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{{#Wiki_filter:SOUTHERN CALIFORNIA Thomas I. PalmisanoEDISON" Vice President & Chief Nuclear OfficerAn EDISON INT-RNA DOINAL I Company10 CFR 50.82(a)(4)(i)September 23, 2014U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington D.C. 20555-0001
{{#Wiki_filter:SOUTHERN CALIFORNIA Thomas I. Palmisano EDISON" Vice President  
& Chief Nuclear OfficerAn EDISON INT-RNA DOINAL I Company10 CFR 50.82(a)(4)(i)
September 23, 2014U. S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington D.C. 20555-0001


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


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


==Subject:==
==Subject:==
Certification of Permanent Cessation of PowerOperations San Onofre Nuclear Generating Station, Units 2 and 32. Letter from Thomas J. Palmisano (SCE) to the U.S. Nuclear RegulatoryCommission dated February 13, 2014;  
 
Certification of Permanent Cessation of PowerOperations San Onofre Nuclear Generating  
: Station, Units 2 and 32. Letter from Thomas J. Palmisano (SCE) to the U.S. Nuclear Regulatory Commission dated February 13, 2014;  


==Subject:==
==Subject:==
Access to NuclearDecommissioning Trust Funds, San Onofre Nuclear Station, Units 2 and 33. Letter from Richard C. Brabec (SCE) to the U.S. Nuclear RegulatoryCommission dated March 12, 2014;  
 
Access to NuclearDecommissioning Trust Funds, San Onofre Nuclear Station, Units 2 and 33. Letter from Richard C. Brabec (SCE) to the U.S. Nuclear Regulatory Commission dated March 12, 2014;  


==Subject:==
==Subject:==
Access to DecommissioningTrust Funds, San Onofre Nuclear Generating Station Units 2 and 34. Letter from Richard C. Brabec (SCE) to the U.S. Nuclear RegulatoryCommission dated March 31, 2014;  
 
Access to Decommissioning Trust Funds, San Onofre Nuclear Generating Station Units 2 and 34. Letter from Richard C. Brabec (SCE) to the U.S. Nuclear Regulatory Commission dated March 31, 2014;  


==Subject:==
==Subject:==
10 CFR 50.75(f)(1)Decommissioning Funding Status Report, San Onofre Nuclear GeneratingStation Units 2 and 3
 
10 CFR 50.75(f)(1)
Decommissioning Funding Status Report, San Onofre Nuclear Generating Station Units 2 and 3


==Dear Sir or Madam:==
==Dear Sir or Madam:==
On June 12, 2013, in accordance with 10 CFR 50.82(a)(1)(i), Southern California Edison (SCE)submitted a letter to the U.S. Nuclear Regulatory Commission (NRC) (Reference 1) certifyingthe permanent cessation of operations at San Onofre Nuclear Generating Station (SONGS),Units 2 and 3. In accordance with 10 CFR 50.54(bb) and 10 CFR 50.82(a)(4)(i), SCE isrequired to submit an Irradiated Fuel Management Plan (IFMP), Site Specific DecommissioningCost Estimate (DCE) and Post-Shutdown Decommissioning Activities Report (PSDAR) withintwo years of permanent cessation of operations.The SONGS, Units 2 and 3 DCE is attached. The SONGS, Units 2 and 3 IFMP and PSDAR arebeing concurrently submitted under separate cover letters. The DCE provides more currentestimates of annual cash flow than were previously provided in the Nuclear DecommissioningTrust Fund Exemption Request (References 2 and 3) and annual funding assurance update(Reference 4). Future filings with the California Public Utilities Commission will be based on theSONGS, Units 2 and 3 DCE and subsequent revisions.P.O. Box 128San Clemente, CA 92672(949) 368-6575 PAX 86575Fax: (949) 368-6183Tom. Pahnisano@sce.com The descriptions of decommissioning activities and phases in the DCE are consistent with thosedescribed in the PSDAR. Both the DCE and PSDAR represent SCE's current plans and aresubject to change as the project progresses. Much of the third-party contracting activitiesassociated with decommissioning are underway but have not been finalized. As contracts arefinalized and SCE progresses through the actual work of the decommissioning project, variousrisks will be realized or avoided and contingencies adjusted, accordingly.Changes to significant details will be included in subsequent revisions to the DCE as requiredby 10 CFR 50.54(bb). Financial assurance information will be provided on an annual basis asrequired by 10 CFR 50.75(f)(1).This letter does not contain any new commitments.If there are any questions or if additional information is needed, please contact me orMs. Andrea Sterdis at (949) 368-9985.Sincerely,
On June 12, 2013, in accordance with 10 CFR 50.82(a)(1)(i),
Southern California Edison (SCE)submitted a letter to the U.S. Nuclear Regulatory Commission (NRC) (Reference  
: 1) certifying the permanent cessation of operations at San Onofre Nuclear Generating Station (SONGS),Units 2 and 3. In accordance with 10 CFR 50.54(bb) and 10 CFR 50.82(a)(4)(i),
SCE isrequired to submit an Irradiated Fuel Management Plan (IFMP), Site Specific Decommissioning Cost Estimate (DCE) and Post-Shutdown Decommissioning Activities Report (PSDAR) withintwo years of permanent cessation of operations.
The SONGS, Units 2 and 3 DCE is attached.
The SONGS, Units 2 and 3 IFMP and PSDAR arebeing concurrently submitted under separate cover letters.
The DCE provides more currentestimates of annual cash flow than were previously provided in the Nuclear Decommissioning Trust Fund Exemption Request (References 2 and 3) and annual funding assurance update(Reference 4). Future filings with the California Public Utilities Commission will be based on theSONGS, Units 2 and 3 DCE and subsequent revisions.
P.O. Box 128San Clemente, CA 92672(949) 368-6575 PAX 86575Fax: (949) 368-6183Tom. Pahnisano@sce.com The descriptions of decommissioning activities and phases in the DCE are consistent with thosedescribed in the PSDAR. Both the DCE and PSDAR represent SCE's current plans and aresubject to change as the project progresses.
Much of the third-party contracting activities associated with decommissioning are underway but have not been finalized.
As contracts arefinalized and SCE progresses through the actual work of the decommissioning  
: project, variousrisks will be realized or avoided and contingencies  
: adjusted, accordingly.
Changes to significant details will be included in subsequent revisions to the DCE as requiredby 10 CFR 50.54(bb).
Financial assurance information will be provided on an annual basis asrequired by 10 CFR 50.75(f)(1).
This letter does not contain any new commitments.
If there are any questions or if additional information is needed, please contact me orMs. Andrea Sterdis at (949) 368-9985.
Sincerely,


==Enclosure:==
==Enclosure:==
San Onofre Nuclear Generating Station Units 2 and 3 Site SpecificDecommissioning Cost Estimatecc: M. L. Dapas, Regional Administrator, NRC Region IVT. J. Wengert, NRC Project Manager, San Onofre Units 2 and 3 DecommissioningR. E. Lantz, NRC Region IV, San Onofre Units 2 and 3G. G. Warrick, NRC Senior Resident Inspector, San Onofre Units 2 and 3S. Y. Hsu, California Department of Health Services, Radiologic Health Branch2 ENERGYSOLUTIONSDocument No. 164001-DCE-0012014 Decommissioning Cost Analysisof theSan Onofre Nuclear Generating Station Units 2 & 3Project No. 164001 Rev 1Prepared for:Southern California Edison.2244 Walnut Grove AvenueRosemead, CA 91770Prepared by:EnergySolutions, LLC100 Mill Plain RoadMailbox No. 106Danbury, CT 06811Authored By:Reviewed By:Approved ByMichael S. Williams, Project ManagerBarry S. Sims, Technical AdvisorA-Md .'September 5, 2014DateSeptember 5, 2014DateSeptember 5, 2014Michael S. Williams, Project ManagerDateNew ReportH Title Change[ Report Revision]Report RewriteEffective Sept 5, 2014DateElectronic documents, once printed, are uncontrolled and may become outdated.Refer to Document Control authority for the correct revision.
 
SONGS UNIT-2 AND UNIT-3DECOMMISSIONING COST ESTIMATEDESCRIPTION OF REVISIONMAJOR REVISION MINOR REVISION XREVISION NUMBER -1 EFFECTIVE DATE9/5/2014The revisions contained in this MINOR REVISION to the SONGS Unit-2 and Unit-3Decommissioning Cost Estimate are minor in nature and do not revise or otherwise impact thecontent or results of the cost estimate.ITEM-1A new Appendix-F is added to the DCE at the request of San Diego Gas & Electric Company(SDG&E) in order to provide information regarding its internal decommissioning costs which itexpects to incur and to fund on its own behalf in addition to its 20% share of theDecommissioning Cost Estimate.ITEM-2The APPENDICES section of the DCE Table of Contents is revised to include the newAPPENDIX-F SDG&E SONGS Decommissioning Costs (100%)ITEM-3Within the narrative section of the DCE the various appearances of the term "utility staff' havebeen revised to include a parenthetic statement "(Licensee)" to clarify that the utility staff meansthe NRC Licensee.ITEM-4On Table 6-1 "Cost and Schedule Summary" the title block for SPENT FUEL is revised toinclude "(72.30)" since this section also contains cost elements associated with ISFSIdecommissioning.ITEM-5Added new SDG&E footnote for Table 1-1 referring to Appendix FElectronic documents, once printed, are uncontrolled and may become outdated.Refer to Document Control authority for the correct revision.
San Onofre Nuclear Generating Station Units 2 and 3 Site SpecificDecommissioning Cost Estimatecc: M. L. Dapas, Regional Administrator, NRC Region IVT. J. Wengert, NRC Project Manager, San Onofre Units 2 and 3 Decommissioning R. E. Lantz, NRC Region IV, San Onofre Units 2 and 3G. G. Warrick, NRC Senior Resident Inspector, San Onofre Units 2 and 3S. Y. Hsu, California Department of Health Services, Radiologic Health Branch2 ENERGYSOLUTIONS Document No. 164001-DCE-001 2014 Decommissioning Cost Analysisof theSan Onofre Nuclear Generating Station Units 2 & 3Project No. 164001 Rev 1Prepared for:Southern California Edison.2244 Walnut Grove AvenueRosemead, CA 91770Prepared by:EnergySolutions, LLC100 Mill Plain RoadMailbox No. 106Danbury, CT 06811Authored By:Reviewed By:Approved ByMichael S. Williams, Project ManagerBarry S. Sims, Technical AdvisorA-Md .'September 5, 2014DateSeptember 5, 2014DateSeptember 5, 2014Michael S. Williams, Project ManagerDateNew ReportH Title Change[ Report Revision]Report RewriteEffective Sept 5, 2014DateElectronic documents, once printed, are uncontrolled and may become outdated.
2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001San Onofre Nuclear Generating Station Units 2 & 3TABLE OF CONTENTSSection Page1.0 EXECUTIVE SUM M ARY ...........................................................................................  
Refer to Document Control authority for the correct revision.
SONGS UNIT-2 AND UNIT-3DECOMMISSIONING COST ESTIMATEDESCRIPTION OF REVISIONMAJOR REVISION MINOR REVISION XREVISION NUMBER -1 EFFECTIVE DATE9/5/2014The revisions contained in this MINOR REVISION to the SONGS Unit-2 and Unit-3Decommissioning Cost Estimate are minor in nature and do not revise or otherwise impact thecontent or results of the cost estimate.
ITEM-1A new Appendix-F is added to the DCE at the request of San Diego Gas & Electric Company(SDG&E) in order to provide information regarding its internal decommissioning costs which itexpects to incur and to fund on its own behalf in addition to its 20% share of theDecommissioning Cost Estimate.
ITEM-2The APPENDICES section of the DCE Table of Contents is revised to include the newAPPENDIX-F SDG&E SONGS Decommissioning Costs (100%)ITEM-3Within the narrative section of the DCE the various appearances of the term "utility staff' havebeen revised to include a parenthetic statement  
"(Licensee)"
to clarify that the utility staff meansthe NRC Licensee.
ITEM-4On Table 6-1 "Cost and Schedule Summary" the title block for SPENT FUEL is revised toinclude "(72.30)"
since this section also contains cost elements associated with ISFSIdecommissioning.
ITEM-5Added new SDG&E footnote for Table 1-1 referring to Appendix FElectronic documents, once printed, are uncontrolled and may become outdated.
Refer to Document Control authority for the correct revision.
2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3TABLE OF CONTENTSSection Page1.0 EXECUTIVE SUM M ARY ...........................................................................................  


