE 2

A. Major Assumptions 3

1. Low-Level Radioactive Waste (LLRW) Disposal 4

The 2016 SONGS 1 DCE assumes that only Class A, Class C, and GTCC LLRW still remain at 5

SONGS 1. The estimated disposal cost for the remaining LLRW is $57.3 million (100% share, 2014$), 6

which is incorporated in the cost categories and periods identified in Table III-1 below.8 7

2. Appropriateness and Conservatism of Contingency Factor 8

A 25% contingency is generally applied for the remaining decommissioning work. 9

Contingencies are applied to cost estimates to account for unknown or unplanned occurrences during the 10

performance of a project. “Contingencies” are defined in the American Association of Cost Engineers 11

Project and Cost Engineers’ Handbook as, “specific provision for unforeseeable elements of cost within 12

the defined project scope; particularly important where previous experience relating to estimates and 13

actual costs has shown that unforeseeable events which will increase costs are likely to occur.” The 14

consensus in the industry literature, including sources from the DOE9 and the Association for the 15

8 The 2016 SONGS 1 DCE assumes that Class A LLRW will be shipped to the EnergySolutions LLRW

disposal facility in Clive, Utah, under the terms of the Life-of-Plant Disposal Agreement that SCE has with EnergySolutions. The DCE also assumes that Class C waste will be shipped to the WCS facility in Andrews County, Texas, the only facility in the United States that will accept Class B or C LLRW from waste generators outside the Texas compact. The estimated volumes and costs incurred for the disposal of LLRW remaining at SONGS 1 are shown in the table below:

Line Volume Package Transport Burial Disposal 1 Class A 723 cu ft $0.0 $0.0 $0.1 $0.12 Class C 7,598 cu ft $0.5 $16.8 $36.3 $53.63 GTCC 167 $0.0 $0.2 $3.4 $3.6

SONGS 1 LLRW 100% Share, 2014 $ in Millions

9 Chapter 11 of U.S. Department of Energy Decommissioning Implementation Guide DOE, G 430.1-1, March

28, 1997.

7

Advancement of Cost Engineering International (AACE),10 is that a contingency factor for cost 1

estimates in this stage of development should fall within a range of 15% to 30%. In a previous NDCTP, 2

PG&E prepared a paper entitled, Technical Position Paper for Establishing an Appropriate Contingency 3

Factor for Inclusion in the Decommissioning Revenue Requirements, dated February 2008. Based on 4

industry and regulatory documents, the position paper concludes that it is appropriate to add a 25% 5

contingency factor to estimated decommissioning costs because it provides reasonable assurance for 6

unforeseen circumstances11 that could increase decommissioning costs, and should not be reduced or 7

eliminated simply because foreseeable costs are low. Accordingly, EnergySolutions applied a 25% 8

contingency factor to develop the DCE. 9

B. Cost Estimate For Remaining Decommissioning Work 10

The testimony below briefly discusses the work to be performed in each period. Table III-1 11

summarizes the estimated costs for the SONGS 1 remaining decommissioning work as of January 1, 12

2016. 13

10 Association for the Advancement of Cost Engineering International (AACE) Recommended Practice No.

18R-97, at p. 2 of 9. 11 For example, some activities in the remaining decommissioning work (such as reactor vessel segmentation,

packaging, shipping, and disposal) are less familiar activities in the industry. In addition, no nuclear facility has performed environmental restoration work to the extent that SCE may be required to terminate the easement with the Navy.

8

Table III-1 Cost Estimate for Remaining SONGS 1 Decommissioning Work

100% Share, 2014$ in Millions

1. License Termination Period 1

a) Decon PD 7 – Decommissioning During Fuel Storage – Unit 1 2

In the 2016 SONGS 1 DCE, this period runs from 2016-2049. The SONGS 1 RPV package is 3

being temporarily staged in the northeast corner of the north industrial area (NIA). This period includes 4

distributed costs primarily for disposing the SONGS 1 RPV package. After the DGC has been selected, 5

the disposal options for the SONGS 1 RPV will be evaluated. The engineering and design for the 6

selected disposal option will be implemented and the RPV package will be transported and disposed. 7

Until this is completed, the RPV package will continue to require maintenance, such as radiological 8

surveys and painting. 9

The period also includes undistributed costs for insurance, NRC fees, and ground water 10

monitoring. 11

Line Period No. Description Distributed Cost Undistributed Cost Total12 License Termination 3 Decon Pd 7 Decommissioning During Fuel Storage 88.7 20.2 108.94 Decon Pd 8 License Termination During Final Site Restoration 7.2 1.4 8.65 Category Total 95.9 21.6 117.567 Spent Fuel (SONGS 1 share)8 SNF Pd 2 1.1 1.19 SNF Pd 3 Dry Storage During Decommissioning 19.1 19.110 SNF Pd 4 Dry Storage Only 5.4 5.411 SNF D&D Pd 1 ISFSI License Termination 0.1 0.112 SNF D&D Pd 2 ISFSI Demolition 3.7 1.1 4.813 Category Total 3.7 26.8 30.51415 Site Restoration16 SR Pd 7 Planning for Completion of Unit 1 Site Restoration 2.7 1.9 4.617 SR Pd 8 Final Site Restoration and Lease Termination 76.5 10.3 86.818 Category Total 79.2 12.2 91.419 Grand Total 178.8 60.6 239.4

9

b) Decon PD 8 – License Termination During Final Site Restoration – Unit 1 1

In the 2016 SONGS 1 DCE, this period runs from 2049-2051. The activities in this period occur 2

during the last two years of the decommissioning project, concurrent with site restoration activities. 3

This period includes distributed costs for preparing and submitting the License Termination Plan to the 4

NRC for review and approval. In addition, the Final Site Survey will be prepared, and subsequently 5

submitted to and reviewed by the NRC and Oak Ridge Institute for Science and Education (ORISE). 6

The period also includes undistributed costs for insurance, NRC fees, materials and services, and 7

utility staff. 8

2. Spent Fuel Management Period 9

a) SNF PD 2 – Dry Storage During Decommissioning – Unit 1 10

In the 2016 SONGS 1 DCE, this period runs 2016-2019. The period does not include distributed 11

costs (because there are no physical activities related to SONGS 1),12 and only includes undistributed 12

costs for nuclear liability insurance. 13

b) SNF PD 3 – Dry Storage During Decommissioning – Units 1, 2, & 3 14

In the 2016 SONGS 1 DCE, this period runs from 2019-2031. The period does not include 15

distributed costs (because there are no physical activities related to SONGS 1), and includes only 16

undistributed costs for insurance, NRC fees, utility staffing, health physics supplies, security force and 17

related expenses, maintenance, materials and services, energy, and utilities (water, gas, and phone). 18

c) SNF PD 4 – Dry Storage Only – Units 1, 2, & 3 19

In the 2016 SONGS 1 DCE, this period runs 2031-2034. The period includes distributed costs 20

for removing all SONGS 1 spent fuel and GTCC waste from the ISFSI. The SONGS 1 spent fuel and 21

GTCC waste at the ISFSI will be loaded onto a transporter for shipment by DOE beginning in 2028. 22

This period is similar to the previous period and will include the same type of undistributed 23

costs associated with insurance, NRC fees, an increase in utility staffing, health physics supplies, 24

12 As discussed above, EnergySolutions conformed the 2016 SONGS 1 DCE to the format and methodology of

the 2014 SONGS 2&3 DCE. Therefore, EnergySolutions included SNF PD 2 in the 2016 SONGS 1 DCE. However, there are no physical activities and associated distributed costs related to SONGS 1 in this period.

10

security force and related expenses, maintenance, materials and services, energy, utilities (water, gas, 1

and phone), and in addition, includes expenses for the site lease and easement. 2

d) SNF D&D PD 1 – ISFSI License Termination 3

In the 2016 SONGS 1 DCE, this period runs from 2049-2050. The period includes 4

undistributed costs for insurance, NRC fees, utility staffing, security force and related expenses, 5

materials and services, energy, utilities (water, gas, and phone), and site lease and easement expenses. 6

e) SNF D&D PD 2 – ISFSI Demolition 7

In the 2016 SONGS 1 DCE, this period runs from 2050-2051, when the ISFSI will be 8

decommissioned. The period includes distributed costs for ISFSI decommissioning, which will be 9

apportioned between SONGS 1 and SONGS 2&3 based on a weighted average of the quantity of spent 10

fuel from each unit stored in the ISFSI throughout its useful life. 11

The period also includes undistributed costs for utility staffing, health physics supplies, security 12

force and related expenses, DGC staffing, training and supplies, materials and services, LLRW disposal, 13

energy, and utilities (water, gas, and phone). 14

3. Site Restoration Period 15

a) SR PD 7 – Planning for Completion of Unit 1 Site Restoration 16

In the 2016 SONGS 1 DCE, this period runs 2048-2050. The period includes distributed costs 17

related to the engineering, planning, and design activities that will take place for subsurface structure 18

removal, final site grading, environmental impact analyses for lease termination and, if necessary, 19

outfall conduit removal. The required permits and approvals for these activities also will be obtained. 20

The period also includes undistributed costs for utility staffing, DGC staffing, and materials and 21

services. 22

b) SR PD 8 – Final Site Restoration and Lease Termination – Unit 1 23

In the 2016 SONGS 1 DCE, this period runs from 2050-2051. The period includes distributed 24

costs for installation of a dewatering system and excavation, removal, and disposal of several subsurface 25

structures as required by the Navy. In addition, shoreline erosion control and restoration will be 26

installed with the final grading and re-vegetation of the site. 27

11

The period also includes undistributed costs for utility staffing, DGC staffing, and materials and 1

services. 2

At the conclusion of this period, the SONGS site will be completely decommissioned, licenses 3

terminated, site restoration completed, and Navy easement terminated. 4

12

IV. 1

RECONCILIATION OF 2016 DCE TO THE 2012 DCE 2

A. Reconciliation of the DCEs 3

The 2016 SONGS 1 DCE of $239.4 million (100% share, 2014$) is for the remaining 4

decommissioning work to be completed for SONGS 1, as of January 1, 2016. In the 2012 NDCTP, the 5

2012 SONGS 1 DCE of $182.3 million (100% share, 2011$) was determined to be reasonable by the 6

Commission. The 2012 DCE included $12.4 million (100% share, 2011$) for work to be performed in 7

2013-2015.13 Subtracting the $12.4 million from the 2012 DCE results in a remaining estimate of 8

$169.9 million going forward. The difference between the 2012 and 2016 estimates is identified in 9

Table IV-2 and discussed below. 10

Table IV-2 Increase in DCE

100% Share, $ in Millions

There is an increase of $69.5 million from the 2012 DCE to the 2016 DCE for the remaining 11

decommissioning work beyond January 1, 2016. The increase in the 2016 SONGS 1 DCE is due to the 12

following decommissioning activities and items shown in Table IV-3 and Figure IV-1 below. 13

13 A.12-12-013, Workpapers for Exhibit SCE-1, SONGS 1 Cost Study for Remaining Decommissioning Work,

December 2012 Table 2, page 59.

Line No. Item Estimate1 2016 DCE $239.42 2012 DCE $169.93 Increase $69.5

13

Table IV-3 Changes in 2016 SONGS 1 DCE 100% Share, 2014 $ in Millions

Line No. Item Variance1 Undistributed costs 37.0 2 Full removal of intake/discharge conduits 35.7 3 License termination 10.5 4 Subsurface structure removal (38.4)5 Misc 13.7 6 Escalation 11.0 7 Total increase 69.5

Figure IV-1

2016 SONGS 1 DCE Compared to the 2012 SONGS 1 DCE 100% Share, $ in Millions

1. Undistributed Costs 1

The 2012 DCE did not include certain necessary and unavoidable undistributed costs that SCE 2

will be required to incur from 2016-2051 for SONGS 1 decommissioning. The items identified in Table 3

IV-4 have been included in the 2016 DCE: 4

14

Table IV-4 Undistributed Expenses

100% Share, 2014$ in Millions Line No. Item Variance

1 Insurance 6.52 NRC Fees 11.53 Energy, Utilities, & Other 10.94 Ground Water Monitoring 8.05 Lease/Easement Fees 0.16 Total 37.0

The insurance costs are based on information provided to EnergySolutions by SCE for nuclear 1

property and liability, non-nuclear liability, workers’ compensation, and property insurance.14 The NRC 2

fees are based on NRC regulatory requirements ($230,000 per year) and NRC inspections ($110,000 per 3

year).15 Energy, utilities, and other costs were also provided by SCE.16 Prior to the permanent 4

retirement of SONGS 2&3, SCE was able to use the generation from SONGS 2&3 for SONGS 1 5

decommissioning energy requirements; therefore, energy costs were not included in prior SONGS 1 6

DCEs. The energy costs are based on SDG&E retail rates. The ground water monitoring costs ($30,000 7

for labor and $150,000 for analysis per year) are necessary for SCE to continue to implement the NEI 8

07-07 Ground Water Protection Initiative. The easement fees are for the Navy easement for the SONGS 9

1 site. 10

2. Full Removal of Offshore Intake/Discharge Conduits 11

Paragraph 14 of the Easement Lease P.R.C. No. 3193.1 with the CSLC for the site of the 12

offshore circulating water conduits was amended effective in 2005 to no longer require the complete 13

removal of the conduits. The amended agreement required SCE to remove all vertical structures that 14

protrude above the seafloor, and to install mammal barriers over each resulting opening. The remainder 15

of the conduits located below the seafloor will remain in place. SCE retains the liability for any required 16

14 EnergySolutions 2016 Decommissioning Cost Analysis of the San Onofre Nuclear Generating Station Unit 1,

dated February 16, 2016, Section 5.0, Item 19, page 20. 15 Id., Section 5.0, Items 16, 17, and 18, pages 19 and 20. 16 Id., Section 5.0, Item 20, page 20.