==52.0 INTRODUCTION==
==52.0 INTRODUCTION==
......................................................................................................... 82.1 Study Objective ................................................................................................... 82.2 Regulatory Framework .................................................................................... 103.0 STUDY M ETHODOLOGY ......................................................................................... 123.1 General Description ......................................................................................... 123.2 Schedule Analysis .............................................................................................. 123.3 Decommissioning Staff ..................................................................................... 133.4 W aste Disposal ................................................................................................... 133.5 Final Status Survey ........................................................................................... 163.6 Contingency ....................................................................................................... 163.7 Cost Reporting .................................................................................................. 174.0 SITE SPECIFIC TECHNICAL APPROACH ............................................................... 184.1 Facility Description ............................................................................................ 184.2 Decommissioning Periods ............................................................................... 184.3 Decommissioning Staff .................................................................................... 214.4 Spent Fuel M anagement Staff ........................................................................ 214.5 Spent Fuel Shipments ...................................................................................... 225.0 BASES OF ESTIM ATE AND KEY ASSUM PTIONS .............................................. 236.0 STUDY RESULTS ....................................................................................................... 2
 
.........................................................................................................
82.1 Study Objective  
...................................................................................................
82.2 Regulatory Framework  
....................................................................................
103.0 STUDY M ETHODOLOGY  
.........................................................................................
123.1 General Description  
.........................................................................................
123.2 Schedule Analysis  
..............................................................................................
123.3 Decommissioning Staff .....................................................................................
133.4 W aste Disposal  
...................................................................................................
133.5 Final Status Survey ...........................................................................................
163.6 Contingency  
.......................................................................................................
163.7 Cost Reporting  
..................................................................................................
174.0 SITE SPECIFIC TECHNICAL APPROACH  
...............................................................
184.1 Facility Description  
............................................................................................
184.2 Decommissioning Periods ...............................................................................
184.3 Decommissioning Staff ....................................................................................
214.4 Spent Fuel M anagement Staff ........................................................................
214.5 Spent Fuel Shipments  
......................................................................................
225.0 BASES OF ESTIM ATE AND KEY ASSUM PTIONS ..............................................
236.0 STUDY RESULTS .......................................................................................................
2


==87.0 REFERENCES==
==87.0 REFERENCES==
................................................................................................................. 37FIGURESFigure 1-1 Summary Schedule ......................................................................................... 7Figure 6-1 Summ ary Schedule ......................................................................................... 31TABLESTable 1-1 Decommissioning Cost Summ ary ....................................................................... 6Table 6-1 Cost and Schedule Summary ........................................................................... 32Table 6-2 Utility Staff Levels ....................................................................................... 33Table 6-3 DGC Staff Levels ................................. ..... .... 34Table 6-4 W aste Disposal Volumes .................................................................................. 35Page 2 of 37 2014 Decommissioning Cost Analysis of theSan Onofre Nuclear Generating Station Units 2 & 3Document No. 164001-DCE-001APPENDICESAppendix AAppendix BAppendix CAppendix DAppendix EAppendix FList of Systems and StructuresSpent Fuel Shipping ScheduleDetailed Project ScheduleDetailed Cost TableAnnual Cash Flow TableSDG&E SONGS Decommissioning Costs (100%)Page 3 of 37 2014 Decommissioning Cost Analysis of theSan Onofre Nuclear Generating Station Units 2 & 3Document No. 164001-DCE-001ACRONYMS AND ABBREVIATIONSAHSMAIFALARAAROCFRCPMDAWDGCDOEDSCESSFEMAFSSFTEGSAGTCCHPISFSILLRWLLWLLWPALOPMARSSIMMPCMWtNONNRCNSSSORISEPCBPGEPSDARPWRRIFSCESONGSSTRUCTTCEQWBSWCSUCFAdvanced Horizontal Storage ModulesAtomic Industrial ForumAs Low As Reasonably AchievableAsset Retirement ObligationCode of Federal RegulationsCritical Path MethodDry Active WasteDecommissioning General ContractorU.S. Department of EnergyDry Shielded CanisterEssential SystemFederal Emergency Management AgencyFinal Status SurveyFull Time EquivalentU.S. General Services AdministrationGreater Than Class CHealth PhysicsIndependent Spent Fuel Storage InstallationLow-Level Radioactive WasteLow Level WasteLow-Level Waste Policy ActLife-of-PlantMulti-Agency Radiation Survey and Site Investigation ManualMulti-Purpose CanisterMegawatt thermalNon-Essential SystemNuclear Regulatory CommissionNuclear Steam Supply SystemOak Ridge Institute for Science and EducationPolychlorinated BiphenylPacific Gas & ElectricPost-Shutdown Decommissioning Activities ReportPressurized Water ReactorReduction In ForceSouthern California EdisonSan Onofre Nuclear Generating StationStructureTexas Commission on Environmental QualityWork Breakdown StructureWaste Control Specialists LLCUnit Cost FactorPage 4 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001San Onofre Nuclear Generating Station Units 2 & 31.0 EXECUTIVE SUMMARYThis report presents the 2014 Decommissioning Cost Estimate (DCE) Study of the San OnofreNuclear Generating Station (SONGS) Units 2 & 3, hereinafter referred to as the 2014 CostStudy. The San Onofre Nuclear Generating Station is operated by the Southern CaliforniaEdison Company (SCE).On June 7, 2013, SCE announced its intention to permanently cease power generation operationsand shut down SONGS Units 2 & 3. Units 2 & 3 had not produced power since January 9, 2012and January 31, 2012, respectively. SCE now has the responsibility to decommission the site. InJanuary 2014 SCE contracted with EnergySolutions to evaluate decommissioning alternativesand assist in the development of a detailed project schedule and DCE to support the preparationand submittal of a Post Shutdown Decommissioning Activities Report (PSDAR) in accordancewith 10 CFR 50.82(a)(4)(i), which requires that a PSDAR be submitted within two yearsfollowing the permanent cessation of operations.This study has been performed to furnish an estimate of the costs for: (1) decommissioningSONGS Units 2 & 3 to the extent required to terminate the plant's operating license pursuant to10 CFR 50.75(c); (2) post-shutdown management of spent fuel until acceptance by the U.S.Department of Energy (DOE) pursuant to 10 CFR 50.54(bb); (3) demolition of uncontaminatedstructures and restoration of the site in accordance with the United States Department of NavyGrant of Easement (Ref. No. 14); and the California State Lands Commission Easement Lease(Ref. No. 15); and (4) Independent Spent Fuel Storage Installation (ISFSI) decommissioningpursuant to 10 CFR 72.30. This study includes SCE's actual costs incurred in the transitionalperiods following cessation of permanent operations on June 7, 2013 until December 31, 2013.Costs presented herein commencing on January 1, 2014 are estimated.SCE's December 2012 testimony to the CPUC provided the basis for the current spent fuelmanagement costs. SCE is continuing to review available information from the DOE todetermine if the DOE start date assumption of 2024 requires updating. The DCE will be revisedaccordingly as new information becomes available.Accordingly, the costs and schedules for all activities are segregated for regulatory purposes asfollows: costs for "License Termination" (10 CFR 50.75(c)); costs for "Spent Fuel Management"(10 CFR 50.54(bb)); costs for "Site Restoration" (clean removal and site restoration) final siteconditions; and costs for "ISFSI Decommissioning" (10 CFR 72.30). EnergySolutions hasestablished a Work Breakdown Structure (WBS) and cost accounting system to differentiatebetween these project accounts.This study analyzes the following technical approach to decommissioning as defined by SCE:" DECON methodology." Permanent cessation of operations on June 7, 2013." Termination of spent fuel pool operation six years after permanent shutdown." Spent fuel will be stored in Multi-Purpose Canisters (MPCs) at an on-siteIndependent Spent Fuel Storage Installation (ISFSI).Page 5 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001San Onofre Nuclear Generating Station Units 2 & 3" A dry transfer facility will not be necessary for transfer of SNF canisters fortransport." DOE begins accepting spent fuel from the industry in 2024 and completes theremoval of all SONGS spent fuel by 2049." Decommissioning will be performed by a Decommissioning General Contractor(DGC) with oversight by the SONGS participants." Incorporation of Life-of-Plant (LOP) Disposal Rates for Class A Low-LevelRadioactive Waste (LLRW)." Incorporation of disposal rates for Class B and C LLRW based on recent quotesfor 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 (whichcorrespond to 10 CFR 50.54 (bb) requirements); and Site Restoration costs (which correspond toactivities such as clean building demolition and site grading and end-state preparation as requiredunder the Site Easement).Table 1-1Decommissioning Cost Summary12(2014 Dollars in Thousands)License Termination 50.75(c) $1,034,230 $1,078,016 $2,112,246Spent Fuel Management 50.54(bb) $623,209 $652,987 $1,276,196Site Restoration $423,297 $599,507 $1,022,804Totals $2,080,735 $2,330,511 $4,411,246The estimate is based on site-specific plant systems and buildings inventories. Theseinventories, and EnergySolutions' proprietary Unit Cost Factors (UCFs), were used to generaterequired manhours, activity schedule hours and costs, and waste volume, weight, andclassification. Based on the activity schedule hours and a decommissioning activities analysis, aCritical Path Method (CPM) analysis was performed to determine the decommissioningschedules. These schedules reflect the effects of sequenced activity-dependent or distributeddecommissioning 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," "SpentFuel Management," or "Site Restoration." The summary is shown in Figure 1-1, and may alsobe found in Section 6.0 of this report.In addition, the Decommissioning Cost Summary in Table 1-1 does not include separate internal costs that SanDiego Gas & Electric Company (SDG&E) has indicated that it expects to incur. SDG&E provides informationregarding these costs in Appendix F2 Rows and columns may not add correctly due to rounding.Page 6 of 37 2014 Decommissioning Cost Analysis of theSan Onofre Nuclear Generating Station Units 2 & 3Document No. 164001-DCE-001Figure 1-1Summary ScheduleDECON with Dry Storage, 2013 Shutdown and DOE Acceptance in 2024Tad, NamoPotSitonSp"n Fuel If ggemenI~ : slo I ih t12 1314 161&1715 If 110111 1121121141151161171t5115ue1i2l1223fMl4251a27128ue20121 3l2aI32I3I5l2I72I41I VU7l1M3 W'201Spam Fuel 51*1*1n Complete -Unit ISpam Fuel Si*V Co._mpls -Units 2 & 3 1MO1M204. t1;31/2049SNF Pd 1-Spent Fuel Manegenunt Transition o0w7r014 12r2112012SNF Pd 2-Spen Fuel Tremelar to Dry Stwap 1711014 0&ii2Dt* *iSNF Pd 3- Dry SWtrage During Decommissioning- Units 1, 2 and $ 064O1I201/ 121g SUF Pd 4.Dry Only- Units 1, 2 ad 2 12/06=t 1212211MSNF Pd 5 -Dry Stamg 01* -Units 2 mnd 2 m2 =o1 12s21/049SNF D&D PdI -FSI DAD Planning 1211/2049 06/W20In flda r.. prnJ .an ..m n .I~teqr-* IW31MMMMW1W------------qPgwun e£- RWM uMW---vJl aRt So License Termination 06107/2 MA i'2~N=O[ IJtalg Deeon Pd 1 -Transition to Nouniesionifg 0610712012 12t1/2012Decon Pd 2. Decomnissioning Plmnning an Sias Modiclions WM II2II4 1 5MSDeom Pd 2-Decommisaioning Proeration and Reacko InwnlsSegmentation 1 o 2inoms o60&M1Deco Pd 4- Plant Systems and Lanp Component Removal 04111J 011241=21Decan Pd 5- BuddingDo ion 0WMJA4M 0WIM 41l a 1 .7 It..J Il. .i"It *OS-tYMMSits Reatoration -067r201l2 1.1...2..1SR Pd i -Transition to Simt -061O71201" -lSR Pd 2. Bu&&V Demolition Dufg t 06o MS 071111201?SR Pd 3. Si&awfa Oe nmolidan Enginsing anld Pem"n 1010=9 SR Pd 4- Buiding Demolilion to S Feet Below Grae o7n6120124 1t412026SR Pd e. Final Sit Reslomrion and Lease Teneuintion W0*06120 12W/16061Fmal Tanmnatc i2'fIS11 12115I1201 121Page 7 of 37 2014 Decommissioning Cost Analysis of theSan Onofre Nuclear Generating Station Units 2 & 3Document No. 164001-DCE-00


==
.................................................................................................................
37FIGURESFigure 1-1 Summary Schedule
.........................................................................................
7Figure 6-1 Summ ary Schedule
.........................................................................................
31TABLESTable 1-1 Decommissioning Cost Summ ary ...........................................................


==37.0 REFERENCES==
==37.0 REFERENCES==
: 1
: 1. U.S. Nuclear Regulatory Commission, "Domestic Licensing of Production andUtilization Facilities,"
10 CFR Part 50, 2008, Available fromhMp://www.nrc.gov/reading-rmndoc-collections/cfr/part050/full-text.html.
: 2. Atomic Industrial Forum, Inc., "Guidelines for Producing Commercial Nuclear PowerPlant Decommissioning Cost Estimates,"
AIF/NESP-036, May 1986.3. U.S. Nuclear Regulatory Commission, "Standard Format and Content ofDecommissioning Cost Estimates for Nuclear Power Reactors,"
Regulatory Guide 1.202,February 2005.4. Federal Register, Vol. 4, "Standard Contract for Disposal of Spent Nuclear Fuel and/orHigh-Level Radioactive Waste," NRC 10 CFR Part 961 (DOE), January 1, 1999.5. U.S. Nuclear Regulatory Commission, "Technology, Safety and Costs ofDecommissioning a Reference Pressurized Water Reactor Power Station,"
NUREG/CR-0130, June 1978.6. U.S. Nuclear Regulatory Commission, "Technology, Safety and Costs ofDecommissioning a Reference Boiling Water Reactor Power Station,"
NUREG/CR-0672, June 1980.7. Life-of-Plant Disposal Agreement, between EnergySolutions, LLC and SCE effective January 1 st, 2014.8. U.S. Nuclear Regulatory Commission, "Multi-Agency Radiation Survey and SiteInvestigation Manual (MARSSIM),"
NUREG-1575, Rev. 1, August 2000.9. U.S. Department of Energy, "Cost Estimating Guide," DOE G 430.1-1, March 1997.10. RS Means, "Labor Rates for the Construction Industry,"
2014.11. ABZ, Incorporated, "San Onofre Nuclear Generating Station Units 2 and 3 (SONGS2/3)", December 14,201212. U.S. Department of Energy, "Acceptance Priority Ranking & Annual Capacity Report,"DOE/RW-0567, July 2004.13. Pacific Gas &

Revision as of 09:07, 1 July 2018

San Onofre Nuclear Generating Station, Units 2 and 3, Site Specific Decommissioning Cost Estimate
ML14269A034
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 09/23/2014
From: Palmisano T J
Southern California Edison Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML14269A034 (93)


Text

SOUTHERN CALIFORNIA Thomas I. Palmisano EDISON" Vice President

& Chief Nuclear OfficerAn EDISON INT-RNA DOINAL I Company10 CFR 50.82(a)(4)(i)

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

Subject:

Docket Nos. 50-361 and 50-362,San Onofre Nuclear Generating

Station, Units 2 and 3Site Specific Decommissioning Cost Estimate

References:

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

Subject:

Certification of Permanent Cessation of PowerOperations San Onofre Nuclear Generating

Station, Units 2 and 32. Letter from Thomas J. Palmisano (SCE) to the U.S. Nuclear Regulatory Commission dated February 13, 2014;

Subject:

Access to NuclearDecommissioning Trust Funds, San Onofre Nuclear Station, Units 2 and 33. Letter from Richard C. Brabec (SCE) to the U.S. Nuclear Regulatory Commission dated March 12, 2014;

Subject:

Access to Decommissioning Trust Funds, San Onofre Nuclear Generating Station Units 2 and 34. Letter from Richard C. Brabec (SCE) to the U.S. Nuclear Regulatory Commission dated March 31, 2014;

Subject:

10 CFR 50.75(f)(1)

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

Dear Sir or Madam:

On June 12, 2013, in accordance with 10 CFR 50.82(a)(1)(i),

Southern California Edison (SCE)submitted a letter to the U.S. Nuclear Regulatory Commission (NRC) (Reference

1) certifying the permanent cessation of operations at San Onofre Nuclear Generating Station (SONGS),Units 2 and 3. In accordance with 10 CFR 50.54(bb) and 10 CFR 50.82(a)(4)(i),

SCE isrequired to submit an Irradiated Fuel Management Plan (IFMP), Site Specific Decommissioning Cost Estimate (DCE) and Post-Shutdown Decommissioning Activities Report (PSDAR) withintwo years of permanent cessation of operations.

The SONGS, Units 2 and 3 DCE is attached.

The SONGS, Units 2 and 3 IFMP and PSDAR arebeing concurrently submitted under separate cover letters.

The DCE provides more currentestimates of annual cash flow than were previously provided in the Nuclear Decommissioning Trust Fund Exemption Request (References 2 and 3) and annual funding assurance update(Reference 4). Future filings with the California Public Utilities Commission will be based on theSONGS, Units 2 and 3 DCE and subsequent revisions.

P.O. Box 128San Clemente, CA 92672(949) 368-6575 PAX 86575Fax: (949) 368-6183Tom. Pahnisano@sce.com The descriptions of decommissioning activities and phases in the DCE are consistent with thosedescribed in the PSDAR. Both the DCE and PSDAR represent SCE's current plans and aresubject to change as the project progresses.

Much of the third-party contracting activities associated with decommissioning are underway but have not been finalized.

As contracts arefinalized and SCE progresses through the actual work of the decommissioning

project, variousrisks will be realized or avoided and contingencies
adjusted, accordingly.

Changes to significant details will be included in subsequent revisions to the DCE as requiredby 10 CFR 50.54(bb).

Financial assurance information will be provided on an annual basis asrequired by 10 CFR 50.75(f)(1).

This letter does not contain any new commitments.

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

Sincerely,

Enclosure:

San Onofre Nuclear Generating Station Units 2 and 3 Site SpecificDecommissioning Cost Estimatecc: M. L. Dapas, Regional Administrator, NRC Region IVT. J. Wengert, NRC Project Manager, San Onofre Units 2 and 3 Decommissioning R. E. Lantz, NRC Region IV, San Onofre Units 2 and 3G. G. Warrick, NRC Senior Resident Inspector, San Onofre Units 2 and 3S. Y. Hsu, California Department of Health Services, Radiologic Health Branch2 ENERGYSOLUTIONS Document No. 164001-DCE-001 2014 Decommissioning Cost Analysisof theSan Onofre Nuclear Generating Station Units 2 & 3Project No. 164001 Rev 1Prepared for:Southern California Edison.2244 Walnut Grove AvenueRosemead, CA 91770Prepared by:EnergySolutions, LLC100 Mill Plain RoadMailbox No. 106Danbury, CT 06811Authored By:Reviewed By:Approved ByMichael S. Williams, Project ManagerBarry S. Sims, Technical AdvisorA-Md .'September 5, 2014DateSeptember 5, 2014DateSeptember 5, 2014Michael S. Williams, Project ManagerDateNew ReportH Title Change[ Report Revision]Report RewriteEffective Sept 5, 2014DateElectronic documents, once printed, are uncontrolled and may become outdated.

Refer to Document Control authority for the correct revision.

SONGS UNIT-2 AND UNIT-3DECOMMISSIONING COST ESTIMATEDESCRIPTION OF REVISIONMAJOR REVISION MINOR REVISION XREVISION NUMBER -1 EFFECTIVE DATE9/5/2014The revisions contained in this MINOR REVISION to the SONGS Unit-2 and Unit-3Decommissioning Cost Estimate are minor in nature and do not revise or otherwise impact thecontent or results of the cost estimate.

ITEM-1A new Appendix-F is added to the DCE at the request of San Diego Gas & Electric Company(SDG&E) in order to provide information regarding its internal decommissioning costs which itexpects to incur and to fund on its own behalf in addition to its 20% share of theDecommissioning Cost Estimate.

ITEM-2The APPENDICES section of the DCE Table of Contents is revised to include the newAPPENDIX-F SDG&E SONGS Decommissioning Costs (100%)ITEM-3Within the narrative section of the DCE the various appearances of the term "utility staff' havebeen revised to include a parenthetic statement

"(Licensee)"

to clarify that the utility staff meansthe NRC Licensee.

ITEM-4On Table 6-1 "Cost and Schedule Summary" the title block for SPENT FUEL is revised toinclude "(72.30)"

since this section also contains cost elements associated with ISFSIdecommissioning.

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

Refer to Document Control authority for the correct revision.

2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3TABLE OF CONTENTSSection Page1.0 EXECUTIVE SUM M ARY ...........................................................................................

52.0 INTRODUCTION

.........................................................................................................

82.1 Study Objective

...................................................................................................

82.2 Regulatory Framework

....................................................................................

103.0 STUDY M ETHODOLOGY

.........................................................................................

123.1 General Description

.........................................................................................

123.2 Schedule Analysis

..............................................................................................

123.3 Decommissioning Staff .....................................................................................

133.4 W aste Disposal

...................................................................................................

133.5 Final Status Survey ...........................................................................................

163.6 Contingency

.......................................................................................................

163.7 Cost Reporting

..................................................................................................

174.0 SITE SPECIFIC TECHNICAL APPROACH

...............................................................

184.1 Facility Description

............................................................................................

184.2 Decommissioning Periods ...............................................................................

184.3 Decommissioning Staff ....................................................................................

214.4 Spent Fuel M anagement Staff ........................................................................

214.5 Spent Fuel Shipments

......................................................................................

225.0 BASES OF ESTIM ATE AND KEY ASSUM PTIONS ..............................................

236.0 STUDY RESULTS .......................................................................................................

2

87.0 REFERENCES

.................................................................................................................

37FIGURESFigure 1-1 Summary Schedule

.........................................................................................

7Figure 6-1 Summ ary Schedule

.........................................................................................

31TABLESTable 1-1 Decommissioning Cost Summ ary .......................................................................

6Table 6-1 Cost and Schedule Summary ...........................................................................

32Table 6-2 Utility Staff Levels .......................................................................................

33Table 6-3 DGC Staff Levels .................................

..... .... 34Table 6-4 W aste Disposal Volumes ..................................................................................

35Page 2 of 37 2014 Decommissioning Cost Analysis of theSan Onofre Nuclear Generating Station Units 2 & 3Document No. 164001-DCE-001 APPENDICES Appendix AAppendix BAppendix CAppendix DAppendix EAppendix FList of Systems and Structures Spent Fuel Shipping ScheduleDetailed Project ScheduleDetailed Cost TableAnnual Cash Flow TableSDG&E SONGS Decommissioning Costs (100%)Page 3 of 37 2014 Decommissioning Cost Analysis of theSan Onofre Nuclear Generating Station Units 2 & 3Document No. 164001-DCE-001 ACRONYMS AND ABBREVIATIONS AHSMAIFALARAAROCFRCPMDAWDGCDOEDSCESSFEMAFSSFTEGSAGTCCHPISFSILLRWLLWLLWPALOPMARSSIMMPCMWtNONNRCNSSSORISEPCBPGEPSDARPWRRIFSCESONGSSTRUCTTCEQWBSWCSUCFAdvanced Horizontal Storage ModulesAtomic Industrial ForumAs Low As Reasonably Achievable Asset Retirement Obligation Code of Federal Regulations Critical Path MethodDry Active WasteDecommissioning General Contractor U.S. Department of EnergyDry Shielded CanisterEssential SystemFederal Emergency Management AgencyFinal Status SurveyFull Time Equivalent U.S. General Services Administration Greater Than Class CHealth PhysicsIndependent Spent Fuel Storage Installation Low-Level Radioactive WasteLow Level WasteLow-Level Waste Policy ActLife-of-Plant Multi-Agency Radiation Survey and Site Investigation ManualMulti-Purpose CanisterMegawatt thermalNon-Essential SystemNuclear Regulatory Commission Nuclear Steam Supply SystemOak Ridge Institute for Science and Education Polychlorinated BiphenylPacific Gas & ElectricPost-Shutdown Decommissioning Activities ReportPressurized Water ReactorReduction In ForceSouthern California EdisonSan Onofre Nuclear Generating StationStructure Texas Commission on Environmental QualityWork Breakdown Structure Waste Control Specialists LLCUnit Cost FactorPage 4 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 31.0 EXECUTIVE SUMMARYThis report presents the 2014 Decommissioning Cost Estimate (DCE) Study of the San OnofreNuclear Generating Station (SONGS) Units 2 & 3, hereinafter referred to as the 2014 CostStudy. The San Onofre Nuclear Generating Station is operated by the Southern California Edison Company (SCE).On June 7, 2013, SCE announced its intention to permanently cease power generation operations and shut down SONGS Units 2 & 3. Units 2 & 3 had not produced power since January 9, 2012and January 31, 2012, respectively.

SCE now has the responsibility to decommission the site. InJanuary 2014 SCE contracted with EnergySolutions to evaluate decommissioning alternatives and assist in the development of a detailed project schedule and DCE to support the preparation and submittal of a Post Shutdown Decommissioning Activities Report (PSDAR) in accordance with 10 CFR 50.82(a)(4)(i),

which requires that a PSDAR be submitted within two yearsfollowing the permanent cessation of operations.

This study has been performed to furnish an estimate of the costs for: (1) decommissioning SONGS Units 2 & 3 to the extent required to terminate the plant's operating license pursuant to10 CFR 50.75(c);

(2) post-shutdown management of spent fuel until acceptance by the U.S.Department of Energy (DOE) pursuant to 10 CFR 50.54(bb);

(3) demolition of uncontaminated structures and restoration of the site in accordance with the United States Department of NavyGrant of Easement (Ref. No. 14); and the California State Lands Commission Easement Lease(Ref. No. 15); and (4) Independent Spent Fuel Storage Installation (ISFSI) decommissioning pursuant to 10 CFR 72.30. This study includes SCE's actual costs incurred in the transitional periods following cessation of permanent operations on June 7, 2013 until December 31, 2013.Costs presented herein commencing on January 1, 2014 are estimated.

SCE's December 2012 testimony to the CPUC provided the basis for the current spent fuelmanagement costs. SCE is continuing to review available information from the DOE todetermine if the DOE start date assumption of 2024 requires updating.

The DCE will be revisedaccordingly as new information becomes available.

Accordingly, the costs and schedules for all activities are segregated for regulatory purposes asfollows:

costs for "License Termination" (10 CFR 50.75(c));

costs for "Spent Fuel Management" (10 CFR 50.54(bb));

costs for "Site Restoration" (clean removal and site restoration) final siteconditions; and costs for "ISFSI Decommissioning" (10 CFR 72.30). EnergySolutions hasestablished a Work Breakdown Structure (WBS) and cost accounting system to differentiate between these project accounts.

This study analyzes the following technical approach to decommissioning as defined by SCE:" DECON methodology.

" Permanent cessation of operations on June 7, 2013." Termination of spent fuel pool operation six years after permanent shutdown.

" Spent fuel will be stored in Multi-Purpose Canisters (MPCs) at an on-siteIndependent Spent Fuel Storage Installation (ISFSI).Page 5 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3" A dry transfer facility will not be necessary for transfer of SNF canisters fortransport.

" DOE begins accepting spent fuel from the industry in 2024 and completes theremoval of all SONGS spent fuel by 2049." Decommissioning will be performed by a Decommissioning General Contractor (DGC) with oversight by the SONGS participants.

" Incorporation of Life-of-Plant (LOP) Disposal Rates for Class A Low-Level Radioactive Waste (LLRW)." Incorporation of disposal rates for Class B and C LLRW based on recent quotesfor 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 (whichcorrespond to 10 CFR 50.54 (bb) requirements);

and Site Restoration costs (which correspond toactivities such as clean building demolition and site grading and end-state preparation as requiredunder the Site Easement).

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

License Termination 50.75(c)

$1,034,230

$1,078,016

$2,112,246 Spent Fuel Management 50.54(bb)

$623,209

$652,987

$1,276,196 Site Restoration

$423,297

$599,507

$1,022,804 Totals $2,080,735

$2,330,511

$4,411,246 The estimate is based on site-specific plant systems and buildings inventories.

Theseinventories, and EnergySolutions' proprietary Unit Cost Factors (UCFs), were used to generaterequired

manhours, activity schedule hours and costs, and waste volume, weight, andclassification.

Based on the activity schedule hours and a decommissioning activities

analysis, aCritical 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,"

"SpentFuel Management,"

or "Site Restoration."