15

future removal of the conduits. Accordingly, SCE has included the cost to comply with this potential 1

liability in the current estimate. The cost in the 2016 DCE to completely remove and dispose of the 2

conduits is $35.7 million. This estimate includes the cost for a survey and environmental assessment, 3

engineering planning and design, permits and approvals, and the actual removal of the conduits. 4

3. License Termination Activities 5

The 2012 SONGS 1 DCE included $4.5 million in 2011$ ($4.8 million in 2014$) for the ISFSI 6

decommissioning, final site survey, NRC license termination, final site restoration, and Navy easement 7

termination. The 2016 SONGS 1 DCE includes $15.2 million for these activities. Table IV-6 below 8

provides a detailed breakdown of these expenses. 9

Table IV-5 License Termination Activities 100% Share, 2014$ in Millions

Line No. Item Estimate

1 ISFSI decommissioning 1.82 License termination plan 0.73 Final site survey 5.64 NRC approval 0.95 Environmental analyses for lease termination 0.26 Equipment, final site grading, and shoreline protection 5.67 Permits and approvals 0.48 Total 15.2

There is a $10.4 million variance in license termination expenses between the 2016 SONGS 1 10

DCE and 2012 SONGS 1 DCE (when the 2012 DCE is escalated to 2014$). The detailed breakdown of 11

the license termination by EnergySolutions in the 2016 SONGS 1 DCE is consistent with activities 12

identified in the 2014 SONGS 2&3 DCE. The estimates are based on EnergySolutions experience with 13

decommissioning projects. 14

4. Subsurface Structure Removal 15

The 2012 SONGS 1 DCE included $71.1 million in 2011$ ($75.7 million in 2014$) for the 16

removal of foundations and subsurface structures. This scope includes the removal of the containment 17

sphere foundation, sphere enclosure building foundation, miscellaneous storm drain systems, and 18

16

miscellaneous subsurface systems and foundations. The storm drain systems were assumed to be 100% 1

contaminated and the miscellaneous system and foundations were assumed to be 10% contaminated. 2

The contaminated structures were assumed to require disposal at a licensed LLRW facility. 3

The 2016 SONGS 1 DCE identifies $37.3 million (2014$) for the removal of these foundations 4

and subsurface structures. The 2012 DCE estimate is $38.4 million (2014$) higher than the 2016 DCE 5

estimate. The 2016 DCE is lower due to a revised assumption that there will be less contamination of 6

the structures and less of a need for LLRW disposal. This assumption is based on the decay of the 7

radiological activity in the subsurface structures from the time of the shutdown of SONGS 1 in 1992 8

until the time for site restoration and removal of the subsurface structures in 2050. Therefore, a large 9

part of the subsurface structure can be disposed of at a landfill rather than an LLRW disposal facility. 10

Appendix 1

2016 SONGS 1 DCE

Electronic documents, once printed, are uncontrolled and may become outdated. Refer to Document Control authority for the correct revision.

Document No. 164007-DCE-017

2016 Decommissioning Cost Analysis of the

San Onofre Nuclear Generating Station Unit 1

Project No. 164007 Revision 0

Prepared for: Southern California Edison. 2244 Walnut Grove Avenue

Rosemead, CA 91770

Prepared by: EnergySolutions, LLC

1009 Commerce Park Drive Suite 100

Oak Ridge, TN 37830

: 2-23-16 Robert C. Woodard, Project Director Date

2-23-16 Barry S. Sims, Technical Advisor Date

X New Report

Title Change

Report Revision

Report Rewrite

EffectiveDate

2-23-2016

Appendix 1-1

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page i

TABLE OF CONTENTS

Section Page

1.0� EXECUTIVE SUMMARY ................................................................................................ 1�

2.0 INTRODUCTION .............................................................................................................. 4�2.1� Study Objective....................................................................................................... 4�2.2 Regulatory Framework ........................................................................................... 5�

3.0 STUDY METHODOLOGY ............................................................................................... 8�3.1� General Description ................................................................................................ 8�3.2� Schedule Analysis................................................................................................... 8�3.3� Decommissioning Staff........................................................................................... 9�3.4� Waste Disposal........................................................................................................ 9�3.5� Final Status Survey ............................................................................................... 12�3.6� Contingency .......................................................................................................... 12�3.7� Cost Reporting ...................................................................................................... 12�

4.0 SITE SPECIFIC TECHNICAL APPROACH.................................................................. 13�4.1� Facility Description............................................................................................... 13 4.2� Decommissioning Status of Unit 1 ....................................................................... 13�4.3� Decommissioning Periods .................................................................................... 14�4.4� Decommissioning Staff......................................................................................... 17�4.5� Spent Fuel Management Staff............................................................................... 17 4.6� Spent Fuel Shipments ........................................................................................... 17

5.0 BASES OF ESTIMATE AND KEY ASSUMPTIONS.................................................... 18�

6.0 STUDY RESULTS........................................................................................................... 22�

7.0 REFERENCES ................................................................................................................. 29�

FIGURES

Figure 1-1 Summary Schedule ...............................................................................................3 Figure 6-1 Summary Schedule .............................................................................................24

TABLES

Table 1-1 Decommissioning Cost Summary............................................................................2 Table 6-1 Cost and Schedule Summary .................................................................................25 Table 6-2 Decom Agent Levels ............................................................................................26 Table 6-3 DGC Staff Levels ............................................................................................27 Table 6-4 Waste Disposal Volumes .......................................................................................28

Appendix 1-2

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page ii

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 1-3

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page iii

ACRONYMS AND ABBREVIATIONS

AHSM Advanced Horizontal Storage Modules AIF Atomic Industrial Forum ALARA As Low As Reasonably Achievable 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 FEMA Federal Emergency Management Agency FSS Final Status Survey FTE Full Time Equivalent GE General Electric GSA U.S. General Services Administration GTCC Greater Than Class C HP Health Physics IFMP Irradiated Fuel Management Plan 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 NDT Nuclear Decommissioning Trust NRC Nuclear Regulatory Commission NSSS Nuclear Steam Supply System ORISE Oak Ridge Institute for Science and Education PG&E Pacific Gas & Electric PSDAR Post-Shutdown Decommissioning Activities Report PWR Pressurized Water Reactor RIF Reduction In Force RPV Reactor Pressure Vessel SCE Southern California Edison SONGS San Onofre Nuclear Generating Station STRUCT Structure WBS Work Breakdown Structure WCS Waste Control Specialists LLC UCF Unit Cost Factor

Appendix 1-4

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 1

1.0 EXECUTIVE SUMMARY

This report presents the 2016 Decommissioning Cost Estimate Study of the San Onofre Nuclear Generating Station (SONGS) Unit 1, hereinafter referred to as U1-DCE-2016. The San Onofre Nuclear Generating Station is operated by the Southern California Edison Company (SCE).

This study is an update to the SONGS Unit 1 Cost Study for Remaining Decommissioning Work, dated March 2009 (Ref. No. 1). This study is integrated with the 2014 SONGS 2 & 3 DCE (Ref. No. 2) to ensure a consistent and efficient station decommissioning strategy. This study has been performed to furnish an estimate of the costs for: (1) decommissioning SONGS Unit 1 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 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. 3); and the California State Lands Commission Easement Lease (Ref. No. 4); and (4) Independent Spent Fuel Storage Installation (ISFSI) decommissioning pursuant to 10 CFR 72.30. EnergySolutions has established a Work Breakdown Structure (WBS) and cost accounting system to differentiate between these project accounts.

All spent fuel from Unit 1 (and some Greater-than-Class-C (GTCC) waste generated during segmentation of the reactor vessel internals) was transferred to the ISFSI between October 2003 and September 2004. The spent fuel from Unit 1 that was stored in fuel pools at Units 2 and 3 was transferred to the ISFSI between May and June 2005. In total there are 395 spent fuel assemblies from Unit 1 stored in 17 Multi-Purpose Canisters (MPCs) at the ISFSI (plus one MPC containing GTCC waste). An additional 270 spent fuel assemblies from Unit 1 are being stored by General Electric-Hitachi Nuclear America, LLC (hereinafter GE) in their spent fuel pool located in Morris, Illinois (hereinafter GE-Morris). The 270 spent fuel assemblies were shipped to GE-Morris before the ISFSI was constructed. Per the SONGS Units 2 & 3 Irradiated Fuel Management Plan (IFMP), the costs associated with ongoing storage of Unit 1 spent fuel at GE-Morris are currently funded from sources other than the Nuclear Decommissioning Trusts (NDT).

SCE’s December 2012 testimony to the CPUC provided the basis for previous estimated spent fuel management costs, based on a DOE start date assumption of 2024. This report uses a DOE start date assumption of 2028; the adjustment was made to account for the four years since the 2012 testimony, with no progress by DOE that would make a 2024 start date a credible assumption.

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

� Deferred completion of decommissioning and final site restoration pending completion of the transfer to DOE of all spent fuel located at the ISFSI.

� A total of 395 Unit 1 spent fuel assemblies are being stored in transportable MPCs at the ISFSI.

� An additional 270 Unit 1 spent fuel assemblies are being stored at GE Morris (the cost of which is not included in this estimate).

Appendix 1-5

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 2

� A dry transfer facility will not be necessary for transfer of spent fuel canisters for transport.

� DOE begins accepting spent fuel from the industry in 2028 and completes the removal of Unit 1 spent fuel from the ISFSI by 2034, and from GE-Morris by 2051.

� Remaining Unit 1 decommissioning and site restoration activities will be performed by a Decommissioning General Contractor (DGC), concurrent with the decommissioning of Units 2 & 3, with oversight by an entity defined by the co-participants, hereafter referred to as the Decom Agent.

� 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); 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) and ISFSI decommissioning pursuant to 10 CFR 72.30.

Table 1-1 Decommissioning Cost Summary

(2014 Dollars in Thousands)

Cost Account TotalLicense Termination 50.75(c) $117,530Spent Fuel Management 50.54(bb) $30,541Site Restoration $91,365Totals $239,436

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 man-hours, 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 schedule is shown in Figure 1-1, and may also be found in Section 6.0 of this report.

Appendix 1-6

2016

Dec

omm

issio

ning

Cos

t Ana

lysis

of t

he

Doc

umen

t No.

164

007-

DC

E-0

17

San

Ono

fre

Nuc

lear

Gen

erat

ing

Stat

ion

Uni

t 1

Rev

ision

0

Page

3

Figu

re 1

-1

Sum

mar

y Sc

hedu

le

App

endi

x 1-

7

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 4

2.0 INTRODUCTION

2.1 Study Objective

This report presents the 2016 Decommissioning Cost Estimate Study of the San Onofre Nuclear Generating Station (SONGS) Unit 1. The Unit 1 portion of the San Onofre Nuclear Generating Station is owned by the Southern California Edison Company (SCE) and the San Diego Gas & Electric Company (SDG&E). SCE is an 80% owner and SDG&E is a 20% owner. Unit 1 was operated by SCE on behalf of the co-participants.

This study is an update to the SONGS Unit 1 Cost Study for Remaining Decommissioning Work, dated March 2009 (Ref. No. 1). This study, hereinafter referred to as the U1-DCE-2016, is integrated with the 2014 SONGS 2 & 3 DCE (Ref. No 2) to ensure a consistent and efficient station decommissioning strategy. This study develops and presents the Unit 1 apportioned estimated costs for: (1) decommissioning what remains of Unit 1 to the extent required to terminate the plant’s operating license; (2) post-shutdown management of Unit 1 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. 3), and the California State Lands Commission Easement Lease (Ref. No. 4); and (4) decommissioning and demolition of the Unit 1 portion of the ISFSI.