The summary is shown in Figure 1-1, and may alsobe found in Section 6.0 of this report.In addition, the Decommissioning Cost Summary in Table 1-1 does not include separate internal costs that SanDiego Gas & Electric Company (SDG&E) has indicated that it expects to incur. SDG&E provides information regarding these costs in Appendix F2 Rows and columns may not add correctly due to rounding.

Page 6 of 37 2014 Decommissioning Cost Analysis of theSan Onofre Nuclear Generating Station Units 2 & 3Document No. 164001-DCE-001 Figure 1-1Summary ScheduleDECON with Dry Storage, 2013 Shutdown and DOE Acceptance in 2024Tad, NamoPotSitonSp"n Fuel If ggemenI~ : slo I ih t12 1314 161&1715 If 110111 1121121141151161171t5115ue1i2l1223fMl4251a27128ue20121 3l2aI32I3I5l2I72I41 I VU7l1M3 W'201Spam Fuel 51*1*1n Complete

-Unit ISpam Fuel Si*V Co._mpls

-Units 2 & 3 1MO1M204.

t1;31/2049 SNF Pd 1-Spent Fuel Manegenunt Transition o0w7r014 12r2112012 SNF Pd 2-Spen Fuel Tremelar to Dry Stwap 1711014 0&ii2Dt*

  • iSNF Pd 3- Dry SWtrage During Decommissioning-Units 1, 2 and $ 064O1I201/

121g SUF Pd 4.Dry Only- Units 1, 2 ad 2 12/06=t 1212211MSNF Pd 5 -Dry Stamg 01* -Units 2 mnd 2 m2 =o1 12s21/049 SNF D&D PdI -FSI DAD Planning 1211/2049 06/W20In flda r.. prnJ .an ..m n .I~teqr-* IW31MMMMW1W------------

qPgwun e£- RWM uMW---vJl aRt So License Termination 06107/2 MA i'2~N=O[

IJtalg Deeon Pd 1 -Transition to Nouniesionifg 0610712012 12t1/2012 Decon Pd 2. Decomnissioning Plmnning an Sias Modiclions WM II2II4 1 5MSDeom Pd 2-Decommisaioning Proeration and Reacko InwnlsSegmentation 1 o 2inoms o60&M1Deco Pd 4- Plant Systems and Lanp Component Removal 04111J 011241=21 Decan Pd 5- BuddingDo ion 0WMJA4M 0WIM 41l a 1 .7 It..J Il. .i"It *OS-tYMMSits Reatoration

-067r201l2 1.1...2..1 SR Pd i -Transition to Simt

-061O71201"

-lSR Pd 2. Bu&&V Demolition Dufg t 06o MS 071111201?

SR Pd 3. Si&awfa Oe nmolidan Enginsing anld Pem"n 1010=9 SR Pd 4- Buiding Demolilion to S Feet Below Grae o7n6120124 1t412026SR Pd e. Final Sit Reslomrion and Lease Teneuintion W0*06120 12W/16061 Fmal Tanmnatc i2'fIS11 12115I1201 121Page 7 of 37 2014 Decommissioning Cost Analysis of theSan Onofre Nuclear Generating Station Units 2 & 3Document No. 164001-DCE-001

2.0 INTRODUCTION

2.1 Study Objective This report presents the 2014 Decommissioning Cost Estimate Study of the San Onofre NuclearGenerating Station (SONGS) Units 2 & 3, hereinafter referred to as the 2014 Cost Study. TheSan Onofre Nuclear Generating Station is owned by the Southern California Edison Company(SCE), San Diego Gas & Electric

Company, and the City of Riverside.

A former owner, the Cityof Anaheim, also has liability for decommissioning.

SCE has provided the following information regarding the liability by owner for SONGS decommissioning costs:Cost Categories OwnersSDG&E Riverside Anaheim SCESONGS 1 20% 0% 0% 80%SONGS 2 20% 1.79% 2.4737% 75.7363%SONGS 3 20% 1.79% 2.4625% 75.7475%Common Facilities (Units 2 & 3) 20% 1.79% 2.4681% 75.7419%SONGS 1 Fuel 20% 0% 0% 80%SONGS 2/3 Fuel 20% 1.79% 2.3398% 75.8702%ISFSI Maintenance and D&D 20% 1.6066% 2.2686% 76.1248%San Diego Switchyard 100% 0% 0% 0%Edison Switchyard 0% 0% 0% 100%Interconnection Facilities 50% 0% 0% 50%Nuclear Fuel Cancellation Charges 20% 1.79% 0% 78.21%This study has been performed to support the development of a site-specific PSDAR and furnishan estimate of the costs for (1) decommissioning SONGS Units 2 & 3 to the extent required toterminate the plant's operating

license, (2) post-shutdown management of spent fuel untilacceptance 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 ofEasement (Ref. No. 14), and the California State Lands Commission Easement Lease (Ref. No.15), and (4) Independent Spent Fuel Storage Installation (ISFSI) decommissioning.

This studyalso includes SCE's actual costs incurred in the transitional periods following cessation ofpermanent operations until December 31, 2013. Estimated costs begin on January 1, 2014.The study methodology follows the basic approach originally presented in the Atomic Industrial Forum/National Environmental Studies Project Report AIF/NESP-036, "Guidelines forProducing Commercial Nuclear Power Plant Decommissioning Cost Estimates,"

(Ref. No. 2).The report was prepared in accordance with Nuclear Regulatory Commission (NRC) Regulatory Guide 1.202, "Standard Format and Content of Decommissioning Cost Estimates for NuclearPower Reactors,"

(Ref. No. 3). The estimate is based on compliance with current regulatory requirements and proven decommissioning technologies.

Page 8 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3NRC 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 plantfacility, those associated with storage of spent fuel on-site, and those associated with thedecommissioning 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.

10CFR 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 ofsite restoration activities that do not involve the removal of residual radioactivity necessary toterminate the NRC license(s).

10 CFR 50.54 (bb) requires funding by the licensee(s)

"for themanagement of all irradiated fuel at the reactor upon expiration of the reactor operating license(s) until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository."

10 CFR 72.30 requires funding fordecommissioning of the on-site spent fuel storage facility after the irradiated fuel is accepted bythe DOE.In addition to the NRC Decommissioning requirements described above, the Site Easements require the demolition and removal of all improvements installed on both the on-shore and off-shore sites, including all substructures regardless of depth, and site restoration to the satisfaction of the Grantors.

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

" DECON methodology.

" Permanent cessation of operations and commencement of decommissioning planning on June 7, 2013." Termination of spent fuel pool operation within six years after permanent shutdown.

" Spent fuel will be stored in transportable Multi-Purpose Canisters (MPCs) at anon-site Independent Spent Fuel Storage Installation (ISFSI)." A dry transfer facility will not be necessary for transfer of SNF canisters fortransport.

" DOE begins accepting spent fuel from the industry in 2024 and completes theremoval of all SONGS spent fuel by 2049." Decommissioning will be performed by a Decommissioning General Contractor (DGC) with oversight by the SONGS participants.

In addition, this study includes the following assumptions:

" Incorporation of EnergySolutions' Life-of-Plant (LOP) Disposal Rates for Class ALow-Level Radioactive Waste (LLRW), (Ref. No. 7)." Incorporation of disposal rates for Class B and C LLRW based on recent quotesfor disposal at the Waste Control Specialists LLC (WCS) site in Andrews County,Texas.Page 9 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 32.2 Regulatory Framework Provisions of current laws and regulations affecting decommissioning, waste management, andspent fuel management are as follows:1. NRC regulations require a license for on-site storage of spent fuel. Wet storage ina spent fuel pool is authorized by a facility's 10 CFR Part 50 license.

On-site drystorage of spent fuel at an Independent Spent Fuel Storage Installation (ISFSI) islicensed by either: (a) the general license set forth in 10 CFR 72.210, whichrequires that a Part 50 license be in place; or (b) a site-specific ISFSI licenseissued pursuant to 10 CFR Part 72.2. 10 CFR 50.75(c) requires funding by the licensee(s) of the facility fordecommissioning.

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 theoperating license(s),

whichever occurs first, to submit written notification to theNRC for its review and preliminary approval of the program by which thelicensee intends to manage and provide funding "for the management of allirradiated fuel at the reactor upon expiration of the reactor operating license untiltitle to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository."

4. 10 CFR 961 (Ref. No. 4), Appendix E, requires spent fuel to be cooled for at leastfive years before it can be accepted by DOE as "standard spent fuel."5. 10 CFR 72.30 requires funding by the licensee(s) for termination of the ISFSIlicense.Decommissioning Alternatives The three basic methods for decommissioning are DECON, SAFSTOR, and ENTOMB, whichare summarized as follows:1. DECON: The equipment, structures, and portions of the facility and site thatcontain radioactive contaminants are promptly removed or decontaminated to alevel that permits termination of the license after cessation of operations.
2. SAFSTOR:

The facility is placed in a safe, stable condition and maintained in thatstate (safe storage).

The facility is decontaminated and dismantled at the end ofthe storage period to levels that permit license termination.

NRC regulations require decommissioning to be completed within 60 years of cessation ofoperation.

3. ENTOMB: Radioactive structures,
systems, and components are encased in astructurally long-lived substance, such as concrete.

The entombed structure isappropriately maintained and monitored until radioactivity decays to a level thatpermits termination of the license.

Since entombment will exceed the requirement Page 10 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3for 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 powerplant operators are (1) wet storage consisting of continued maintenance and operation of thespent 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 presentcase at SONGS. Maintaining the spent fuel pool for an extended duration following cessation ofoperations prevents termination of the Part 50 license and typically has a higher annualmaintenance and operating cost than the dry storage alternative.

Transfer of spent fuel to anISFSI requires additional expenditures for purchase and construction of the ISFSI anddismantlement 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 thatDOE will commence accepting spent fuel from domestic commercial nuclear power plants in2024, and that the DOE will accept spent fuel at the rate published in DOE's July 2004Acceptance Priority Ranking & Annual Capacity Report (DOE/RW-0567)

(Ref. No. 12). Theseassumptions are in accordance with SCE testimony to the Public Utilities Commission of theState of California (Ref. No. 17). Additionally, SCE is reviewing available information from theDOE to determine if the DOE start date assumption requires updating.

The DCE will be revisedaccordingly as new information becomes available.

Page 11 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 33.0 STUDY METHODOLOGY 3.1 General Description EnergySolutions maintains a proprietary decommissioning cost model based upon thefundamental technical approach established in AIF/NESP-036, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates,"

dated May 1986 (Ref. No.2). The cost model has been updated frequently in accordance with regulatory requirements andindustry experience.

The cost model includes elements for estimating distributed andundistributed costs. Distributed costs are activity specific and include planning and preparation costs as well as costs for decontamination, packaging,

disposal, and removal of majorcomponents and systems.

For example, costs for the segmentation, packaging, and disposal ofthe reactor internals are distributed costs. Undistributed costs, sometimes referred to as collateral costs, are typically time dependent costs such as utility (Licensee) and decommissioning generalcontractor staff, property taxes, insurance, regulatory fees and permits, energy costs, and securitystaff.The methodology for preparing cost estimates for a selected decommissioning alternative requires development of a site-specific detailed work activity sequence based upon the plantinventory.

The activity sequence is used to define the labor, material, equipment, energyresources, 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 optionsavailable.

In the case of structures and small components and equipment such as piping, pumps, and tanks,the work durations and costs are calculated based on UCFs. UCFs are economic parameters developed to express costs per unit of work output, piece of equipment, or time. They aredeveloped using decommissioning experience, information on the latest technology applicable todecommissioning, and engineering judgment.

The total cost of a specific decommissioning activity can be determined by multiplying the total number of units associated with that activityby the UCF, expressed as $/unit, for that activity.

For example, the estimated demolition cost ofa non-contaminated concrete structure can be obtained by multiplying the volume of concrete inthe 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 AnalysisAfter the work activity durations are calculated for all distributed activities, a critical pathschedule analysis is performed using MS Project.

The schedule accounts for constraints such asspent fuel cooling periods and regulatory reviews.

The schedule is typically delineated intophases or time periods (hereinafter referred to as period or periods) that differentiate manpowerrequirements and undistributed costs.In order to differentiate between License Termination, Spent Fuel, and Site Restoration elementsof the entire decommissioning scope of work, EnergySohltions has established a WorkBreakdown Structure (WBS) and cost accounting system to treat each element as a subproject.

Page 12 of 37 2014 Decommissioning Cost Analysis of theSan Onofre Nuclear Generating Station Units 2 & 3Document No. 164001-DCE-001 Accordingly, the overall project schedule is divided into interrelated periods with majormilestones defining the beginning and ending of each period. The major milestones also serve asthe basis for integrating the periods of the three subprojects.

3.3 Decommissioning StaffEnergySolutions has assumed that the SONGS Units 2 and 3 decommissioning project will beperformed in an efficiently planned and executed manner using project personnel experienced indecommissioning.

This DCE assumes that the decommissioning will be performed by a highlyexperienced and qualified DGC, with oversight and management of the decommissioning operations performed by the Licensee staff. It is also assumed that the Utility (Licensee) staffwill be supplemented by a professional consulting engineering firm, particularly in the planningand preparation phase.EnergySolutions analyzed the SONGS licensee staff and developed a site-specific staffing plan.The SCE existing salary structure was then used as the basis for calculating Utility (Licensee) staff labor costs. EnergySolutions used industry data to develop DGC salary costs.Staffing levels, for both staffing plans and for each project period, are based on the AtomicIndustrial Forum (AIF) guidelines and industry experience.

The sizes of the staffs are varied ineach period in accordance with the requirements of the work activities.

Staffing has beenorganized into the following departments or functional groups:" Decommissioning

" Engineering

" Maintenance and Work Control" Operations

" Oversight and Nuclear Safety" Radiation Protection and Chemistry

" Regulatory and Emergency Planning" Safety and Human Performance

" Security Administration

" Security Guard Force" Site Management and Administration

" Additional Staff for Spent Fuel Shipping" DGC Staff3.4 Waste DisposalWaste management costs comprise a significant portion of the decommissioning cost estimate.

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

Waste Classification Regulations governing disposal of radioactive waste are stringent in order to ensure control ofthe waste and preclude adverse impact on public health and safety. At present, LLRW disposalPage 13 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3is 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 suchthat it is acceptable for burial at licensed LLRW disposal sites.For each waste classification, 10 CFR 61 stipulates specific criteria for physical and chemicalproperties that the LLRW must meet in order to be accepted at a licensed disposal site. TheLLRW 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 byemploying a combination of analytical techniques such as computerized analyses based uponscaling factors, sample laboratory

analyses, and direct assay methods.

Having performed anisotopic 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)) asdefined in 10 CFR 61.EnergySolutions' classification of LLRW resulting from decommissioning activities is based onAIF/NESP-036 (Ref. No. 2), NUREG/CR-0130 (Ref. No. 5), NUREG/CR-0672 (Ref. No. 6),and recent industry experience.

The estimated curie content of the reactor vessel and internals atshutdown is derived from NUREG/CR-0130 for Pressurized Water Reactors (PWRs) andNUREG/CR-0672 for Boiling Water Reactors (BWRs), and adjusted for the different mass ofcomponents and period of decay.Packaging Selection of the type and quantity of containers required for Class B and C wastes is based on themost restrictive of either curie content, dose-rate, container weight limit, or container volumelimit. GTCC wastes from segmentation of the reactor vessel internals is packaged in spent fuelcanisters.

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. Largecomponents, such as steam generators, pressurizers, and reactor recirculation pumps, are shippedas their own containers with additional shielding as required.

Container costs are obtained from manufacturers specializing in the design and fabrication ofstorage containers for nuclear materials.

Shielded transport cask and liner costs are obtainedfrom 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 selectedroutes and modes are obtained from vendor quotes or published tariffs whenever possible.

Class A Disposal Options and RatesIn accordance with the existing Life-of-Plant Disposal Agreement (Ref. No. 7), all Class A wastethat meets the waste acceptance criteria are to be disposed of at EnergySolutions' LLRWPage 14 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3disposal facility in Clive, Utah. All reported waste disposal costs include packaging, transportation, and any applicable surcharges.

Class B and C Disposal Options and RatesCurrently, 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 byEnergySolutions in Barnwell, South Carolina; the U.S. Ecology facility in Richland, Washington; and the recently licensed facility in Andrews County, Texas operated by WasteControl Specialists.

Barnwell only accepts waste from states within the Atlantic Compact andU.S. Ecology only accepts waste from states within the Northwest and Rocky MountainCompacts.

However, the WCS facility will accept waste from the Texas Compact (comprised ofTexas and Vermont) and from non-Compact generators.

The Texas Compact Commission onMarch 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 disposalfacilities.

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, thesecomponents, which are referred to as Greater Than Class C (GTCC) wastes, cannot be disposedof in a near-surface LLRW disposal facility and must be transferred to a geologic repository or asimilar site approved by the NRC.Highly activated sections of the reactor vessel internals will result in GTCC waste. Presently, afacility 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. Althoughcourts have held that DOE is obligated to accept and dispose of GTCC, issues regarding potential costs remain potentially unsettled.

Therefore, EnergySolutions conservatively estimates a GTCCwaste disposal cost. EnergySolutions assumes that the GTCC waste will be packaged in spentfuel canisters and will be shipped to a storage or disposal facility operated by DOE along withthe spent fuel. Additionally, EnergySolutions assumes shipping costs for GTCC waste to beequivalent to the commercial cost of shipping a Type B licensed, shielded cask such as the CNS8-120B cask, which is owned and operated by EnergySolutions.

LLRW Volume Reduction Becasue current Class A LLRW disposal rates are significantly lower than LLRW volumereduction rates, EnergySolutions does not assume on-site volume reduction techniques such aswaste compaction or an aggressive decontamination, survey and release effort.Non-Radioactive Non-Hazardous Waste DisposalEnergySolutions assumes that recyclable, non-radioactive scrap metal resulting from thedecommissioning program will be sold to a scrap metal dealer. However, no cost credit isassumed in the estimate for the value of the scrap metal. Clean (non-contaminated) concrete anddemolition debris is assumed to be removed off site to an out of state Class III landfill consistent Page 15 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3with the Governor of the State of California Executive Order D-62-02 (Ref. No. 16). This studyincludes the costs of installation and operation of EnergySolutions' GAmma Radiation Detection and In-container ANalysis or GARDIAN System. The GARDIAN System performs radiological assays of bulk shipping containers.

The GARDIAN System is a cost effective and efficient means to ensure all non-radiological waste and recyclable materials arising from thedecommissioning and demolition of the SONGS' site comply with all applicable regulatory requirements.

Hazardous and Industrial Waste DisposalUncontaminated lead shielding remaining after shutdown was assumed to be removed from itsinstalled locations and shipped offsite by entities having a need for the material.

The entities willreceive the lead at no charge in return for providing the removal and shipping services.

Non-Radioactive contaminated surfaces coated with tightly adhering and undamaged lead based paintwill be removed as non-hazardous building demolition debris. All other chemicals andhazardous materials present at shutdown will be removed and properly disposed of duringdecommissioning.

3.5 Final Status SurveyThe cost of performing a final status survey (FSS) is based on NUREG-1575, "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM),"

(Ref. No. 8). Estimates ofMARSSIM Class I, II, and III survey designations are based on radiological assumptions regarding contamination resulting from small and large component removal activities.

The FSSactivity cost calculation includes the in-place remote survey of underground metal and concretepipe, soil, and groundwater sampling and analysis.

Estimated costs for NRC and Oak RidgeInstitute for Science and Education (ORISE) verification are also included, and the NRC reviewperiod 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 overthat expected; equipment breakdowns, weather delays, and labor strikes.

This is consistent withthe definition provided in the DOE Cost Estimating Guide, DOE G 430.1-1, 3-28-97 (DOE G)(Ref. No. 9). Contingency "covers costs that may result from incomplete design, unforeseen andunpredictable conditions, or uncertainties within the defined project scope. The amount ofcontingency will depend on the status of design, procurement, and construction; and thecomplexity and uncertainties of the component parts of the project.

Contingency is not to beused to avoid making an accurate assessment of expected costs." EnergySolutions determines site-specific contingency factors to be applied to each estimate based on industry practices.

The DOE has established a recommended range of contingencies as a function of completeness of program design, DOE G. The ranges are:Page 16 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3Contingency RangeType of Estimate as a % of Total EstimatePlanning Phase Estimate 20-30Budget Estimate 15-25Title I (Preliminary Design Estimate) 10-20Title II (Definitive Design Estimate) 5-15Also, the Pacific Gas & Electric Company (PG&E) Technical Position Paper "Establishing anAppropriate Contingency Factor for Inclusion in the Decommissioning Revenue Requirements" (Ref. No. 13) was developed to review and determine a "conservative contingency factor" to beapplied to decommissioning cost estimates.

In that study it was determined that "based on anunderstanding of the level of project definition, and the extent and maturity of estimate inputinformation used to develop decommissioning cost estimates, the 25 percent contingency factoris within the range of industry recognized cost engineering practices."

The contingencies presented in this study are consistent with the values presented in DOE G430.1-1 for a Planning Phase estimate (Ref. No. 9) and the PG&E study (Ref. No. 13). Asdirected by SCE, EnergySolutions has applied a 25% contingency to all costs in this study, withthe exception of following:

2013 and 2014 Actual Expenditures 0%Department of Navy Easement Payments 15%Hazardous and Asbestos Wastes 50%Site Characterization Surveys 15%Temporary Facilities 15%Backfill and Compaction 15%A reactor decommissioning program will be conducted under an NRC-approved QualityAssurance Program which meets the requirements of 10 CFR 50, Appendix B. However, thedevelopment of the quality assurance

program, the performance of work under that program, andthe effort required to ensure compliance with the program, is already included in the detailed costestimate.

Therefore, EnergySolutions does not include quality assurance as an element of thecontingency allowance.

The same is true for contamination.

Where radioactive contamination or activated materials are dealt with, the EnergySolutions UCFs and associated calculations fullyreflect the cost impact of that material, and a separate contingency is not required specifically due to working with contamination.

3.7 Cost Reporting Total project costs are aggregated from the distributed activity and undistributed costs into thefollowing categories

-Labor, Materials and Equipment, Waste Disposal, and Other costs. Othercosts include property taxes, insurance, license fees, permits, and energy. Waste Disposal costsare 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 ofeach distributed activity cost and included in the category of Material and Equipment, with theexception that HP supplies for the Utility HP staff are calculated and reported as an undistributed line item. A line item specific contingency is then calculated for each activity cost element.Page 17 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 34.0 SITE SPECIFIC TECHNICAL APPROACH4.1 Facility Description The San Onofre Nuclear Generating Station Units 2 & 3 site is located in southern California onthe shore of the Pacific Ocean, about 62 miles Southeast of Los Angeles and approximately 51miles Northwest of San Diego. The station is located entirely within the Camp Pendleton MarineCorps Base. The current Grant of Easement for the site from the United States Department of theNavy is currently scheduled to expire May 12, 2023 (Ref. No. 14). Units 2 & 3 occupy 52.8acres of the 84 acre site. Approximately 16 acres are occupied by the North Industrial Area(formerly Unit 1), which is where the existing ISFSI is located.The Nuclear Steam Supply System (NSSS) for both units are identical, with two independent loops, and utilizing pressurized light water cooled reactors (PWRs) supplied by Combustion Engineering, Inc. The construction permit was issued for an initial reactor power of 3,390 MWtwith licensed Rated Thermal Power of 3,438 MWt.The facility currently has an existing ISFSI containing spent fuel that was transferred into MPCsto maintain full core offload capability during operations and to facilitate decommissioning ofUnit 1. This study also assumes that the MPCs will be licensed under a 10 CFR Part 72 generallicense, using the manufacturer's Certificate of Compliance.

The 10 CFR Part 50 license will bemaintained until decommissioning is complete and all spent fuel has been transferred to DOE.Appendix A provides a list of the SONGS Unit 2 & 3 systems and structures included in thematerial inventory for this study.4.2 Decommissioning PeriodsThe project periods consist of six License Termination

periods, seven Spent Fuel Management periods (two of which are ISFSI decontamination and demolition periods),

and six SiteRestoration periods.

As shown in Figure 1-1 above, the periods for each of these project areasare independent from (do not compete with) the periods for the other project areas. The projectperiods defined for this site-specific study and the major activities performed during each periodare as follows:License Termination PeriodsDecon Pd 1 -Transition to Decommissioning

" Defuel Reactors" Notification of Permanent Fuel Removal" Disposition of LLRW ResinsDecon Pd 2 -Decommissioning Planning and Site Modifications

" Preparation of Decommissioning License Documents

" Preparation of NRC Deliverables

" Submit PSDAR to NRC" Perform Historical Site Assessment and Site Characterization

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

Page 18 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3" Design and Implement Spent Fuel Pool Support System Modifications, ControlRoom Relocation, and Spent Fuel Security System Modifications

" Select Decommissioning General Contractor (DGC)Decon Pd 3 -Decommissioning Preparations and Reactor Internal Segmentation

" DGC Mobilization and Planning" System Decontamination

" Reactor Internals Removal Preparations

" Reactor Internals Segmentation Planning and Implementation

" Purchase Dry Storage Modules for GTCC Waste" Segment and Package Reactor Internals for Storage in the ISFSIDecon Pd 4 -Plant Systems and Large Component Removal" Upgrade Rail Spur on 'Owner Controlled Area' (does not affect spur connecting to CALTRANS).