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. 5). 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. 6). The estimate is based on compliance with current regulatory requirements and proven decommissioning technologies.

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 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.” 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.

Appendix 1-8

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 5

In addition to the NRC Decommissioning requirements described above, the Grant of Easement from the Government states: “That upon termination of the easement granted herein, the Grantees at their own expense may remove, and if desired by the Government, shall remove, any and all improvements installed or constructed hereunder, and shall restore the Premises to a condition satisfactory to the Director, Southwest Division, Bureau of Yards and Docks;…”This estimate includes the costs for removal of all Unit 1 subsurface structures.

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

� Deferred completion of decommissioning and final site restoration pending completion of the transfer to DOE of all spent fuel located at the ISFSI.

� A total of 395 Unit 1 spent fuel assemblies are being stored in transportable Multi-Purpose Canisters (MPCs) at the ISFSI.

� An additional 270 Unit 1 spent fuel assemblies are being stored at GE Morris (the cost of which is not included in this estimate).

� A dry transfer facility will not be necessary for transfer of spent fuel canisters for transport.

� DOE begins accepting spent fuel from the industry in 2028 and completes the removal of Unit 1 spent fuel from the ISFSI by 2034, and from GE-Morris by 2051.

� Remaining Unit 1 decommissioning and site restoration activities will be performed by a Decommissioning General Contractor (DGC), concurrent with the decommissioning of Units 2 & 3, with oversight by the Decom Agent.

� 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.

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. On-site dry storage of spent fuel at an 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

Appendix 1-9

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 6

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. 7), 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 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 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

Appendix 1-10

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 7

2028, 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. 8). SCE’s December 2012 testimony to the CPUC provided the basis for previous estimated spent fuel management costs, based on a DOE start date assumption of 2024. This report uses a the DOE start date assumption of 2028; the adjustment was made to account for the four years since the 2012 testimony, with no progress by DOE that would make a 2024 start date a credible assumption.

Appendix 1-11

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 8

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. 5). 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 disposition of the Unit 1 reactor vessel are distributed costs. Undistributed costs, sometimes referred to as collateral costs, are typically time dependent costs including, but not limited to Decom Agent 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, 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, EnergySolutions has established a Work Breakdown Structure (WBS) and cost accounting system to treat each element as a subproject.

Appendix 1-12

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 9

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

This U1-DCE-2016 assumes that the remaining Unit 1 decommissioning activities will be performed as part of an integrated SONGS site-wide program for decommissioning Units 2 & 3, spent fuel management, ISFSI decommissioning, and site restoration. This DCE is based on the work being performed by a qualified DGC with oversight and management of the decommissioning operations performed by the Decom Agent. It is also assumed that the Decom Agent will be supplemented by a professional engineering consulting firm.

The sizes of the staffs are varied in each period in accordance with the requirements of the work activities. The SCE existing salary structure is the basis for calculating Decom Agent labor costs. EnergySolutions used industry data to develop DGC salary costs. Staffing has been organized into the following departments or functional groups:

� Decommissioning � Engineering� Maintenance and Work Control � Oversight and Nuclear Safety � Radiation Protection and Chemistry � Regulatory and Emergency Planning � 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. Waste Control Specialists (WSC) is currently the only licensed facility for receipt of Class B and C waste; WCS rate structure is used for estimating costs for Class B and C disposal. 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 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

Appendix 1-13

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 10

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. 5), NUREG/CR-0130 (Ref. No. 10), NUREG/CR-0672 (Ref. No. 11), and recent industry experience. Information regarding the classification of waste in the Unit 1 Reactor Pressure Vessel was furnished by SCE.

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 custom designed 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. 12), all Class A waste that meets the waste acceptance criteria are to be disposed of at EnergySolutions’ LLRW 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

Appendix 1-14

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 11

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 custom designed 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

Because 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 with the Governor of the State of California Executive Order D-62-02 (Ref. No. 13).

Hazardous and Industrial Waste Disposal

Non-Radioactive contaminated surfaces coated with tightly adhering and undamaged lead based paint will be removed as non-hazardous building demolition debris. Any chemicals or hazardous materials present at Unit 1 will be removed and properly disposed of during decommissioning and site restoration.

Appendix 1-15

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 12

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. 14). 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. 15). Contingency “covers costs that may result from incomplete design, unforeseen and unpredictable conditions, or uncertainties within the defined project scope.

EnergySolutions has applied a 25% contingency to all costs in this study, with the exception of Site Characterization Surveys at a 15% contingency. Extensive surveys performed during Phase I of SONGS Unit 1 decommissioning provide data to support a lower contingency for future surveys.

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 Decom Agent HP staff are calculated and reported as an undistributed line item. A line item specific contingency is then calculated for each activity cost element.

Appendix 1-16

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 13

4.0 SITE SPECIFIC TECHNICAL APPROACH

4.1 Facility Description

The San Onofre Nuclear Generating Station Unit 1 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 11, 2024 (Ref. No. 3). 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 facility currently has an existing ISFSI containing spent fuel that was transferred into MPCs 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.

4.2 Decommissioning Status of Unit 1

Unit-1 was permanently retired on November 30, 1992. Following an evaluation in the fall of 1997 a decision was made to proceed with active decommissioning of Unit 1. In December of 1997, SCE and SDG&E advised the California Public Utility Commission (CPUC) and the U. S. Nuclear Regulatory Commission (NRC) of their intent to commence decommissioning Unit 1. SCE submitted an updated Post Shutdown Decommissioning Activities Report (PSDAR) to the NRC on December 15, 1998. Subsequently, in Decision D.99-06-007, the CPUC approved SCE's request to the CPUC to commence Unit 1 decommissioning. The following paragraphs describe the decommissioning phases implemented by SCE.

Phase-I Decommissioning

Phase I decommissioning activities were performed between July 1999 and December 2008, and included: (1) the decontamination, dismantling, and disposal of all contaminated and non-contaminated Unit 1 equipment, components, and structures that were either installed above-ground or below-ground but above the water table; (2) the installation of low-density concrete within void spaces in structures below the water table to ensure stability of the site; and (3) the licensing and construction of a spent fuel dry storage facility on the Unit 1 site, the fabrication of dry storage canisters, and the loading and placement of all Unit 1 spent fuel stored at SONGS and one canister of GTCC waste into the spent fuel dry storage facility.

Phase-II Decommissioning

Phase II Decommissioning commenced on January 1, 2009 upon completion of Phase I and will continue until all spent fuel has been removed from the ISFSI. Phase II of the Unit 1 decommissioning project will primarily consist of maintaining and monitoring the Unit 1 spent fuel in ISFSI until it is removed by the U.S. Department of Energy (DOE). SCE currently projects that the DOE will remove the last Unit 1 fuel from the site in 2040. Other Phase II activities will include the final disposition of the Unit 1 offshore conduits, and the disposition of the Unit 1 Reactor Pressure Vessel (RPV) as further discussed below.

Appendix 1-17

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 14

Phase-III Decommissioning

Phase III of Unit 1 decommissioning will include the removal of any remaining residual radioactivity as required to terminate the NRC License for the Unit 1 site, and removal of remaining site structures and improvements as required for final site restoration and termination of the easement-leases from the U.S. Department of the Navy (Navy). Phase III of Unit 1 decommissioning will be completed concurrently with Unit 2 & 3 decommissioning. This is not expected to occur until after the DOE removes the last spent fuel from Units 2 & 3 from the ISFSI, which is currently projected to occur in 2049.

Unit 1 Reactor Pressure Vessel

The Unit 1 RPV package, which contains both the RPV and many of the segmented pieces of the RPV’s internal components, is grouted and sealed inside a large shipping container and is awaiting shipment to a disposal facility that is licensed to accept Class C LLRW. There are three options for U1 Reactor disposal 1) Ship via barge around cape horn to Texas, 2) Segment and ship over land to Texas, 3) Keep in the existing shipping container and utilize total volume averaging to allow for disposal in the class A disposal facility in Clive, UT. Due to the logistical challenges associated with shipping such a large, heavy, radioactive package, SCE believes it may be necessary to cut or “segment” the RPV package into several smaller, lighter pieces to allow transportation to the disposal site. SCE currently projects that, if necessary, it would perform the segmentation of the Unit 1 RPV package concurrently with the segmentation of the Units 2 & 3 RPVs.

SCE believes that Options 1 & 3 above are the most likely scenarios for RPV disposal, and that a 25% contingency is appropriate. Segmentation of a Class C RPV package similar to the RPV has not been performed by the nuclear industry, and therefore, a 40% contingency is an appropriate value for Option 2. This study will be updated to reflect any changes in RPV disposal assumptions or methodology.

Appendix A provides a list of the SONGS Unit 1 systems and structures included in the material inventory for this study.

4.3 Decommissioning Periods

As described above, the basis for this estimate is that the completion of the Unit 1 decommissioning and site restoration activities will occur concurrently with Units 2 & 3 decommissioning and the ISFSI decontamination and demolition. The project periods consist of eight License Termination periods, seven Spent Fuel Management periods (two of which are ISFSI decontamination and demolition periods), and eight Site Restoration periods. As shown in Figure 1-1, 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:

Appendix 1-18

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 15

License Termination Periods

Decon Pd 1 –Transition to Decommissioning� Units 2 & 3 Activities Only

Decon Pd 2 –Decommissioning Planning and Site Modifications� Units 2 & 3 Activities Only

Decon Pd 3 – Decommissioning Preparations and Reactor Internal Segmentation� Units 2 & 3 Activities Only

Decon Pd 4 – Plant Systems and Large Component Removal� Units 2 & 3 Activities Only

Decon Pd 5 – Building Decontamination� Units 2 & 3 Activities Only

Decon Pd 6 – License Termination During Decommissioning� Units 2 & 3 Activities Only

Decon Pd 7 –Decommissioning During Fuel Storage – Unit 1� Engineering Analysis of Transportation and Disposal Options for Unit 1 RPV � Engineering Planning and Design for Unit 1 RPV Disposition � Transportation and Disposal of Unit 1 RPV

Decon Pd 8 – License Termination During Decommissioning� Prepare License Termination Plan – Unit 1 � Perform Final Status Survey – Unit 1 � ORISE Verification and NRC Approval – Unit 1

Spent Fuel Management Periods

SNF Pd 1 – Spent Fuel Transfer Management Transition� Units 2 & 3 Activities Only

SNF Pd 2 – Dry Storage During Decommissioning Unit 1� Unit 1 portion of ISFSI Related Nuclear Property and Liability Insurance

SNF Pd 3 – Dry Storage During Decommissioning Units 1, 2, & 3� Operation, Maintenance and Surveillance of ISFSI

SNF Pd 4 – Dry Storage Only – Units 1, 2, & 3� Operation, Maintenance and Surveillance of ISFSI

SNF Pd 5 – Dry Storage Only – Units 2 & 3� Units 2 & 3 Activities Only

SNF D&D Pd 1 – ISFSI License Termination� Preparation and NRC Review of License Termination Plan

Appendix 1-19

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 16

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� Units 2 & 3 Activities Only

SR Pd 2 –Building Demolition During Decommissioning� Units 2 & 3 Activities Only

SR Pd 3 – Subsurface Demolition Engineering & Permitting� Units 2 & 3 Activities Only

SR Pd 4 – Building Demolition to 3 Feet Below Grade� Units 2 & 3 Activities Only

SR Pd 5 – Subgrade Structure Removal Below – 3 Feet� Units 2 & 3 Activities Only

SR Pd 6 – Final Site Restoration and Easement Termination� Units 2 & 3 Activities Only

SR Pd 7 – Planning for Completion of Unit 1 Site Restoration� Subsurface Structure Removal Engineering Planning and Design – Unit 1 � Environmental Impacts Analyses for Lease Termination Activities – Unit 1 � Final Site Grading and Shoreline Protection Engineering Planning and Design –

Unit 1 � Obtain Required Permits and Approvals – Unit 1

SR Pd 8 – Final Site Restoration and Easement Termination – Unit 1� Install Dewatering System – Unit 1 � Excavate and Remove Slurry Backfill – Unit 1 � Excavate and Remove Containment Foundation – Unit 1 � Excavate and Remove Turbine Pedestal Foundation – Unit 1 � Excavate and Remove Circulating Water Structures – Unit 1 � Excavate and Remove Sewage Treatment Plant – Unit 1 � Excavate and Remove Auxiliary Feedwater Foundation and Trench – Unit 1 � Excavate and Remove Underground Utilities – Unit 1 � Excavate and Remove Storm Drains, Catch Basins and Manholes – Unit 1 � Remove and Stockpile Existing Seawall Erosion Protection – Unit 1 � Remove Seawall and Pedestrian Walkway – Unit 1 � Finish Grading and Re-vegetate Site – Unit 1

Appendix 1-20

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 17

4.4 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 Decom Agent. It is also assumed that the Decom Agent will be supplemented by a professional engineering consulting firm. The sizes of the Decom Agent 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.