" Install Large Array Radiation Detection System" Remove, Package, and Dispose of Non-Essential Systems" Asbestos and Lead Abatement

" Fuel Pool Closure" Remove Spent Fuel Racks, Spent Fuel Pool Island Equipment, and Bridge Cranes" Remove and Dispose of Legacy Class B & C Wastes" Remove, Package, and Dispose of Essential Systems" Removal and Disposal of Spent Resins, Filter Media, and Tank Sludge" Large Component Removal" Prepare License Termination PlanDecon Pd 5 -Building Decontamination

" Decon Containment Buildings

-Units 2 & 3" Decon Turbine Buildings

-Units 2 & 3" Decon Fuel Handling Buildings

-Units 2 & 3" Decon Auxiliary Radwaste Building" Decon Auxiliary Control Building" Decon Penetration Buildings

-Units 2 & 3" Decon Safety Equipment and Main Steam Isolation Valve Buildings

-Units 2 &3" Radiological Survey of Structures During DeconDecon Pd 6 -License Termination During Decommissioning

" Final Status Survey" ORISE Verification and NRC ApprovalSpent Fuel Management PeriodsSNF Pd 1 -Spent Fuel Transfer Management Transition

" Implementation of Security Enhancements Required for Reductions in Staff" Cyber Security Modifications

" Post Fukushima Modifications

-Unit 2" Design and Fabricate Spent Fuel Canisters Page 19 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3SNF Pd 2 -Spent Fuel Transfer to Dry Storage" Prepare Irradiated Fuel Management Plan" Select Dry Storage System Canister Design and Vendor" Design and Construct ISFSI Expansion

" Purchase, Deliver and Load Spent Fuel Canisters and Transfer to ISFSISNF Pd 3 -Dry Storage During Decommissioning Units 1, 2, & 3SNF Pd 4 -Dry Storage Only -Units 1, 2, & 3SNF Pd 5 -Dry Storage Only -Units 2, & 3SNF D&D Pd 1 -ISFSI License Termination N Preparation and NRC Review of License Termination PlanSNF 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 ReviewSite Restoration PeriodsSR Pd 1 -Transition to Site Restoration

" Severance Costs from Post-Shutdown Reduction in Staffing" Phase I and II Environmental Assessment of the Mesa Site" Disposition of Hazardous Waste at the Mesa Site" Site Characterization of the Mesa SiteSR Pd 2 -Building Demolition During Decommissioning

" Demolish South Access for Decommissioning, South Yard Facility, and MesaStructures

" Finish Grade and Re-vegetate Mesa Site" Mesa Lease Termination SR Pd 3 -Subsurface Demolition Engineering

& Permitting

" Hydrogeologic Investigation and Outfall Conduit Survey" Subsurface Structure Removal Analyses for Lease Termination Activities

" Final Site Grading and Shoreline Protection Engineering Planning and Design" Obtain Permits and Approvals SR Pd 4 -Building Demolition to 3 Feet Below Grade" Demolition Preparations

" De-Tension and Remove Containment Building Tendons -Units 2 & 3" Demolish Diesel Generator Buildings

-Units 2 & 3" Demolish Condensate Buildings and Transformer Pads -Units 2 & 3Page 20 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3" Demolish Full Flow Areas and Turbine Buildings

-Units 2 & 3" Demolish Auxiliary Radwaste Building0 Demolish Auxiliary Control Building" Remove Systems and Demolish Make-up Demineralizer Structures

" Demolish Penetration Buildings

-Units 2 & 3" Demolish Safety Equipment and Main Steam Isolation Valve Buildings

-Units 2& 3" Demolish Fuel Handling Buildings to 3 Feet Below Grade -Units 2 & 3" Demolish Containment Buildings to 3 Feet Below Grade -Units 2 & 3" Demolish Intake and Discharge Structures to 3 Feet Below GradeSR Pd 5 -Subgrade Structure Removal Below -3 Feet" Install Sheet Piling and Excavation

Shoring, Dewatering System, and EffluentTreatment and Discharge Controls" Demolish and Backfill Unit 3 Subsurface Structures

" Demolish and Backfill Unit 2 Subsurface Structures

" Demolish and Backfill Common Subsurface Structures

" Demolish and Backfill Intake Structure Inside Seawall Below -3 Feet" Remove Off Shore Intake and Outfall Conduits" Remove Sheet Piling, Excavation

Shoring, and Dewatering and EffluentTreatment

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

" Obtain Required Permits and Approvals

" Install Dewatering System and Effluent Treatment and Discharge Controls" Remove and Stockpile Existing Seawall Erosion Protection

" Remove Unit 2 & 3 Seawall and Pedestrian Walkway" Remove Remaining Intake Structure Beneath Seawall" Backfill and Compaction of Excavation

" Remove Dewatering System & Effluent Treatment

" Remove Railroad Tracks, Gunite Slope Protection, Access Road, and NorthParking Lot" Finish Grading and Re-vegetate Site4.3 Decommissioning StaffEnergySolutions developed staffing based on the assumption that decommissioning will beperformed by an experienced and qualified DGC, with oversight and management of thedecommissioning operations performed by the Utility (Licensee) staff. It is also assumed thatthe Utility staff will be supplemented by a professional consulting engineering firm, particularly in the planning and preparation phase. The sizes of the Utility (Licensee) and DGC staffs arevaried in each period in accordance with the requirements of the work activities.

Details on thestaff levels, by functional group, during each period are provided in Section 6.0.4.4 Spent Fuel Management StaffThe largest spent fuel staff is in place while the fuel pool is operational during the spent fuelcooling period and the fuel assemblies are being transferred to dry storage.

After all spent fuelPage 21 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3has been removed from the spent fuel pool, the staff is reduced.

During spent fuel pooloperations and the dry storage period, the full-time spent fuel management staff is supplemented with part-time staff to support fuel movements.

Details on the staff levels, by functional group,during each period are provided in Section 6.0.4.5 Spent Fuel Shipments The spent fuel shipping schedules are based in part on the DOE's "Acceptance Priority Ranking& Annual Capacity Report,"

dated July 2004. (Ref. No. 12). The information regarding existingfuel inventory, planned transfers to dry storage and DOE's projected date of 2024 for acceptance of spent fuel is based on information provided by SCE. The spent fuel shipping schedule isprovided in Appendix B. The spent fuel shipment schedule is based upon best currentinformation and assumptions, as qualified and described elsewhere in this study, including inSection 2.2 above.Page 22 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 35.0 BASES OF ESTIMATE AND KEY ASSUMPTIONS The bases of, and key assumptions for, this site-specific decommissioning estimate are presented below:1. SCE's actual decommissioning expenses incurred from the time of permanent cessation of operations on June 7, 2013 until December 31, 2013 are included in the estimate.

All other decommissioning cost data used in this study is current as of 2014. Totals andsubtotals have been rounded to significant figures.2. EnergySolutions developed a prompt dismantlement (DECON) project schedule basedon a permanent shutdown date of June 7, 2013.3. The decommissioning will be performed using currently available technologies.

4. DOE currently has no plans, program, or schedule in place for acceptance of utilityspent fuel. However, for purposes of this decommissioning cost estimate, certainsimplifying assumptions must be made regarding the schedule and rate of DOEperformance.

Therefore, while DOE's Standard Contract governing the acceptance ofSCE's spent fuel allows for alternative removal schedules, including priority forshutdown reactors and exchanges of allocations, for purposes of this estimate DOEacceptance from the industry is assumed to commence in 2024 in accordance with SCEtestimony to the Public Utilities Commission of the State of California (Ref. No. 17).The spent fuel shipment schedules are based upon the assumption that the DOE willaccept spent fuel at the rate published in DOE's July 2004 Acceptance Priority Ranking& Annual Capacity Report (DOE/RW-0567)

(Ref. No. 12). Additionally, SCE isreviewing available information from DOE to determine if the DOE start dateassumption requires updating.

The DCE will be revised accordingly as new information becomes available.

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

The purposeof the GARDIAN system is to ensure all materials not intended for disposal at alicensed facility meet all applicable requirements.

.Page 23 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 38. The estimate is based on final site restoration, in which all existing and proposedstructures, with the exception of the switchyard, will be removed.

Clean demolition costs are based on the assumption that all site improvements will be removed in theirentirety.

Clean backfill will be imported and placed to re-establish grade. The entiredisturbed area of the site is to be graded, to restore the natural grade to the extentpossible, and seeded.9. Uncontaminated lead shielding remaining is assumed to be removed from its installed locations and shipped offsite by entities having a need for the material.

The entitiesreceive the lead at no charge in return for providing the removal and shipping services.

10. Site-specific information regarding contaminated soil was used as a basis forcalculation of current costs for their remediation.

While no known radiological orchemical remediation is required at the switchyard or the Mesa, those areas will beaddressed as part of the Baseline Characterization Survey and Historical SiteAssessment.

If the studies conclude that radiological or chemical remediation isrequired at the switchyard or the Mesa, the DCE will be amended.

For radiological contamination found at either the switchyard or the Mesa, the DCE will be amended toinclude all subsequent cost estimates for the remediation, which will be paid for by theSONGS participants in accordance with their cost allocations for the 'CommonFacilities'.

Chemical remediation of the switchyards will be paid by either SCE orSDG&E owners of the respective switchyards.

11. Costs for hazardous waste disposal, as well as asbestos and lead abatement, areincluded in this study.12. All Class A waste is assumed to be disposed of at EnergySolutions' facility in Clive,Utah, in accordance with the existing Life-of-Plant Disposal Agreement betweenEnergySolutions and Southern California Edison, dated January 18, 2014 (Ref. No. 7).The following 2014 disposal rates will be applied:Demolition Debris and Soil -$57.97/Cubic Foot plus 5% Utah taxesOversized Debris -$111.3 1/Cubic Foot plus 5% Utah taxesContainerized Waste Facility

-$214.50/Cubic Foot plus 12% Utah taxesLarge Components

-$289.87/Cubic Foot plus 5% Utah taxesCask Shipments

-$44,059/Cask plus 12% Utah taxesClass A waste includes Dry Active Waste (DAW) arising from the disposal ofcontaminated protective clothing and health physics supplies.

13. Class B, C, and GTCC waste disposal costs are based on recent quotes for disposal ofactivated hardware and resins at the WCS facility.

All resins and filter waste isassumed to be Class B.14. Shipping costs for the Class B and C waste are based on a distance of 1,079 miles oneway from SONGS to the WCS site.Page 24 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 315. GTCC is not subject to the same storage and security requirements as spent fuel andtherefore is not required to be stored on the ISFSI pad. But for purposes of thisestimate and to facilitate decommissioning, GTCC waste generated from thesegmentation of the reactor internals is assumed to be packaged in Dry ShieldedCanisters (DSCs) and placed in Advanced Horizontal Storage Modules (AHSMs) in theISFSI to await final disposition at a DOE repository.

16. It is assumed that a total of six DSCs per unit will be required for GTCC waste.17. Reactor vessel and internals curie estimates were derived from the values for theReference PWR vessel and internals in NUREG/CR-0130 (Ref. No. 5). These valueswere adjusted for decay period.18. The EnergySolutions site-specific classification of radioactive wastes for the SONGSPlant identified that the spent fuel assemblies and two components within the reactorvessel (the Core Shroud Assembly and the Lower Core Grid Plate) will exceed Class Climitations.
19. The spent fuel shipments are based upon best current information and assumptions, asqualified and described elsewhere in this study, including in Section 2.2. above.20. Spent fuel will remain in the spent fuel pool for six years before being transferred to theISFSI.21. The costs for ISFSI construction and transfer of spent fuel from Units 2 & 3 to drystorage were developed by SCE and furnished to EnergySolutions.

Following completion of spent fuel transfers to dry storage the cost of maintenance and operation of the ISFSI is distributed between Units 1, 2 and 3 based on the relative percentages ofspent fuel assemblies in storage.

The percentages are 10, 45, and 45 for Units 1, 2, and3, respectively.

The exception is that all property taxes are solely the liability of Units2 & 3. Following completion of SNF Pd 4 -Dry Storage Only Units 1, 2, and 3, allISFSI maintenance and operating costs are assigned to Units 2 & 3 until the ISFSID&D. During ISFSI D&D costs are distributed to all three units in the samepercentages of 10, 45, and 45.22. DOE has not committed to accept SCE's canistered spent fuel. But for purposes of thisestimate, it is assumed that an SCE-funded dry storage facility will not be necessary.

23. Costs for ISFSI demolition are included in this estimate.

SCE assumes that portions ofthe AHSM concrete will be activated.

24. EnergySolttions has assumed that the 10 CFR Part 50 license will be maintained untilDOE has taken possession of the spent fuel.25. SCE's annual ISFSI insurance premiums of $302,000 are assumed to be incurred untilall fuel shipments have been completed and the structure is no longer in use.Page 25 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 326. SCE's Emergency Preparedness (FEMA) fees of $500,000 per year and California Office of Emergency Services fees of $2,800,000 per year are applied until the spentfuel pool is empty. These fees were supplied by SCE.27. SCE's current annual property taxes are assumed to be reduced to a constant$1,500,000 per year. The property taxes are a license termination expense until thecompletion of decommissioning, and then a spent fuel management expense untilcompletion of the ISFSI D&D.28. EnergySolutions has included the annual NRC 10 CFR 171.15(c)(2) fees, for reactors indecommissioning of $231,000/yr per unit until decommissioning is completed as alicense termination expense.

Following completion of decommissioning, this expenseis continued as a spent fuel management cost for maintenance of the 10 CFR Part 50license.29. EnergySolutions has included Environmental Permits and Fees of $1,900,000 per yearas supplied by SCE.30. EnergySolutions has included NRC inspection fees during each decommissioning period based on the type and level of activities being performed.

31. SONGS annual insurance
premiums, in 2014 dollars as supplied by SCE, are asfollows:Nuclear Property Primary -$4,878,099 Nuclear Liability

-$1,151,075 Additional Liability, Non-Nuclear

-$3,576,519 Workers' Compensation

-$180,335Property Insurance

-$353,286The premium amounts have been adjusted by EnergySohltions in accordance withinformation furnished by SCE to meet the requirements of each period.32. Site operating expenses expected to be incurred during decommissioning and spent fuelmanagement 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 oninformation provided by SCE and adjusted by EnergySolutions to match therequirements of each period, based on staffing levels.33. Site Lease and Easement expenses of $2,300,000 per year until the Mesa lease isterminated are included in the estimate.

Following termination of the Mesa lease thesite lease and easement expenses are reduced to $299,920 per year. These costs arebased on information provided by SCE.34. Utility (Licensee) staff positions and average direct burdened salary (i.e. totalcompensation) data in 2014 dollars were supplied by SCE.Page 26 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 335. Severance costs for those employees terminated as a result of SONGSdecommissioning, including those costs required under California law are included inthe estimate.

Severance costs for Reductions-in-Force (RIFs) that occurredimmediately after shutdown, and during the course of spent fuel management anddecommissioning are assumed to be a site restoration expense and are included in theestimate.