4.5 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 when the fuel assemblies are being transferred to dry storage. After all spent fuel 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.

4.6 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. 8). The information regarding existing fuel inventory, planned transfers to dry storage and DOE’s projected date of 2028 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.

Appendix 1-21

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 18

5.0 BASES OF ESTIMATE AND KEY ASSUMPTIONS

The bases of, and key assumptions for, this site-specific decommissioning estimate are presented below:

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

2. EnergySolutions developed this estimate based on a project schedule integrated with Units 2 & 3 that commences on 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 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 2028. 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. 8).

5. This estimate is based on building inventories derived from SCE furnished drawings of remaining above and below grade Unit 1 structures, the existing ISFSI and conceptual drawings of the ISFSI expansion required to transfer Units 2 & 3 spent fuel to dry storage.

6. 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. 13).

7. The estimate is based on final site restoration, in which all existing and proposed structures, with the exception of the switchyard, access roads and related communications will be removed. Clean demolition costs are based on the assumption that all site improvements will be removed in their entirety. Following demolition and removal of subsurface structures, clean backfill will be imported and placed to re-establish the existing grade. The entire disturbed area of the site will then be graded, to ensure proper management of storm-water runoff and seeded for stabilization and erosion protection.

8. 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. 12). The following 2014 disposal rates will be applied:

Appendix 1-22

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 19

Demolition Debris and Soil - $57.97/Cubic Foot plus 5% Utah taxes Oversized Debris - $111.31/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.

9. 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 wastes are assumed to be Class B.

10. 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.

11. 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.

12. 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 that will be in storage at the completion of the transfer of Units 2 & 3 fuel into dry storage. The percentages are 10%, 45%, and 45% for Units 1, 2, and 3, respectively. These percentages will be applied until all Unit 1 spent fuel has been transferred to DOE. The exception is that all property taxes are solely the liability of Units 2 & 3. Following completion of the transfer of Unit 1 spent fuel to DOE at the conclusion 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%.

13. 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.

14. Costs for ISFSI demolition are included in this estimate. SCE assumes that portions of the AHSM concrete will be activated. This cost is distributed between Units 1, 2, and 3 as stated in Item No. 12 above.

15. EnergySolutions has assumed that the 10 CFR Part 50 license will be maintained until DOE has taken possession of the spent fuel, and all radiological decommissioning activities have been completed, including decommissioning of the ISFSI.

16. EnergySolutions has included the annual NRC fees as required by 10 CFR 171.15(c)(2) for reactors in decommissioning of $231,000 per year until Unit 1 decommissioning is completed as a license termination expense.

17. EnergySolutions has included the annual NRC fees as required by 10 CFR 171.15(c)(2) for an ISFSI of $231,000 per year until decommissioning of the ISFSI is completed as a spent fuel management expense. This cost is distributed between Units 1, 2, and 3 as

Appendix 1-23

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 20

stated in Item No. 12 above during the periods where Unit 1 spent fuel is stored in the ISFSI and during the ISFSI D&D period.

18. EnergySolutions has included NRC inspection fees during spent fuel management periods based on the type and level of activities being performed. This cost is distributed between Units 1, 2, and 3 as stated in Item No. 12 above during the periods where Unit 1 spent fuel is stored in the ISFSI.

19. Annual insurance premiums, in 2014 dollars as supplied by SCE, allocated to SONGS Unit 1 are as follows:

Nuclear Property and Liability - $168,212 Additional Liability, Non-Nuclear - $33,565 Workers’ Compensation - $8,000 Property Insurance - $3,533

20. Site operating expenses expected to be incurred during spent fuel management and site restoration 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. These costs are distributed between Units 1, 2, and 3, as stated in Item No. 12 above, during the periods where Unit 1 spent fuel is stored in the ISFSI and during the ISFSI D&D period.

21. Decom Agent positions and average direct burdened salary (i.e., total compensation) data in 2014 dollars were supplied by SCE.

22. No severance costs are assigned to Unit 1.

23. DGC staff salaries, including overhead and profit, were determined by EnergySolutionsand represent EnergySolutions’ standard assumptions for these rates.

24. 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.

25. 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. 16), for Anaheim, CA. Since the skilled laborers are assumed to be supplied by the local union hall, they will not be paid per diem.

26. The security guard force included in this estimate has been sized in accordance with the current Design Basis Threat assessment.

27. This study follows the occupational exposure principles of As Low As Reasonably Achievable (ALARA) through the use of productivity loss factors that incorporate such

Appendix 1-24

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 21

items as the use of respiratory protection and personnel protective clothing. These factors increase the work duration and cost.

28. 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 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

29. 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.

Appendix 1-25

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 22

6.0 STUDY RESULTS

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

� Deferred completion of decommissioning and final site restoration pending completion of the transfer to DOE of all spent fuel located at the ISFSI.

� A total of 395 Unit 1 spent fuel assemblies are being stored in transportable Multi-Purpose Canisters (MPCs) at the ISFSI.

� An additional 270 Unit 1 spent fuel assemblies are being stored at GE Morris (the cost of which is not included in this estimate).

� A dry transfer facility will not be necessary for transfer of spent fuel canisters for transport.

� DOE begins accepting spent fuel from the industry in 2028 and completes the removal of Unit 1 spent fuel from the ISFSI by 2034, and from GE-Morris by 2051.

� Remaining Unit 1 decommissioning and site restoration activities will be performed by a DGC, concurrent with the decommissioning of Units 2 & 3, with oversight by the Decom Agent.

� 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.

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 2028. The spent fuel shipment schedules are based upon best current information and assumptions, as qualified and described elsewhere in this study.

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.

Project 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 Decom Agent. Decom Agent 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.

Appendix 1-26

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 23

LLRW Disposal Volumes

LLRW disposal is a significant element of the decommissioning project. The estimated cubic feet of waste are summarized as follows:

Class A 723 Class B & C 7,598 GTCC 167

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.

Appendix 1-27

2016

Dec

omm

issio

ning

Cos

t Ana

lysis

of t

he

Doc

umen

t No.

164

007-

DC

E-0

17

San

Ono

fre

Nuc

lear

Gen

erat

ing

Stat

ion

Uni

t 1

Rev

ision

0

Page

24

Figu

re 6

-1

Sum

mar

y Sc

hedu

le

App

endi

x 1-

28

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 25

Table 6-11

Cost and Schedule Summary (2014 Dollars in Thousands)

Period No. Period Description Start End Years Total Cost License Termination (50.75(c))

Decon Pd 7 Decommissioning During Fuel Storage - Unit 1 1/1/2016 12/31/2049 33.99 $108,919

Decon Pd 8 License Termination During Final Site Restoration - Unit 1 12/31/2049 12/15/2051 1.95 $8,611

Account Total 35.94 $117,530Spent Fuel (50.54(bb))

SNF Pd 2 Dry Storage During Decommissioning - Unit 1 1/1/2016 6/1/2019 3.41 $1,102

SNF Pd 3 Dry Storage During Decommissioning - Units 1, 2 and 3 6/1/2019 12/5/2031 12.51 $19,092

SNF Pd 4 Dry Storage Only - Units 1, 2 and 3 12/5/2031 12/31/2034 3.07 $5,400SNF Pd 5 Dry Storage Only - Units 2 and 3 12/31/2034 12/31/2049 15.00 $0SNF D&D Pd 1 ISFSI License Termination 12/31/2049 5/6/2050 0.34 $137

SNF D&D Pd 2 ISFSI Demolition 5/6/2050 9/8/2051 1.34 $4,811

Account Total 35.67 $30,541Site Restoration

SR Pd 7 Planning for Completion of Unit 1 Site Restoration 5/9/2048 5/6/2050 1.99 $4,607

SR Pd 8 Final Site Restoration and Lease Termination - Unit 1 5/6/2050 12/15/2051 1.60 $86,757

Account Total 3.59 $91,365Grand Total $239,436

1 Rows and columns may not add correctly due to rounding.

Appendix 1-29

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 26

Table 6-2 Decom Agent Levels

License Termination – 50.75(c) Decom Agent (Unit 1 Only) Decon Decon

Department Pd 7 Pd 8

Decommissioning 0 0Engineering 0 0Maintenance and Work Control 0 0 Operations 0 0Oversight and Nuclear Safety 0 0 Radiation Protection and Chemistry 0 0 Regulatory and Emergency Planning 0 0.25 Safety and Human Performance 0 0 Security Admin 0 0 Security Guard Force 0 0 Site Management and Administration 0 0 Period Totals 0 0.25

Spent Fuel - 50.54(bb) Decom Agent (Units 1, 2, & 3)

Department SNF Pd 3

SNF Pd 4

SNF Pd 5

SNF D&D Pd 1

SNF D&D Pd 2

Spent Fuel Shipping 0 2 2 0 0 Decommissioning 0 0 0 1 1 Engineering 1 1 1 0 1 Maintenance and Work Control 0 0 0 0 0 Operations 1 1 1 0 0 Oversight and Nuclear Safety 0.25 0.25 0.25 0 0 Radiation Protection and Chemistry 4 4 4 1 2 Regulatory and Emergency Planning 0 0 0 1 1 Security Admin 10 8 8 1 1 Security Guard Force 35 35 35 5 5 Site Management and Administration 0 0 0 1 1 Period Total 51.25 54.25 54.25 10 12

Site Restoration - Decom Agent (Unit 1 Only)

Department SR

Pd 7 SR

Pd 8 Decommissioning 0.25 1Engineering 0.25 0Maintenance and Work Control 0 1 Regulatory and Emergency Planning 0.25 0 Safety and Human Performance 0.25 1 Security Admin 0 0 Security Guard Force 0 0 Site Management and Administration 0 0 Period Totals 1 3

Appendix 1-30

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 27

Table 6-3 DGC Staff Levels

License Termination – 50.75(c) DGC Staff (Unit 1 Only) Decon Decon

Department Pd 7 Pd 8

Administration 0 0Engineering 0 0Health Physics 0 0 Management 0 0Quality Assurance 0 0 Waste Operations 0 0 Period Totals 0 0

Spent Fuel - 50.54(bb) - DGC Staff (Units 1, 2, & 3)

Department SNF D&D

Pd 2 Administration 1 Engineering 2 Health Physics 3 Management 1 Quality Assurance 1 Waste Operations 4Period Totals 12

Site Restoration DGC Staff (Unit 1 Only) SR SR

Department Pd 7 Pd 8

Administration 0 0Engineering 1 6Health Physics 0 0 Management 0 0Quality Assurance 0 0 Waste Operations 0 7 Period Totals 1 13

Appendix 1-31

2016

Dec

omm

issio

ning

Cos

t Ana

lysis

of t

he

Doc

umen

t No.

164

007-

DC

E-0

17

San

Ono

fre

Nuc

lear

Gen

erat

ing

Stat

ion

Uni

t 1

Rev

ision

0

Page

28

Tab

le 6

-4

Was

te D

ispo

sal V

olum

es

(Cos

t Exc

lude

s Con

tinge

ncy

- 201

4 D

olla

rs)

Faci

lity

and

Was

te C

lass

W

aste

W

eigh

t (L

Bs)

Was

te

Vol

ume

(CF)

Bur

ial

Vol

ume

(CF)

Pa

ckag

ing

Cos

t T

rans

port

atio

n C

ost

Bas

e B

uria

l C

ost

Tot

al

Dis

posa

l Cos

t C

lass

B, C

& G

TC

C F

acili

ties

C

lass

B &

C

1,52

5,00

0 7,

598

7,59

8 $5

25,0

00

$16,

800,

000

$36,

310,

869

$53,

635,

869

GTC

C

27,1

59

55

167

$0

$210

,000

$3

,440

,770

$3

,650

,770

1,55

2,15

9 7,

654

7,76

5 $5

25,0

00

$17,

010,

000

$39,

751,

639

$57,

286,

639

Ene

rgyS

olut

ions

C

lass

A –

Deb

ris

37,2

63

723

723

$733

$2

,988

$4

6,21

4 $4

9,93

5

O

ther

O

ut o

f Sta

te C

lass

III L

andf

ill

155,

545,

280

2,39

3,00

4 2,

393,

004

$0

$11,

759,

838

$3,6

33,1

06

$15,

392,

944

Scra

p M

etal

Rec

ycle

r 1,

651,

239

66,0

50

66,0

50

$0

$8,1

49

$0

$8,1

4915

7,19

6,51

9 2,

459,

054

2,45

9,05

4 $0

$1

1,76

7,98

7 $3

,633

,106

$1

5,40

1,09

3

Gra

nd T

otal

15

8,78

5,94

1 2,

467,

431

2,46

7,54

2 $5

25,7

33

$28,

780,

975

$43,

430,

959

$72,

737,

667

App

endi

x 1-

32

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 29

7.0 REFERENCES

1. Southern California Edison, San Onofre Nuclear Generating Station Unit 1 (SONGS 1), Cost Study for Remaining Decommissioning Work, March 2009.

2. EnergySolutions LLC, 2014 Decommissioning Cost Analysis of the San Onofre Nuclear Generating Station Units 2 & 3, Document No. 164001-DCE-001, Rev 1, September 5, 2014.

3. Department of the Navy, “Grant of Easement,” May 1964.

4. State of California State Lands Commission, “Lease P.R.C. No. 4862.1”, dated November 19, 1984.

5. Atomic Industrial Forum, Inc., “Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates,” AIF/NESP-036, May 1986.

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

7. 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.

8. U.S. Department of Energy, “Acceptance Priority Ranking & Annual Capacity Report,” DOE/RW-0567, July 2004.

9. 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.

10. U.S. Nuclear Regulatory Commission, “Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station,” NUREG/CR-0130, June 1978.

11. U.S. Nuclear Regulatory Commission, “Technology, Safety and Costs of Decommissioning a Reference Boiling Water Reactor Power Station,” NUREG/CR-0672, June 1980.

12. Life-of-Plant Disposal Agreement, between EnergySolutions, LLC and SCE effective January 1st, 2014.

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

14. U.S. Nuclear Regulatory Commission, “Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM),” NUREG-1575, Rev. 1, August 2000.

15. U.S. Department of Energy, “Cost Estimating Guide,” DOE G 430.1-1, March 1997.

Appendix 1-33

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Page 30

16. RS Means, “Labor Rates for the Construction Industry,” 2014.

Appendix 1-34

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Appendix A

List of Systems and Structures

Appendix 1-35

SONGS Unit 1 Remaining Structures List

Unit 1

Type System Name or Description

Struct Anchor Block 1 and Slurry Backfill - Unit 1Struct Anchor Block 2 - Unit 1Struct Auxilary Feedwater Heater Tank Foundation - Unit 1Struct Auxilary Feedwater Trench - Unit 1Struct Blowdown Trench - Unit 1Struct Containment Foundation - Unit 1Struct Cooling Water Pipe - Unit 1Struct Discharge Box Culvert - Unit 1Struct Intake Box Culvert - Unit 1Struct Intake TunnelsStruct ISFSI Foundation and AHSMsStruct Remaining Slurry Backfill - Unit 1Struct Seawall - Unit 1Struct Sewage Treatment Plant - Unit 1Struct Slurry Backfill NE of Containment - Unit 1Struct Storm Drains, Catch Basins and Manholes - Unit 1Struct Turbine Generator Pedestal Foundation - Unit 1Struct Underground Conduit - Unit 1Struct Vent Stack Foundation - Unit 1Struct Water and Sanitary Sewer - Unit 1Struct Yard Sump - Unit 1

Page 1 of 1

Appendix 1-36

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Appendix B

Spent Fuel Shipping Schedule

Appendix 1-37

SONGS Unit 1Spent Fuel Shipping Schedule

2028 DOE Acceptance

Inventory (Beginning of Year)

Year

Assemblies in Storage at GE

Morris

Assemblies in Dry Storage at

SONGS

Total Assemblies in

Storage

Assemblies Shipped to

DOE from GE Morris

Assemblies Shipped to DOE from SONGS

Total Assemblies Shipped to

DOE

2016 270 395 665 0 0 0

2017 270 395 665 0 0 0

2018 270 395 665 0 0 0

2019 270 395 665 0 0 0

2020 270 395 665 0 0 0

2021 270 395 665 0 0 0

2022 270 395 665 0 0 0

2023 270 395 665 0 0 0

2024 270 395 665 0 0 0

2025 270 395 665 0 0 0

2026 270 395 665 0 0 0

2027 270 395 665 0 0 0

2028 270 395 665 0 96 96

2029 270 299 569 0 48 48

2030 270 251 521 0 120 120

2031 270 131 401 0 48 48

2032 270 83 353 0 48 48

2033 270 35 305 0 0 0

2034 270 35 305 0 35 35

20351 270 0 270 0 0 0

2036 270 0 270 0 0 0

2037 270 0 270 0 0 0

2038 270 0 270 0 0 0

2039 270 0 270 0 0 0

2040 270 0 270 0 0 0

2041 270 0 270 0 0 0

2042 270 0 270 0 0 0

2043 270 0 270 0 0 0

2044 270 0 270 0 0 0

2045 270 0 270 0 0 0

2046 270 0 270 0 0 0

2047 270 0 270 0 0 0

2048 270 0 270 0 0 0

2049 270 0 270 0 0 0

20502 270 0 270 147 0 147

20512123 0 123 123 0 123

Footnotes:1 Excludes Greater Than Class C (GTCC) Waste2 Unit 1 fuel assemblies transferred to DOE from GE Hitachi facility in Morris, Illinois in

TADS (21 assemblies per TAD)

Off-Site Transfers (During Year)