36. Severance costs per employee were provided by SCE.37. DGC staff salaries, including overhead and profit, were determined by EnergySolutions and represent EnergySolutions' standard assumptions for these rates.38. The professional personnel used for the planning and preparation activities, and DGCpersonnel, are assumed to be paid per diem at the rate of $204/day, based on per diemrates from U.S. General Services Administration (GSA) for Orange County, California.
39. Craft labor rates were taken from the CA Union Craft Rate Sheet, dated January 9,2014. Craft labor rates for disciplines not provided in the rate sheet have been takenfrom the 2014 RS Means Labor Rates for the Construction Industry (Ref. No. 10), forAnaheim, CA. Since the skilled laborers are assumed to be supplied by the local unionhall, they will not be paid per diem.40. The security guard force included in this estimate has been sized in accordance with thecurrent Design Basis Threat assessment.
41. This study follows the occupational exposure principles of As Low As Reasonably Achievable (ALARA) through the use of productivity loss factors that incorporate suchitems as the use of respiratory protection and personnel protective clothing.

Thesefactors increase the work duration and cost.42. The costs of all required safety analyses and safety measures for the protection of thegeneral public, the environment, and decommissioning workers are included in the costestimates.

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 Waste10 CFR 71 Packaging of Radioactive Material for Transport 10 CFR 72 Licensing Requirements for the Independent Storage of SpentNuclear Fuel and High-Level Radioactive Waste29 CFR 1910 Occupational Safety and Health Standards Page 27 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 349 CFR 170-189 Department of Transportation Regulations Governing theTransport of Hazardous Materials Reg. Guide 1.159 Assuring the Availability of Funds for Decommissioning NuclearReactors43. Activity labor costs do not include any allowance for delays between activities, nor isthere any cost allowance for craft labor retained on site while waiting for work tobecome available.

Page 28 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 36.0 STUDY RESULTSThis study analyzes the following technical approach to decommissioning as defined by SCE:" Prompt DECON methodology.

" Permanent cessation of operations and commencement of decommissioning planning on June 7, 2013." Termination of spent fuel pool operation six years after permanent shutdown.

" Spent fuel will be stored in MPCs at an on-site ISFSI." A dry transfer facility will not be necessary for transfer of SNF for transport.

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

" LOP Disposal Rates are used for Class A LLRW." WCS Texas Disposal Rates are used for Class B and C LLRW." DOE begins accepting spent fuel from the industry in 2024.Spent Fuel Shipping ScheduleThe spent fuel shipping schedule is provided in Appendix B. Spent fuel shipments from theindustry to DOE will begin in 2024. The spent fuel shipment schedules are based upon bestcurrent information and assumptions, as qualified and described elsewhere in this study,including in Section 2.2 above.Cost and ScheduleFigure 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 LicenseTermination, Spent Fuel, and Site Restoration activities.

A detailed cost table is provided inAppendix D, and a table of annual expenditures is provided in Appendix E.Proiect StaffingThis scenario is based on the assumption that decommissioning will be performed by anexperienced and qualified DGC, with oversight and management of the decommissioning operations performed by the Licensee staff. Utility (Licensee) staffing levels, by organizational department and function, for each period are provided in Table 6-2. The DGC staffing levels, byorganizational department and function, for each period are provided in Table 6-3.Page 29 of 37 2014 Decommissioning Cost Analysis of theSan Onofre Nuclear Generating Station Units 2 & 3Document No. 164001-DCE-001 LLRW Disposal VolumesLLRW disposal is a significant element of the decommissioning project.

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

Page 30 of 37 2014 Decommissioning Cost Analysis of theSan Onofre Nuclear Generating Station Units 2 & 3Document No. 164001-DCE-001 Figure 6-1Summary ScheduleDECON with Dry Storage, 2013 Shutdown and DOE Acceptance in 2024Pdoat BENlzw ;anb -ov 9 F PI M ar e n W I O&l7/2013 iMIMFSpami Fuel Shl~pin Cormplw -Unit 1 1 lV1W'122 InSpent Fuel W4*pm CRO" et- Unks 2 & 3 1 !3t120491 12=2049*12IMW*1241tBSWl d 1- Speam Fuel Melugenwot Transiion 0517/2012i 112211201

-.- -- --t ~ 1/1/WiC -I/WI.SiUF Pd 2 -Spent Fual Transfer to Dry Storge1/'1,201U,"J01 tSNF Pd S- Dry Storage During Deomnisioning

-Units 1, 2 and 3 12/062061 SNF Pd 4 -Dry Storap Only -Unite 1, 2 md 2 0 1/2112025 SNF Pd 5- Dry StoraW Only- Units 2 and 3 12*1/025 3112049SNF DWD Pd 1. ISFSI D&D Plamning 1241/2 06611 12MW000-.1WwU&U '02- OIMBA"U&U Port 50 Licens Temnamtion I 6/7204 m26202AIMMg~MnOn Of LO6SME1 01 L5opeatSIt

.11 (Jn7,2013) 06WIMMl3l OGW/2013 W &IDeoon Pd 1.

to F*I WIII/ M "112013 upDecon Pd 2. Docounwnisioning Pl6an and Sie VModilice tione 1/trW0141 J-Decan Pd 3- Decommissoing Prepawtiona and Reacor Intenals Segm ntation 0 o1s 0et0m1 *Decon Pd 4 -Plant Spaema and Lare Component Removal n 0601/019 0M24/2022 Decon Pd 5- Building Deoc, minaon I 24',' 071121024

==WW=MWwowDecon Pd 6- ILoente Termniation urig Demolition 07/If2/U4 S ite R et ratio n 06 / 012 1 X M15/2 ---1-SR Pd I -Tra-,,-tion to Sie Restoration 06M..1I7

"

sR Pd 2- o D o 8lonlngl 0/120171SR Pd s- Subsaflsoe Demfolio Engiinering and P...*v 10101P019 0oMM2m4 pMMMWSA Pd 4-Demolition to 3 Feet Below Oracde 01202M SI 1141028 IilIISRq P:d a -Sub~tlo Sruetwe enmald Below .2q Feet 10/14* 12MM1S Pd 6 -Finl Sit Restoration and lea6 Termination 050&2060 12M/1601Final Easom Ti Torn**It6cn 2tI5-/2M 1 11211/2051 112/Page 31 of 37 2014 Decommissioning Cost Analysis of theDocument No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3Table 6-13Cost and Schedule Summary(2014 Dollars in Thousands)

License Termination (50.75(c))

DeconPd 1Transition toDeconP Decommissioning 6/7/2013 12/31/2013 0.56 $25,749 $26,566 $52,315Decon Pd 2 Decommissioning Planning 1/1/2014 6/30/2015 1.49 $118,709

$122,430

$241,140and Site Modifications Decommissioning Decon Pd 3 Preparations and Reactor 6/30/2015 6/1/2019 3.92 $262,210

$276,799

$539,009Internals Segmentation Decon Pd 4 Plant Systems and Large 6/1/2019 9/24/2022 3.31 $392,029

$412,475

$804,504Component RemovalDecon Pd 5 Building Decontamination 9/24/2022 7/13/2024 1.80 $212,447

$216,659

$429,106Decon Pd 6 License Termination During 7/13/2024 12/24/2032 8.44 $23,085 $23,085 $46,171Demolition Account Total 19.52 $1,034,230

$1,078,016

$2,112,246 Spent Fuel (50.54(bb))

and (72.30)SNF Pd 1 Spent Fuel Management SNF Pd 1 Transition 6/7/2013 12/31/2013 0.56 $63,891 $66,105 $129,997SNF Pd 2 TSpnstiFelTrnsfrtr SNFPd2 Spent Fuel Transfer to Dry 1/1/2014 6/1/2019 5.41 $344,629

$372,193

$716,822StorageDry Storage DuringSNF Pd 3 Decommissioning

-Units 1, 2 6/1/2019 12/5/2031 12.51 $61,425 $61,425 $122,849and 3SM~ Pd 4 Dry Storage Only -Units 1, 2SNFPd4 and 3 12/5/2031 12/31/2035 4.07 $29,383 $29,383 $58,765SNPd Dry Storage Only -Units 2 12/31/2035 12/31/2049 14.00 $107,326

$107,326

$214,653and 3SNF D&D ISFSI License Termination 12/31/2049 5/6/2050 0.34 $1,260 $1,260 $2,520Pd ISNF D&D ISFSI Demolition 5/6/2050 9/8/2051 1.34 $15,295 $15,295 $30,590Pd 2Account Total 38.23 $623,209

$652,987

$1,276,196 Site Restoration SR Pd 1 Transition to Site Restoration 6/7/2013 6/30/2015 2.06 $64,280 $66,210 $130,489SR Pd 2 Building Demolition During 6/30/2015 7/11/2017 2.03 $13,003 $37,242 $50,245Decommissioning SR Pd 3 Subsurface Demolition Engineering and Permitting 10/1/2019 7/13/2024 4.78 $15,593 $22,319 $37,912SR Pd 4 Building Demolition to 3 Feet 7/13/2024 10/14/2028 4.25 $124,953

$134,113

$259,066Below GradeSRPd5 Subgrade Structure Removal 10/14/2028 12/5/2031 3.14 $171,987

$269,560

$441,547Below -3 FeetSR Pd 6 Final Site Restoration and 5/6/2050 12/15/2051 1.60 $33,482 $70,064 $103,545Lease Termination Account Total 17.86 $423,297

$599,507

$1,022,804 Grand Total $2,080,735

$2,330,511

$4,411,246 3 Rows and columns may not add correctly due to rounding.

Page 32 of 37 2014 Decommissioning Cost Analysis of theSan Onofre Nuclear Generating Station Units 2 & 3Document No. 164001-DCE-001 Table 6-2Utility Staff LevelsDecommissioning Engineering Maintenance and Work ControlOperations Oversight and Nuclear SafetyRadiation Protection and Chemistry Regulatory and Emergency PlanningSafety and Human Performance Security AdminSecurity Guard ForceSite Management and Administration 0 21 21 2) 18 U0 49 14 14 12 00 38 10 10 3 00 15 7 7 0 00 7 2 2 1 00 27 26 31 26 00 10 4 4 4 0.50 13 7 7 7 00 6 6 6 6 00 12 12 12 12 00 13 13 13 9 1Period Totals 0 211 122 131 98 1.5S ent Fuel -50.54(bb Utili StaffSpent Fuel Shipping 0 0 0 2 2 0 0Decommissioning 0 0 0 0 0 1 1Engineering 0 1 1 1 1 0 1Maintenance and Work Control 0 31 0 0 0 0 0Operations 0 45 1 1 1 0 0Oversight and Nuclear Safety 0 1 0.25 0.25 0.25 0 0Radiation Protection and Chemistry 0 6 4 4 4 1 2Regulatory and Emergency Planning 0 0 0 0 0 1 1Security Admin 0 14 10 8 8 1 1Security Guard Force 0 178 35 35 35 5 5Site Management and Administration 0 0 0 0 0 1 1Period Total 0 276 51.25 54.25 54.25 10 12Site Restoration

-Utilit StaffDecommissioning 0 2 0 5 4 2Engineering 0 1 0 2 1 0Maintenance and Work Control 0 1 0 2 2 2Regulatory and Emergency Planning 0 1 0 0 0 0Safety and Human Performance 0 1 0 2 1 1Security Admin 0 0 0 1 1 0Security Guard Force 0 0 0 5 5 0Site Management and Administration 0 0 0 4 3 3Period Totals 0 6 0 21 17 8Page 33 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3Table 6-3DGC Staff LevelsLicense Termination

-50.75(c)

DGC StaffAdministration 9 17 17 0Engineering 15 29 14 0Health Physics 16 73 73 2Management 3 3 3 0Quality Assurance 2 5 4 0Waste Operations 7 16 16 0Period Totals 52 143 127 2Scent Fuel -50.54tbbl

-DGC StaffAdministration IEngineering 2Health Physics 3Management IQuality Assurance 1Waste Operations 4Period Totals 12Site Restoration DGC StaffAdministration 0 0 0 10 5 4Engineering 0 0 0 13 11 5Health Physics 0 0 0 3 0 0Management 0 0 0 2 2 1Quality Assurance 0 0 0 2 1 0Waste Operations 0 0 0 11 7 7Period Totals 0 0 0 41 26 17Page 34 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 & 3Table 6-4Waste Disposal Volumes(Cost Excludes Contingency

-2014 Dollars)Class B and C FacilityClass B 1,132,323 6,696 15,199 $1,199,186

$6,433,599

$72,635,570

$80,268,355 Class C 407,380 1,546 8,191 $2,064,309

$26,706,007

$39,142,870

$67,913,186 GTCC 92,861 190 1,882 $196,288

$1,680,000

$38,775,980

$40,652,268 1,632,564 8,431 25,272 $3,459,782

$34,819,606

$150,554,420

$188,833,808 EnergySolutions Class A -Debris 200,560,122 3,229,506 3,308,050

$3,804,262

$13,779,286

$211,423,909

$229,007,458 Class A -Oversize 9,967,521 146,943 184,730 $187,314

$784,285

$22,669,947

$23,641,545 Class A -Containerized Waste 1,053,914 12,287 16,303 $397,152

$364,322

$4,112,378

$4,873,851 Class A -Large Component 11,480,200 108,866 136,373 $6,313,568

$69,622,664

$43,582,464

$119,518,696 Class A- Mixed Waste 62,643 3,012 3,012 $67,887 $12,448 $801,226

$881,561223,124,400 3,500,614 3,648,469

$10,770,182

$84,563,005

$282,589,924

$377,923,111 OtherOut of State Class III Landfill 1,909,207,440 25,212,269 29,372,422

$0 $146,326,469

$43,929,750

$190,256,219 Scrap Metal Recycler 184,787,372 377,117 7,391,495

$0 $911,926

$0 $911,9262,093,994,812 25,589,386 36,763,917

$0 $147,238,394

$43,929,750

$191,168,144 Grand Total 2,318,751,776 29,098,431 40,437,658

$14,229,964

$266,621,006

$477,074,094

$757,925,064 Page 35 of 37 2014 Decommissioning Cost Analysis of the Document No. 164001-DCE-001 San Onofre Nuclear Generating Station Units 2 &