Appendix 1-38

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Appendix C

Detailed Project Schedule

Appendix 1-39

IDT

ask

Nam

eD

urat

ion

Sta

rtF

inis

h1

Po

st-S

hu

tdo

wn

Sp

ent

Fu

el M

anag

emen

t99

82 d

ays

06/0

7/20

1311

/17/

2051

2S

pent

Fue

l Shi

ppin

g F

rom

ISF

SI C

ompl

ete

- U

nit 1

0 da

ys12

/31/

2034

12/3

1/20

34

3S

pent

Fue

l Shi

ppin

g C

ompl

ete

- U

nits

2 &

30

days

12/3

1/20

4912

/31/

2049

4S

NF

Pd

1 -

Sp

ent

Fu

el M

anag

emen

t T

ran

siti

on

149

day

s06

/07/

2013

12/3

1/20

135

SN

F P

d 1

Beg

ins

0 da

ys06

/07/

2013

06/0

7/20

136

Sec

urity

Enh

ance

men

ts45

day

s10

/31/

2013

12/3

1/20

137

Des

ign

and

Fab

ricat

e S

pent

Fue

l Can

iste

rs12

0 da

ys06

/07/

2013

11/2

1/20

13

8P

ost F

ukus

him

a M

odifi

catio

ns -

Uni

t 214

8 da

ys06

/07/

2013

12/3

1/20

139

Pos

t Fuk

ushi

ma

Mod

ifica

tions

- U

nit 3

148

days

06/0

7/20

1312

/31/

2013

10C

yber

Sec

urity

Mod

ifica

tions

148

days

06/0

7/20

1312

/31/

2013

11S

NF

Pd

1 E

nds

0 da

ys01

/01/

2014

01/0

1/20

1412

SN

F P

d 2

- D

ry S

tora

ge

Du

rin

g D

eco

mm

issi

on

ing

- U

nit

113

90 d

ays

01/0

1/20

1606

/01/

2019

34S

NF

Pd

3 -

Dry

Sto

rag

e D

uri

ng

Dec

om

mis

sio

nin

g -

Un

its

1, 2

an

d 3

3265

day

s06

/01/

2019

12/0

5/20

3137

SN

F P

d 4

- D

ry S

tora

ge

On

ly -

Un

its

1, 2

an

d 3

801

day

s12

/05/

2031

12/3

1/20

3440

SN

F P

d 5

- D

ry S

tora

ge

On

ly -

Un

its

2 an

d 3

3914

day

s12

/31/

2034

12/3

1/20

4943

SN

F D

&D

Pd

1 -

ISF

SI D

&D

Pla

nn

ing

90 d

ays

12/3

1/20

4905

/06/

2050

44S

NF

D&

D P

d 1

Beg

ins

0 da

ys12

/31/

2049

12/3

1/20

49

45P

repa

ratio

n an

d N

RC

Rev

iew

of L

icen

se T

erm

inat

ion

Pla

n90

day

s01

/01/

2050

05/0

6/20

5046

SN

F D

&D

Pd

1 E

nds

0 da

ys05

/06/

2050

05/0

6/20

5047

SN

F D

&D

Pd

2 -

ISF

SI D

&D

350

day

s05

/06/

2050

09/0

8/20

5148

SN

F D

&D

Pd

2 B

egin

s0

days

05/0

6/20

5005

/06/

2050

49D

OE

Pic

kup

from

Mor

ris F

acili

ty B

egin

s0

days

05/0

6/20

5005

/06/

2050

50Lo

ad S

pent

Fue

l Ass

embl

ies

at G

E M

orris

for

Shi

pmen

t to

DO

E -

Uni

t 134

0 da

ys05

/07/

2050

08/2

5/20

5151

Spe

nt F

uel S

hipp

ing

from

Mor

ris C

ompl

ete

- U

nit 1

0 da

ys08

/25/

2051

08/2

5/20

5152

Inst

all G

AR

DIA

N B

ulk

Ass

ay S

yste

m30

day

s05

/07/

2050

06/1

7/20

5053

Dec

on A

HS

Ms

90 d

ays

05/0

7/20

5009

/09/

2050

54F

inal

Sta

tus

Sur

vey

of IS

FS

I12

0 da

ys05

/28/

2050

11/1

1/20

50

55C

lean

Dem

oliti

on o

f IS

FS

I AH

SM

s an

d P

ad14

5 da

ys09

/10/

2050

03/3

1/20

5156

Cle

an D

emol

ition

of I

SF

SI S

uppo

rt S

truc

ture

s12

0 da

ys10

/15/

2050

03/3

1/20

5157

Res

tore

ISF

SI S

ite55

day

s04

/01/

2051

06/1

6/20

5158

Pre

para

tion

of F

inal

Rep

ort o

n D

ecom

mis

sion

ing

and

NR

C R

evie

w60

day

s06

/17/

2051

09/0

8/20

5159

SN

F D

&D

Pd

2 E

nds

- Li

cens

e T

erm

inat

ion

Com

plet

e0

days

09/0

8/20

5109

/08/

2051

60P

ost-

Shu

tdow

n S

pent

Fue

l Man

agem

ent C

ompl

ete

0 da

ys09

/08/

2051

09/0

8/20

5161

Par

t 50

Lic

ense

Ter

min

atio

n10

052

day

s06

/07/

2013

12/1

5/20

5162

Ann

ounc

emen

t of C

essa

tion

of O

pera

tions

(Ju

ne 7

, 201

3)0

days

06/0

7/20

1306

/07/

2013

63D

eco

n P

d 1

- T

ran

siti

on

to

Dec

om

mis

sio

nin

g14

9 d

ays

06/0

7/20

1312

/31/

2013

71D

eco

n P

d 2

- D

eco

mm

issi

on

ing

Pla

nn

ing

an

d S

ite

Mo

dif

icat

ion

s38

9 d

ays

1/1/

2014

06/3

0/20

1511

6D

eco

n P

d 3

- D

eco

mm

issi

on

ing

Pre

par

atio

ns

and

Rea

cto

r In

tern

als

Seg

men

t10

24 d

ays

06/3

0/20

1506

/01/

2019

152

Dec

on

Pd

4 -

Pla

nt

Sys

tem

s an

d L

arg

e C

om

po

nen

t R

emo

val

865

day

s06

/01/

2019

09/2

4/20

2219

8D

eco

n P

d 5

- B

uild

ing

Dec

on

tam

inat

ion

470

day

s09

/24/

2022

07/1

3/20

2422

2D

eco

n P

d 6

- L

icen

se T

erm

inat

ion

Du

rin

g D

emo

litio

n22

06 d

ays

07/1

3/20

2412

/24/

2032

229

Dec

on

Pd

7 -

Dec

om

mis

sio

nin

g D

uri

ng

Fu

el S

tora

ge

- U

nit

188

72 d

ays

01/0

1/20

1612

/31/

2049

230

Dec

on P

d 7

Beg

ins

0 da

ys01

/01/

2016

01/0

1/20

1623

1U

pdat

e U

nit 1

Dec

omm

issi

onin

g C

ost E

stim

ate

180

days

01/0

1/20

1609

/08/

2016

232

Eng

inee

ring

Ana

lysi

s of

Tra

nspo

rtat

ion

and

Dis

posa

l Opt

ions

for

Uni

t 1 R

x V

ess

90 d

ays

03/2

3/20

2107

/27/

2021

233

Eng

inee

ring

Des

ign

for

Uni

t 1 R

x V

esse

l 22

0 da

ys07

/27/

2021

05/3

1/20

2223

4T

rans

port

atio

n an

d D

ispo

sal o

f Uni

t 1 R

x V

esse

l90

day

s05

/31/

2022

10/0

1/20

22

235

Tra

nspo

rtat

ion

and

Dis

posa

l of G

TC

C W

aste

30 d

ays

03/2

7/20

3505

/05/

2035

12/3

1

12/3

1

6/7 1/

1

12/3

1

5/6

5/6

5/6

8/25

9/8

9/8

6/7

1/1

12

34

56

78

910

1112

1314

1516

1718

1920

2122

2324

2526

2728

2930

3132

3334

3536

3738

3940

4142

SON

GS

Uni

ts 1

, 2 &

3In

tegr

ated

Pro

ject

Sch

edul

ePr

ompt

DE

CO

N, D

OE

Acc

epta

nce

Beg

ins

2028

App

endi

x 1-

40

IDT

ask

Nam

eD

urat

ion

Sta

rtF

inis

h23

6D

econ

Pd

7 E

nds

0 da

ys12

/31/

2049

12/3

1/20

4923

7D

eco

n P

d 8

- L

icen

se T

erm

inat

ion

Du

rin

g F

inal

Sit

e R

esto

rati

on

- U

nit

151

0 d

ays

12/3

1/20

4912

/15/

2051

238

Dec

on P

d 8

Beg

ins

0 da

ys12

/31/

2049

12/3

1/20

4923

9P

repa

re L

icen

se T

erm

inat

ion

Pla

n -

Uni

t 190

day

s01

/01/

2050

05/0

6/20

5024

0P

erfo

rm F

inal

Sta

tus

Sur

vey

300

days

06/1

8/20

5008

/11/

2051

241

Oris

e V

erifi

catio

n90

day

s08

/12/

2051

12/1

5/20

5124

2D

econ

Pd

8 E

nds

0 da

ys12

/15/

2051

12/1

5/20

51

243

Sit

e R

esto

rati

on

1005

2 d

ays

06/0

7/20

1312

/15/

2051

244

SR

Pd

1 -

Tra

nsi

tio

n t

o S

ite

Res

tora

tio

n53

8 d

ays

06/0

7/20

1306

/30/

2015

251

SR

Pd

2 -

Bu

ildin

g D

emo

litio

n D

uri

ng

Dec

om

mis

sio

nin

g53

0 d

ays

06/3

0/20

1507

/11/

2017

270

SR

Pd

3 -

Su

bsu

rfac

e D

emo

litio

n E

ng

inee

rin

g a

nd

Per

mit

tin

g12

50 d

ays

10/0

1/20

1907

/13/

2024

278

SR

Pd

4 -

Bu

ildin

g D

emo

litio

n t

o 3

Fee

t B

elo

w G

rad

e11

10 d

ays

07/1

3/20

2410

/14/

2028

319

SR

Pd

5 -

Su

bg

rad

e S

tru

ctu

re R

emo

val B

elo

w -

3 F

eet

820

day

s10

/14/

2028

12/0

5/20

3135

2S

R P

d 6

- F

inal

Sit

e R

esto

rati

on

an

d L

ease

Ter

min

atio

n -

Un

its

2 &

342

0 d

ays

05/0

6/20

5012

/15/

2051

372

SR

Pd

7 -

Pla

nn

ing

fo

r C

om

ple

tio

n o

f U

nit

1 S

ite

Res

tora

tio

n52

0 d

ays

05/0

9/20

4805

/06/

2050

373

SR

Pd

7 -

Beg

ins

0 da

ys05

/09/

2048

05/0

9/20

4837

4S

ubsu

rfac

e S

truc

ture

Rem

oval

Eng

inee

ring

Pla

nnin

g an

d D

esig

n -

Uni

t 112

0 da

ys05

/09/

2048

10/2

3/20

48

375

Env

ironm

enta

l Im

pact

s A

naly

ses

for

Leas

e T

erm

inat

ion

Act

iviti

es -

Uni

t 190

day

s10

/24/

2048

02/2

6/20

4937

6F

inal

Site

Gra

ding

and

Sho

relin

e P

rote

ctio

n E

ngin

eerin

g P

lann

ing

and

Des

ign

- 90

day

s02

/27/

2049

07/0

2/20

4937

7O

btai

n R

equi

red

Per

mits

and

App

rova

ls fo

r U

nit 1

Dem

oliti

on22

0 da

ys07

/03/

2049

05/0

6/20

5037

8U

nit 1

Out

fall

Con

dut S

urve

y an

d E

nviro

nmen

tal A

sses

smen

t12

0 da

ys05

/09/

2048

10/2

3/20

4837

9E

ngin

eerin

g P

lann

ing

and

Des

ign

for

Rem

oval

of U

nit 1

Out

fall

Con

duit

90 d

ays

10/2

4/20

4802

/26/

2049

380

Obt

ain

Req

uire

d P

erm

its a

nd A

ppro

vals

for

Uni

t 1 O

utfa

ll C

ondu

it R

emov

al22

0 da

ys02

/27/

2049

12/3

1/20

4938

1S

R P

d 7

End

s0

days

05/0

6/20

5005

/06/

2050

382

SR

Pd

8 -

Fin

al S

ite

Res

tora

tio

n a

nd

Lea

se T

erm

inat

ion

- U

nit

1

420

day

s05

/06/

2050

12/1

5/20

5138

3S

R P

d 8

- B

egin

s0

days

05/0

6/20

5005

/06/

2050

384

Pro

cure

Site

Res

tora

tion

Equ

ipm

ent -

Uni

t 142

0 da

ys05

/07/

2050

12/1

5/20

51

385

Inst

all D

ewat

erin

g S

yste

m a

nd E

fflue

nt T

reat

men

t and

Dis

char

ge C

ontr

ols

30 d

ays

05/0

7/20

5006

/17/

2050

386

Exc

avat

e an

d R

emov

e S

lurr

y B

ackf

ill N

orth

-Eas

t of C

onta

inm

ent F

ound

atio

n25

day

s06

/18/

2050

07/2

2/20

5038

7In

stal

l She

et P

iling

for

Con

tain

men

t Fou

ndat

ion

Exc

avat

ion

60 d

ays

06/1

8/20

5009

/09/

2050

388

Exc

avat

e an

d R

emov

e C

onta

inm

ent F

ound

atio

n15

0 da

ys07

/23/

2050

02/1

7/20

5138

9R

emov

e S

heet

Pili

ng fo

r C

onta

inm

ent F

ound

atio

n E

xcav

atio

n60

day

s02

/18/

2051

05/1

2/20

51

390

Exc

avat

e an

d R

emov

e S

lurr

y B

ackf

ill a

nd A

ncho

r B

lock

140

day

s06

/18/

2050

08/1

2/20

5039

1E

xcav

ate

and

Rem

ove

Tur

bine

Ped

esta

l Fou

ndat

ion

40 d

ays

08/1

3/20

5010

/07/

2050

392

Exc

avat

e an

d R

emov

e R

emai

ning

Circ

ulat

ing

Wat

er S

truc

ture

s15

0 da

ys10

/08/

2050

05/0

5/20

5139

3R

emov

e U

nit 1

Out

fall

Con

duit

130

days

10/0

8/20

5004

/07/

2051

394

Exc

avat

e an

d R

emov

e R

emai

ning

Slu

rry

Bac

kfill

15 d

ays

04/0

8/20

5104

/28/

2051

395

Rem

ove

Dew

ater

ing

Sys

tem

and

Effl

uent

Tre

atm

ent

30 d

ays

04/2

9/20

5106

/09/

2051

396

Rem

ove

and

Dis

pose

of A

uxila

ry F

eedw

ater

Fou

ndat

ion

and

Tre

nch

20 d

ays

05/0

6/20

5106

/02/

2051

397

Rem

ove

and

Dis

pose

of S

ewag

e T

reat

men

t Pla

nt50

day

s04

/22/

2051

06/3

0/20

5139

8E

xcav

ate

and

Rem

ove

Und

ergr

ound

Util

ities

120

days

11/1

9/20

5005

/05/

2051

399

Exc

avat

e an

d R

emov

e S

torm

Dra

ins,

Cat

ch B

asin

s an

d M

anho

les

25 d

ays

11/1

9/20

5012

/23/

2050

400

Rem

ove

and

Sto

ckpi

le E

xist

ing

Sea

wal

l Ero

sion

Pro

tect

ion

15 d

ays

05/0

6/20

5105

/26/

2051

401

Exc

avat

e an

d R

emov

e S

eaw

all a

nd P

edes

tria

n W

alkw

ay60

day

s07

/01/

2051

09/2

2/20

5140

2In

stal

l Sho

relin

e E

rosi

on C

ontr

ol a

nd R

esto

ratio

n F

eatu

res

20 d

ays

09/2

3/20

5110

/20/

2051

403

Fin

ish

Gra

ding

and

Re-

Veg

etat

e S

ite60

day

s09

/23/

2051

12/1

5/20

5140

4S

R P

d 8

End

s0

days

12/1

5/20

5112

/15/

2051

12/3

1

12/3

1 12/1

5

5/10

5/6

5/6

12/1

5

12

34

56

78

910

1112

1314

1516

1718

1920

2122

2324

2526

2728

2930

3132

3334

3536

3738

3940

4142

SON

GS

Uni

ts 1

, 2 &

3In

tegr

ated

Pro

ject

Sch

edul

ePr

ompt

DE

CO

N, D

OE

Acc

epta

nce

Beg

ins

2028

App

endi

x 1-

41

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Appendix D

Detailed Cost Table

Appendix 1-42

Item

Des

crip

tion

Lab

orE

quip

men

tO

ther

Con

ting

ency

Tot

alN

o

2014

Dol

lars

in T

hous

ands

Dis

posa

l

Tab

le 1

Scen

ario

Num

ber

1D

ecom

mis

sion

ing

Alt

erna

tive

DE

CO

N

Spe

nt F

uel A

lter

nati

veD

ry

Lic

ense

Sta

tus

PO

L

Fue

l Poo

l Sys

tem

sM

odif

ied

DO

E A

ccep

tanc

e:1/

1/20

28

SON

GS

Uni

t 1

Dec

omm

issi

onin

g C

ost

Est

imat

e, 2

028

DO

E A

ccep

tanc

e, D

ry S

tora

ge

Uni

t 1 S

hut D

own:

11/3

0/19

92

A. L

icen

se T

erm

inat

ion

Dec

on P

d 7

Dec

omm

issi

onin

g D

urin

g F

uel S

tora

ge -

Uni

t 1

Dis

trib

uted Upd

ate

Uni

t 1 D

ecom

mis

sion

ing

Cos

t Est

imat

e$3

98$0

$0$1

00$4

9820

.01

$0

Eng

inee

ring

Ana

lysi

s of

Tra

nspo

rtat

ion

and

Dis

posa

l Opt

ions

for

Uni

t 1 R

x V

esse

l $1

,395

$35

$0$3

57$1

,787

20.0

2$0

Eng

inee

ring

Pla

nnin

g an

d D

esig

n fo

r U

nit 1

Rx

Ves

sel D

ispo

siti

on$2

,220

$290

$0$6

28$3

,138

20.0

3$0

Tra

nspo

rtat

ion

and

Dis

posa

l of

Uni

t 1 R

x V

esse

l$3

,001

$1,1

04$5

,250

$15,

748

$78,

738

20.0

4$5

3,63

6

Tra

nspo

rtat

ion

and

Dis

posa

l of

Uni

t 1 G

TC

C W

aste

$0$0

$0$9

13$4

,563

20.0

5$3

,651

Subt

otal

$7,0

14$1

,428

$5,2

50$1

7,74

5$8

8,72

4D

istr

ibut

ed$5

7,28

7

Und

istr

ibut

edIn

sura

nce

- U

nit 1

$0$0

$1,1

98$3

00$1

,498

1.05

$0

NR

C D

ecom

mis

sion

ing

Fee

s$0

$0$8

,247

$2,0

62$1

0,30

81.

07$0

Wor

kers

Com

pens

atio

n In

sura

nce

- U

nit 1

$0$0

$286

$71

$357

1.14

$0

Gro

und

Wat

er M

onit

orin

g$1

,071

$0$5

,355

$1,6

06$8

,032

1.26

$0

Subt

otal

$1,0

71$0

$15,

085

$4,0

39$2

0,19

5U

ndis

trib

uted

$0

Subt

otal

$8,0

85$1

,428

$20,

335

$21,

784

$108

,919

Dec

on P

d 7

$57,

287

Dec

on P

d 8

Lic

ense

Ter

min

atio

n D

urin

g F

inal

Sit

e R

esto

rati

on -

Uni

t 1

Dis

trib

uted Pre

pare

Lic

ense

Ter

min

atio

n P

lan

- U

nit 1

$549

$13

$0$1

40$7

0121

.01

$0

Per

form

Fin

al S

tatu

s S

urve

y -

Uni

t 1$3

,515

$990

$0$1

,126

$5,6

3221

.02

$0

OR

ISE

Ver

ific

atio

n an

d N

RC

App

rova

l - U

nit 1

$0$0

$715

$179

$893

21.0

3$0

Subt

otal

$4,0

64$1

,003

$715

$1,4

45$7

,226

Dis

trib

uted

$0

Und

istr

ibut

edD

ecom

Age

nt$3

19$0

$0$8

0$3

991.

01$0

Insu

ranc

e -

Uni

t 1$0

$0$6

9$1

7$8

61.

05$0

NR

C D

ecom

mis

sion

ing

Fee

s$0

$0$6

92$1

73$8

661.

07$0

Mat

eria

ls a

nd S

ervi

ces

$0$1

1$0

$3$1

31.

08$0

Wor

kers

Com

pens

atio

n In

sura

nce

- U

nit 1

$0$0

$16

$4$2

11.

14$0

Subt

otal

$319

$11

$778

$277

$1,3

84U

ndis

trib

uted

$0

Subt

otal

$4,3

83$1

,013

$1,4

92$1

,722

$8,6

11D

econ

Pd

8$0

Pag

e 1

of 7

App

endi

x 1-

43

Item

Des

crip

tion

Lab

orE

quip

men

tO

ther

Con

ting

ency

Tot

alN

o

2014

Dol

lars

in T

hous

ands

Dis

posa

l

Tab

le 1

Scen

ario

Num

ber

1D

ecom

mis

sion

ing

Alt

erna

tive

DE

CO

N

Spe

nt F

uel A

lter

nati

veD

ry

Lic

ense

Sta

tus

PO

L

Fue

l Poo

l Sys

tem

sM

odif

ied

DO

E A

ccep

tanc

e:1/

1/20

28

SON

GS

Uni

t 1

Dec

omm

issi

onin

g C

ost

Est

imat

e, 2

028

DO

E A

ccep

tanc

e, D

ry S

tora

ge

Uni

t 1 S

hut D

own:

11/3

0/19

92

Subt

otal

$12,

468

$2,4

42$2

1,82

8$2

3,50

6$1

17,5

30A

. Lic

ense

Ter

min

atio

n$5

7,28

7

Pag

e 2

of 7

App

endi

x 1-

44

Item

Des

crip

tion

Lab

orE

quip

men

tO

ther

Con

ting

ency

Tot

alN

o

2014

Dol

lars

in T

hous

ands

Dis

posa

l

Tab

le 1

Scen

ario

Num

ber

1D

ecom

mis

sion

ing

Alt

erna

tive

DE

CO

N

Spe

nt F

uel A

lter

nati

veD

ry

Lic

ense

Sta

tus

PO

L

Fue

l Poo

l Sys

tem

sM

odif

ied

DO

E A

ccep

tanc

e:1/

1/20

28

SON

GS

Uni

t 1

Dec

omm

issi

onin

g C

ost

Est

imat

e, 2

028

DO

E A

ccep

tanc

e, D

ry S

tora

ge

Uni

t 1 S

hut D

own:

11/3

0/19

92

B. S

pent

Fue

l

SNF

Pd

2D

ry S

tora

ge D

urin

g D

ecom

mis

sion

ing

- Uni

t 1

Und

istr

ibut

edIn

sura

nce

- U

nit 1

$0$0

$882

$220

$1,1

022.

06$0

Subt

otal

$0$0

$882

$220

$1,1

02U

ndis

trib

uted

$0

Subt

otal

$0$0

$882

$220

$1,1

02SN

F P

d 2

$0

SNF

Pd

3D

ry S

tora

ge D

urin

g D

ecom

mis

sion

ing

- Uni

ts 1

, 2 a

nd 3

Und

istr

ibut

edD

ecom

Age

nt S

pent

Fue

l Sta

ff$4

,433

$0$0

$1,1

08$5

,541

2.01

$0

Dec

om A

gent

HP

Sup

plie

s$0

$165

$0$4

1$2

072.

02$0

Sec

urit

y G

uard

For

ce$7

,249

$0$0

$1,8

12$9

,061

2.04

$0

Sec

urit

y R

elat

ed E

xpen

ses

$284

$0$0

$71

$355

2.05

$0

Insu

ranc

e -

Uni

t 1$0

$0$2

,210

$552

$2,7

622.

06$0

NR

C S

pent

Fue

l Fee

s$0

$0$2

56$6

4$3

202.

08$0

Spe

nt F

uel M

aint

enan

ce$0

$0$1

64$4

1$2

052.

10$0

Mat

eria

ls a

nd S

ervi

ces

$0$2

24$0

$56

$280

2.11

$0

Ene

rgy

$0$0

$134

$34

$168

2.13

$0

Util

itie

s (W

ater

, gas

, pho

ne)

$0$1

53$0

$38

$192

2.18

$0

Per

sona

l Com

pute

rs$0

$0$1

$0$2

2.22

$0

Subt

otal

$11,

965

$543

$2,7

66$3

,818

$19,

092

Und

istr

ibut

ed$0

Subt

otal

$11,

965

$543

$2,7

66$3

,818

$19,

092

SNF

Pd

3$0

Pag

e 3

of 7

App

endi

x 1-

45

Item

Des

crip

tion

Lab

orE

quip

men

tO

ther

Con

ting

ency

Tot

alN

o

2014

Dol

lars

in T

hous

ands

Dis

posa

l

Tab

le 1

Scen

ario

Num

ber

1D

ecom

mis

sion

ing

Alt

erna

tive

DE

CO

N

Spe

nt F

uel A

lter

nati

veD

ry

Lic

ense

Sta

tus

PO

L

Fue

l Poo

l Sys

tem

sM

odif

ied

DO

E A

ccep

tanc

e:1/

1/20

28

SON

GS

Uni

t 1

Dec

omm

issi

onin

g C

ost

Est

imat

e, 2

028

DO

E A

ccep

tanc

e, D

ry S

tora

ge

Uni

t 1 S

hut D

own:

11/3

0/19

92

SNF

Pd

4D

ry S

tora

ge O

nly

- U

nits

1, 2

and

3U

ndis

trib

uted

Dec

om A

gent

Spe

nt F

uel S

taff

$1,0

64$0

$0$2

66$1

,330

2.01

$0

Dec

om A

gent

HP

Sup

plie

s$0

$74

$0$1

8$9

22.

02$0

Add

ition

al S

taff

for

Spe

nt F

uel S

hipp

ing

$94

$0$0

$23

$117

2.03

$0

Sec

urit

y G

uard

For

ce$1

,780

$0$0

$445

$2,2

252.

04$0

Sec

urit

y R

elat

ed E

xpen

ses

$328

$0$0

$82

$409

2.05

$0

Insu

ranc

e -

Uni

t 1$0

$0$5

43$1

36$6

782.

06$0

Sit

e L

ease

and

Eas

emen

t Exp

ense

s$0

$0$9

7$1

5$1

112.

07$0

NR

C S

pent

Fue

l Fee

s$0

$0$1

37$3

4$1

722.

08$0

Spe

nt F

uel M

aint

enan

ce$0

$0$4

0$1

0$5

02.

10$0

Mat

eria

ls a

nd S

ervi

ces

$0$6

5$0

$16

$81

2.11

$0

Ene

rgy

$0$0

$33

$8$4

12.

13$0

Util

itie

s (W

ater

, gas

, pho

ne)

$0$4

0$0

$10

$50

2.18

$0

Non

-Pro

cess

Com

pute

rs$0

$16

$0$4

$20

2.20

$0

Tel

ecom

mun

icat

ions

$0$1

6$0

$4$2

02.

21$0

Per

sona

l Com

pute

rs$0

$0$2

$0$2

2.22

$0

Subt

otal

$3,2

65$2

11$8

52$1

,072

$5,4

00U

ndis

trib

uted

$0

Subt

otal

$3,2

65$2

11$8

52$1

,072

$5,4

00SN

F P

d 4

$0

SNF

D&

D P

d 1

ISF

SI L

icen

se T

erm

inat

ion

Und

istr

ibut

edD

ecom

Age

nt S

pent

Fue

l Sta

ff$4

1$0

$0$1

0$5

12.

01$0

Sec

urit

y G

uard

For

ce$2

9$0

$0$7

$36

2.04

$0

Sec

urit

y R

elat

ed E

xpen

ses

$8$0

$0$2

$10

2.05

$0

Sit

e L

ease

and

Eas

emen

t Exp

ense

s$0

$0$1

1$2

$12

2.07

$0

NR

C S

pent

Fue

l Fee

s$0

$0$8

$2$1

02.

08$0

Mat

eria

ls a

nd S

ervi

ces

$0$2

$0$0

$22.

11$0

Ene

rgy

$0$0

$11

$3$1

42.

13$0

Util

itie

s (W

ater

, gas

, pho

ne)

$0$1

$0$0

$12.

18$0

Subt

otal

$77

$3$3

1$2

6$1

37U

ndis

trib

uted

$0

Subt

otal

$77

$3$3

1$2

6$1

37SN

F D

&D

Pd

1$0

Pag

e 4

of 7

App

endi

x 1-

46

Item

Des

crip

tion

Lab

orE

quip

men

tO

ther

Con

ting

ency

Tot

alN

o

2014

Dol

lars

in T

hous

ands

Dis

posa

l

Tab

le 1

Scen

ario

Num

ber

1D

ecom

mis

sion

ing

Alt

erna

tive

DE

CO

N

Spe

nt F

uel A

lter

nati

veD

ry

Lic

ense

Sta

tus

PO

L

Fue

l Poo

l Sys

tem

sM

odif

ied

DO

E A

ccep

tanc

e:1/

1/20

28

SON

GS

Uni

t 1

Dec

omm

issi

onin

g C

ost

Est

imat

e, 2

028

DO

E A

ccep

tanc

e, D

ry S

tora

ge

Uni

t 1 S

hut D

own:

11/3

0/19

92

SNF

D&

D P

d 2

ISF

SI D

emol

itio

nD

istr

ibut

ed Loa

d F

uel A

ssem

blie

s at

GE

Mor

ris

for

Shi

pmen

t to

DO

E -

Uni

t 1$1

,428

$106

$0$3

84$1

,918

13.0

1$0

Dec

on A

HS

Ms

$38

$16

$0$2

6$1

2913

.03

$49

Fin

al S

tatu

s S

urve

y of

IS

FS

I$1

77$2

8$0

$31

$236

13.0

4$0

Cle

an D

emol

itio

n of

IS

FS

I A

HS

Ms

and

Pad

$455

$288

$0$2

78$1

,391

13.0

5$3

70

Subt

otal

$2,0

97$4

39$0

$718

$3,6

74D

istr

ibut

ed$4

20

Und

istr

ibut

edD

ecom

Age

nt S

pent

Fue

l Sta

ff$2

00$0

$0$5

0$2

502.

01$0

Dec

om A

gent

HP

Sup

plie

s$0

$8$0

$2$1

02.

02$0

Sec

urit

y G

uard

For

ce$1

11$0

$0$2

8$1

392.

04$0

Sec

urit

y R

elat

ed E

xpen

ses

$4$0

$0$1

$52.

05$0

Mat

eria

ls a

nd S

ervi

ces

$0$1

0$0

$3$1

32.

11$0

DA

W D

ispo

sal

$0$0

$0$0

$12.

12$1

Ene

rgy

$0$0

$30

$7$3

72.

13$0

Dec

omm

issi

onin

g G

ener

al C

ontr

acto

r S

taff

$503

$0$0

$126

$628

2.14

$0

Cra

ft W

orke

r T

rain

ing

$21

$0$0

$5$2

62.

15$0

Util

itie

s (W

ater

, gas

, pho

ne)

$0$4

$0$1

$52.

18$0

DG

C H

P S

uppl

ies

$0$1

8$0

$4$2

22.

24$0

Subt

otal

$839

$40

$30

$227

$1,1

37U

ndis

trib

uted

$1

Subt

otal

$2,9

36$4

79$3

0$9

46$4

,811

SNF

D&

D P

d 2

$420

Subt

otal

$18,

243

$1,2

35$4

,559

$6,0

83$3

0,54

1B

. Spe

nt F

uel

$420

Pag

e 5

of 7

App

endi

x 1-

47

Item

Des

crip

tion

Lab

orE

quip

men

tO

ther

Con

ting

ency

Tot

alN

o

2014

Dol

lars

in T

hous

ands

Dis

posa

l

Tab

le 1

Scen

ario

Num

ber

1D

ecom

mis

sion

ing

Alt

erna

tive

DE

CO

N

Spe

nt F

uel A

lter

nati

veD

ry

Lic

ense

Sta

tus

PO

L

Fue

l Poo

l Sys

tem

sM

odif

ied

DO

E A

ccep

tanc

e:1/

1/20

28

SON

GS

Uni

t 1

Dec

omm

issi

onin

g C

ost

Est

imat

e, 2

028

DO

E A

ccep

tanc

e, D

ry S

tora

ge

Uni

t 1 S

hut D

own:

11/3

0/19

92

C. S

ite

Res

tora

tion

SR P

d 7

Pla

nnin

g fo

r C

ompl

etio

n of

Uni

t 1

Site

Res

tora

tion

Dis

trib

uted Sub

surf

ace

Str

uctu

re R

emov

al E

ngin

eeri

ng P

lann

ing

and

Des

ign

- U

nit 1

$436

$33

$0$1

17$5

8622

.01

$0

Env

iron

men

tal I

mpa

cts

Ana

lyse

s fo

r L

ease

Ter

min

atio

n A

ctiv

itie

s -

Uni

t 1$8

1$5

$105

$48

$238

22.0

2$0

Fin

al S

ite

Gra

ding

and

Sho

reli

ne P

rote

ctio

n E

ngin

eeri

ng P

lann

ing

and

Des

ign

- U

nit 1

$121

$13

$0$3

4$1

6822

.03

$0

Obt

ain

Req

uire

d P

erm

its

and

App

rova

ls f

or U

nit 1

Dem

olit

ion

$202

$20

$131

$88

$441

22.0

4$0

Uni

t 1 O

utfa

ll C

ondu

t Sur

vey

and

Env

iron

men

tal A

sses

smen

t$0

$0$5

25$1

31$6

5622

.05

$0

Eng

inee

ring

Pla

nnin

g an

d D

esig

n fo

r R

emov

al o

f U

nit 1

Out

fall

Con

duit

$0$0

$263

$66

$328

22.0

6$0

Obt

ain

Req

uire

d P

erm

its

and

App

rova

ls f

or U

nit 1

Out

fall

Con

duit

Rem

oval

$0$0

$263

$66

$328

22.0

7$0

Subt

otal

$839

$71

$1,2

86$5

49$2

,746

Dis

trib

uted

$0

Und

istr

ibut

edD

ecom

Age

nt$5

71$0

$0$1

43$7

143.

01$0

Mat

eria

ls a

nd S

ervi

ces

$0$2

7$0

$7$3

43.

06$0

Dec

omm

issi

onin

g G

ener

al C

ontr

acto

r S

taff

$890

$0$0

$223

$1,1

133.

08$0

Subt

otal

$1,4

61$2

7$0

$372

$1,8

61U

ndis

trib

uted

$0

Subt

otal

$2,3

01$9

9$1

,286

$921

$4,6

07SR

Pd

7$0

Pag

e 6

of 7

App

endi

x 1-

48

Item

Des

crip

tion

Lab

orE

quip

men

tO

ther

Con

ting

ency

Tot

alN

o

2014

Dol

lars

in T

hous

ands

Dis

posa

l

Tab

le 1

Scen

ario

Num

ber

1D

ecom

mis

sion

ing

Alt

erna

tive

DE

CO

N

Spe

nt F

uel A

lter

nati

veD

ry

Lic

ense

Sta

tus

PO

L

Fue

l Poo

l Sys

tem

sM

odif

ied

DO

E A

ccep

tanc

e:1/

1/20

28

SON

GS

Uni

t 1

Dec

omm

issi

onin

g C

ost

Est

imat

e, 2

028

DO

E A

ccep

tanc

e, D

ry S

tora

ge

Uni

t 1 S

hut D

own:

11/3

0/19

92

SR P

d 8

Fin

al S

ite

Res

tora

tion

and

Lea

se T

erm

inat

ion

- U

nit

1D

istr

ibut

ed Pro

cure

Sit

e R

esto

rati

on E

quip

men

t - U

nit 1

$0$3

,981

$0$9

95$4

,976

23.0

1$0

Inst

all D

ewat

erin

g S

yste

m -

Uni

t 1$0

$0$2

,922

$731

$3,6

5323

.02

$0

Exc

avat

e an

d R

emov

e S

lurr

y B

ackf

ill N

orth

-Eas

t of

Con

tain

men

t Fou

ndat

ion

- U

nit 1

$170

$204

$0$1

77$8

8523

.03

$334

Inst

all S

heet

Pil

ing

for

Con

tain

men

t Fou

ndat

ion

Exc

avat

ion

- U

nit 1

$847

$1,7

22$0

$642

$3,2

1123

.04

$0

Exc

avat

e an

d R

emov

e C

onta

inm

ent F

ound

atio

n -

Uni

t 1$8

95$1

,243

$0$1

,204

$6,0

2223

.05

$2,6

80

Rem

ove

She

et P

ilin

g fo

r C

onta

inm

ent F

ound

atio

n E

xcav

atio

n -

Uni

t 1$1

,178

$12

$0$2

97$1

,487

23.0

6$0

Exc

avat

e an

d R

emov

e S

lurr

y B

ackf

ill a

nd A

ncho

r B

lock

1 -

Uni

t 1$1

58$2

80$0

$309

$1,5

4423

.07

$797

Exc

avat

e an

d R

emov

e T

urbi

ne P

edes

tal F

ound

atio

n -

Uni

t 1$1

82$2

18$0

$292

$1,4

5923

.08

$767

Exc

avat

e an

d R

emov

e R

emai

ning

Cir

cula

ting

Wat

er S

truc

ture

s -

Uni

t 1$1

,283

$2,0

64$0

$1,8

19$9

,094

23.0

9$3

,929

Rem

ove

Uni

t 1 O

utfa

ll C

ondu

it$5

,969

$17,

051

$814

$6,8

68$3

4,33

923

.10

$3,6

37

Exc

avat

e an

d R

emov

e R

emai

ning

Slu

rry

Bac

kfil

l - U

nit 1

$105

$119

$0$9

9$4

9523

.11

$171

Rem

ove

Dew

ater

ing

Sys

tem

- U

nit 1

$0$0

$1,3

94$3

49$1

,743

23.1

2$0

Rem

ove

and

Dis

pose

of

Aux

ilar

y F

eedw

ater

Fou

ndat

ion

and

Tre

nch

- U

nit 1

$76

$125

$0$1

36$6

7823

.13

$341

Rem

ove

and

Dis

pose

of

Sew

age

Tre

atm

ent P

lant

- U

nit 1

$368

$522

$0$6

48$3

,241

23.1

4$1

,704

Exc

avat

e an

d R

emov

e U

nder

grou

nd U

tili

ties

- U

nit 1

$852

$313

$0$3

90$1

,948

23.1

5$3

93

Exc

avat

e an

d R

emov

e S

torm

Dra

ins,

Cat

ch B

asin

s an

d M

anho

les

- U

nit 1

$48

$77

$0$6

1$3

0423

.16

$118

Rem

ove

and

Sto

ckpi

le E

xist

ing

Sea

wal

l Ero

sion

Pro

tect

ion

- U

nit 1

$3$5

$0$2

$10

23.1

7$0

Exc

avat

e an

d R

emov

e S

eaw

all a

nd P

edes

tria

n W

alkw

ay -

Uni

t 1$4

60$1

40$0

$190

$949

23.1

8$1

60

Inst

all S

hore

line

Ero

sion

Con

trol

and

Res

tora

tion

Fea

ture

s -

Uni

t 1$2

$66

$0$1

7$8

623

.19

$0

Fin

ish

Gra

ding

and

Re-

Veg

etat

e S

ite

- U

nit 1

$147

$112

$0$6

5$3

2423

.20

$0

Subt

otal

$12,

743

$28,

254

$5,1

31$1

5,29

0$7

6,44

9D

istr

ibut

ed$1

5,03

1

Und

istr

ibut

edD

ecom

Age

nt$1

,494

$0$0

$373

$1,8

673.

01$0

Mat

eria

ls a

nd S

ervi

ces

$0$7

1$0

$18

$89

3.06

$0

Dec

omm

issi

onin

g G

ener

al C

ontr

acto

r S

taff

$6,6

82$0

$0$1

,671

$8,3

533.

08$0

Subt

otal

$8,1

76$7

1$0

$2,0

62$1

0,30

9U

ndis

trib

uted

$0

Subt

otal

$20,

919

$28,

325

$5,1

31$1

7,35

1$8

6,75

7SR

Pd

8$1

5,03

1

Subt

otal

$23,

220

$28,

424

$6,4

17$1

8,27

3$9

1,36

5C

. Sit

e R

esto

rati

on$1

5,03

1

Tot

al$5

3,93

1$3

2,80

4$4

7,86

2$2

39,4

361

Scen

ario

No.

$72,

738

$32,

101

Pag

e 7

of 7

App

endi

x 1-

49

2016 Decommissioning Cost Analysis of the Document No. 164007-DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0

Appendix E

Annual Cash Flow Table

Appendix 1-50

Year License Termination

Spent Fuel Site Restoration Total

2014 Dollars in Thousands

Scenario No. 1

Unit No: Unit 1

Unit 1 Decommissioning Cost Estimate, 2028 DOE Acceptance, Dry Storage

SONGS Annual Cost By Account

2016 $1,091 $322 $0 $1,414

2017 $594 $323 $0 $917

2018 $594 $323 $0 $917

2019 $594 $1,028 $0 $1,622

2020 $594 $1,526 $0 $2,120

2021 $3,986 $1,526 $0 $5,511

2022 $80,865 $1,526 $0 $82,391

2023 $594 $1,526 $0 $2,120

2024 $594 $1,526 $0 $2,120

2025 $594 $1,526 $0 $2,120

2026 $594 $1,526 $0 $2,120

2027 $594 $1,526 $0 $2,120

2028 $594 $1,526 $0 $2,120

2029 $594 $1,526 $0 $2,120

2030 $594 $1,526 $0 $2,120

2031 $594 $1,546 $0 $2,140

2032 $594 $1,757 $0 $2,351

2033 $594 $1,757 $0 $2,351

2034 $594 $1,755 $0 $2,349

2035 $5,157 $0 $0 $5,157

2036 $594 $0 $0 $594

2037 $594 $0 $0 $594

2038 $594 $0 $0 $594

2039 $594 $0 $0 $594

2040 $594 $0 $0 $594

2041 $594 $0 $0 $594

2042 $594 $0 $0 $594

2043 $594 $0 $0 $594

2044 $594 $0 $0 $594

2045 $594 $0 $0 $594

2046 $594 $0 $0 $594

2047 $594 $0 $0 $594

2048 $594 $0 $2,159 $2,753

2049 $595 $1 $1,946 $2,543

2050 $4,050 $2,794 $42,644 $49,487

2051 $4,559 $2,153 $44,616 $51,328

Total $117,530 $30,541 $91,365 $239,436

Page 1 of 1

Appendix 1-51

Appendix 2

Witness Qualifications

1

SOUTHERN CALIFORNIA EDISON COMPANY 1

QUALIFICATIONS AND PREPARED TESTIMONY 2

OF JOSE LUIS PEREZ 3

Q. Please state your name and business address for the record. 4

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

CA 91770. 6

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

A. I am a Principal Manager in the Nuclear Decommissioning Organization responsible for CPUC 8

regulatory activities and financial planning & analysis for SONGS issues. 9

Q. Briefly describe your educational and professional background. 10

A. I earned an MBA from the University of California, Irvine in 1997. I earned a Bachelor of 11

Science Degree in Civil Engineering from California State University, Long Beach in 1977. I 12

am a Registered Professional Engineer in the State of California. Since joining Edison in 1982, I 13

have held various management positions in nuclear generation business, finance, regulatory 14

affairs, planning & strategy, and project controls organizations. In addition, I have managed 15

various projects, including SONGS 1 decommissioning shortly after permanent shutdown and 16

industry restructuring financial analysis. Prior to joining Edison, my professional background 17

included various home office and jobsite positions in the civil engineering, nuclear power plant 18

start-up, and project controls organizations of Bechtel Power Corporation and the collection and 19

analysis of construction cost data for publication in cost estimating manuals for Marshall and 20

Swift Publications. 21

Q. What is the purpose of your testimony in this proceeding? 22

A. The purpose of my testimony in this proceeding is to sponsor the portions of Exhibit SCE-04: 23

Testimony On 2016 SONGS 1 Decommissioning Cost Estimate, as identified in the Table of 24

Contents thereto. 25

Q. Was this material prepared by you or under your supervision? 26

Appendix 2-1

2

A. Yes, it was. 1

Q. Insofar as this material is factual in nature, do you believe it to be correct? 2

A. Yes, I do. 3

Q. Insofar as this material is in the nature of opinion or judgment, does it represent your best 4

judgment? 5

A. Yes, it does. 6

Q. Does this conclude your qualifications and prepared testimony? 7

A. Yes, it does. 8

Appendix 2-2