37.0 REFERENCES

1. U.S. Nuclear Regulatory Commission, "Domestic Licensing of Production andUtilization Facilities,"

10 CFR Part 50, 2008, Available fromhMp://www.nrc.gov/reading-rmndoc-collections/cfr/part050/full-text.html.

2. Atomic Industrial Forum, Inc., "Guidelines for Producing Commercial Nuclear PowerPlant Decommissioning Cost Estimates,"

AIF/NESP-036, May 1986.3. U.S. Nuclear Regulatory Commission, "Standard Format and Content ofDecommissioning Cost Estimates for Nuclear Power Reactors,"

Regulatory Guide 1.202,February 2005.4. Federal Register, Vol. 4, "Standard Contract for Disposal of Spent Nuclear Fuel and/orHigh-Level Radioactive Waste," NRC 10 CFR Part 961 (DOE), January 1, 1999.5. U.S. Nuclear Regulatory Commission, "Technology, Safety and Costs ofDecommissioning a Reference Pressurized Water Reactor Power Station,"

NUREG/CR-0130, June 1978.6. U.S. Nuclear Regulatory Commission, "Technology, Safety and Costs ofDecommissioning a Reference Boiling Water Reactor Power Station,"

NUREG/CR-0672, June 1980.7. Life-of-Plant Disposal Agreement, between EnergySolutions, LLC and SCE effective January 1 st, 2014.8. U.S. Nuclear Regulatory Commission, "Multi-Agency Radiation Survey and SiteInvestigation Manual (MARSSIM),"

NUREG-1575, Rev. 1, August 2000.9. U.S. Department of Energy, "Cost Estimating Guide," DOE G 430.1-1, March 1997.10. RS Means, "Labor Rates for the Construction Industry,"

2014.11. ABZ, Incorporated, "San Onofre Nuclear Generating Station Units 2 and 3 (SONGS2/3)", December 14,201212. U.S. Department of Energy, "Acceptance Priority Ranking & Annual Capacity Report,"DOE/RW-0567, July 2004.13. Pacific Gas & Electric, "Establishing an Appropriate Contingency Factor for Inclusion inthe Decommissioning Revenue Requirements",

April 200914. Department of the Navy, "Grant of Easement,"

May 1964.15. State of California State Lands Commission, "Lease P.R.C. No. 4862.1",

datedNovember 19, 1984Page 36 of 37 2014 Decommissioning Cost Analysis of theSan Onofre Nuclear Generating Station Units 2 & 3Document No. 164001-DCE-001

16. State of California, Executive Order D-62-02, September 200217. Southern California Edison, "Testimony On the Nuclear Decommissioning Of SONGS 2& 3 And Palo Verde Before the Public Utilities Commission of the State of California,"

December 21, 2012.Page 37 of 37 2014 Decommissioning Cost Analysis of theSan Onofre Nuclear Generating Station Units 2 & 3Document No. 164001-DCE-001 Appendix AList of Systems and Structures SONGS Plant System and Structure ListCommonTypeNonStructStructStructStructStructStructStructStructStructStructStructStructStructStructStructStructStructStructStructStructEssEssEssNonNonNonNonNonNonNonNonStructStructStructStructStructStructStructStructStructStructStructStructEssEssSystem Name or Description Not UsedAdministration Building (K-40/50)

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

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

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

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

Mesa Buildings Not UsedOutage Control Center BuildingREMS Staging PadSeawall -Units 2 & 3Security Access Building (A-80, 81, 82)Service Building (K-10, 20, 30)South Security Processing Facility (K-70)South Yard Facility Buildings (T-10, 20, 60 and Haz Mat.)Staging Warehouse BuildingAuxilary Control Systems -Unit 2Fuel Handling Building Systems -Unit 2Radwaste Systems -Unit 2Condenstate Storage Systems -Unit 2Containment Building Systems -Unit 2Diesel Generator Systems -Unit 2Full Flow Areas Systems -Unit 2Intake Systems -Unit 2Penetration Building Systems -Unit 2Safety Equipment Building Systems -Unit 2Turbine Bldg Equip to 9 ft -Unit 2Condensate Storage Area -Unit 2Containment Building

-Unit 2Control Building

-Unit 2Diesel Generator Building

-Unit 2Fuel Handling Building

-Unit 2Full Flow Building

-Unit 2Intake Structure

-Unit 2Penetration Building

-Unit 2Radwaste Building

-Unit 2Safety Equipment Building

-Unit 2Tunnels -Unit 2Turbine Building

-Unit 2Auxilary Control Systems -Unit 3Fuel Handling Building Systems -Unit 3Page 1 of 2 SONGS Plant System and Structure ListUnit 3Type System Name or Description Ess Radwaste Systems -Unit 3Non Condenstate Storage Systems -Unit 3Non Containment Building Systems -Unit 3Non Diesel Generator Systems -Unit 3Non Full Flow Areas Systems -Unit 3Non Intake Systems -Unit 3Non Penetration Building Systems -Unit 3Non Safety Equipment Building Systems -Unit 3Non Turbine Bldg Equip to 9 ft -Unit 3Non Turbine Generator to 63 ft -Unit 3Struct Condensate Storage Tank Area -Unit 3Struct Containment Building

-Unit 3Struct Control Building

-Unit 3Struct Diesel Generator Building

-Unit 3Struct Fuel Handling Building

-Unit 3Struct Full Flow Building

-Unit 3Struct Intake Structure

-Unit 3Struct Penetration Building

-Unit 3Struct Radwaste Building

-Unit 3Struct Safety Equipment Building

-Unit 3Struct Tunnels -Unit 3Struct Turbine Building

-Unit 3Page 2 of 2 2014 Decommissioning Cost Analysis of theSan Onofre Nuclear Generating Station Units 2 & 3Document No. 164001-DCE-001 Appendix BSpent Fuel Shipping Schedule SONGS Unit 2 & Unit 3Spent Fuel Shipping Schedule2024 DOE Acceptance 2016 2668 792 34602015 2668 792 3460 33 0 0 0 0 0 02016 2668 792 3460 33 0 0 0 0 0 02017 2668 792 3460 33 768 24 0 0 0 02018 1900 1560 3460 57 1,536 48 0 0 0 02019 364 3096 3460 105 364 13 0 0 0 02020 0 3460 3460 118 0 0 0 0 0 02021 0 3460 3460 118 0 0 0 0 0 02022 0 3460 3460 118 0 0 0 0 0 02023 0 3460 3460 118 0 0 0 0 0 02024 0 3460 3460 118 0 0 0 0 0 02025 0 3460 3460 118 0 0 0 0 0 02026 0 3460 3460 118 0 0 0 0 0 02027 0 3460 3460 118 0 0 0 0 0 02028 0 3460 3460 118 0 0 0 0 0 02029 0 3460 3460 118 0 0 0 0 0 02030 0 3460 3460 118 0 0 48 48 96 42031 0 3364 3364 114 0 0 192 96 288 122032 0 3076 3076 102 0 0 120 120 240 102033 0 2836 2836 92 0 0 0 96 96 42034 0 2740 2740 88 0 0 112 120 232 82035 0 2508 2508 80 0 0 96 96 192 62036 0 2316 2316 74 0 0 128 96 224 72037 0 2092 2092 67 0 0 0 0 0 02038 0 2092 2092 67 0 0 96 128 224 72039 0 1868 1868 60 0 0 96 96 192 62040 0 1676 1676 54 0 0 96 96 192 62041 0 1484 1484 48 0 0 0 0 0 02042 0 1484 1484 48 0 0 96 96 192 62043 0 1292 1292 42 0 0 96 96 192 62044 0 1100 1100 36 0 0 96 96 192 62045 0 908 908 30 0 0 128 96 224 72046 0 684 684 23 0 0 96 128 224 72047 0 460 460 16 0 0 96 230 326 II2048 0 134 134 5 0 0 0 0 0 02049 0 134 134 5 0 0 134 0 134 52050 0 0 0 0 0 0 0 0 0 0 2014 Decommissioning Cost Analysis of theSan Onofre Nuclear Generating Station Units 2 & 3Document No. 164001-DCE-001 Appendix CDetailed Project Schedule SONGS 2 & 3Detailed Project SchedulePrompt DECON, DOE Repository Opens 2024ID Task Name Duration start1 Post-Shutdown Spent Fuel Management 9982 days 06107/20131 2 Spent Fuel Shipping Complete

-Unit 1 0 days 12131/203 2 3 4 5 6 7 8 910111213 41516171819 0 1 2 3 4 5 7 8 9 1 7 9 1V3Spent fuel :Shipping Complete

-Units 2 & 30 days12/31/2049 12131/2049 4 SNF Pd I -Spent Fuel Management Transition 149 days 0610712013 12/3112013w 5 SNF Pd 1 Begins 0 days 06/07/2013 06/07/20i-13 6 Security Enhancements 45 days 10/31/2013 12/31/2013 7 Design and Fabricate Spent Fuel Canisters 120 days 06/07/2013 11/21/2013 8 Post Fukushima Modifications

-Unit 2 148 days 06/07/2013 12/31/2013 9 Post Fukushima Modifications

-Unit 3 148 days 06/07/2013 12/31/2013 10 Cyber Security Modifications 148 daysl 06/07/2013 12/31/2013 1111SNF Pd 1 Ends0 days01/01/2014 01/01/2014

'Ah-tonr ru ~- op.n. rue. iranarur rr1 U)' inuring.

i0 ainysvSNFPdr 2u -Spent Fum Transfer to Dry Storagegayl11 -e I..13 SNF Pd 2 Begins 0 days 01/01/2014 01/01/2014 14 Security Enhancements 60 days 01/0212014 03/2612014 15 Prepare Irradiated Fuel Management Plan 118 days 01/0212014 0611412014 16 Decay Heat Analysis 85 days 01/02/2014 04/30/2014 17 Zirconium Fire and Shine Analysis 42 days 01/02/2014 0212812014 18 Issue Irradiated Fuel Management Plan 0 days 09/16/2014 0911612014

.J~1119NRC Review of Irradiated Fuel Management Plan82 days09/17/2014 01/08/2015 20ISFSI Expansion 513 days01/02/2014 21 Select Dry Storage System Canister Design and Vendor 30 days22 ISFSI Pad Study 220 days12119/2015 02/12/2014 12/06/2014 Design IiSI-St xpansion120 days06/24/2014 12/0612014 24 ISFSI Permit Approved By California Coastal Commission 0 days 04/1112015 04/11/2015 25 Construct ISFSI Expansion 180 days 04114/2015 12/19/2015 26 Canister

Purchase, Fabrication and Fuel Tranfer 1170 days 12/0912014 06/0112019 27 Purchase Spent Fuel Canisters and AHSMs -Unit 2 220 days 12/09/2014 1011201528 Purchase Spent Fuel Canisters and AHSMs -Unit 3 220 days 12/09/2014 10/10/2015 29 Load Spent Fuel Canisters and Transfer to ISFSI -Unit 2 900 days 12/22/2015 06/01/2019 30 Load Spent Fuel Canisters and Transfer to ISFSI -Unit 3 900 days 12/22/2015 06/01/2019 31 Unit 2 Spent Fuel Pool Empty 0 days 06/01/2019 06/01/2019 32 Unit 3 Spent Fuel Pool Empty 0 days 06/01/2019 06/01/2019 33 SNF Pd 2 Ends 0 days 06/01/2019 06/01/2019 34 SNF Pd 3 -Dry Storage During Decommissioning

-Units 1, 2 and 3 3265 days 06/01/2019 12/05/2031 35 SNF Pd 3 Begins 0 days 06/01/2019 06/01/2019 36 SNF Pd 3 Ends 0 days 12/0512031 12/05/2031 37 SNF Pd 4 -Dry Storage Only -Units 1, 2 and 3 1061 days 12/05/2031 12/31/2035 38 SNF Pd 4 Begins 0 days 12/05/2031 12/05/2031 39 SNF Pd 4 Ends 0 days 12/31/2035 12/31/2035 40 SNF Pd 5 -Dry Storage Only -Units 2 and 3 3654 days 1213112035 12/31/2049 41 SNF Pd 5 Begins 0 days 12/31/2035 12/31/2035 42 SNF Pd 5 Ends 0 days 12/31/2049 12/31/2049 43 SNF D&D Pd I -ISFSI D&D Planning 90 days 12/31/2049 05/04/2050 44 SNF D&D Pd 1 Begins 0 days 12/31/2049 12/31/2049 45 Preparation and NRC Review of License Termination Plan 90 days 01/01/2050 05/06/2050 46 SNF D&D Pd 1 Ends 0 days 05/06/2050 05/06/2050 U41k112/31 12/3112/3112/3112/3112/31Ft;UP612147SNF D&D Pd 2 -ISFSI O&D350 days05/06/2050 09108/2051 SONGS 2 & 3Detailed Project SchedulePrompt DECON, DOE Repository Opens 2024ID rI5i(Name I& Duration~BY~

1121314 15 61718 191o0111I121t3114115lt6117118119120121122J231241251261271281291301311321333451361371839140114 49Install GARDIAN Bulk Assay System30 days05/07/20501 06117/2050 50 Decon AHSMs 90 days 05/0712050 09/0912050 51 Final Status Survey of ISFSI 120 days 05/28/2050 11/11/2050 52 Clean Demolition of ISFSI AHSMs and Pad 145 days 09/10/2050 03/31/2051 53 Clean Demolition of ISFSI Support Structures 120 days 10115/2050 03/31/2051 54 Restore ISFSI Site 55 days 04/01/2051 06/16/2051 55 Preparation of Final Report on Decommissioning and NRC Review 60 days 06/17/2051 09/08/2051 56 SNF D&D Pd 2 Ends -License Termination Complete 0 days 09108/20511 09/08/2051 57Post-Shutdown Spent Fuel Management Complete0 days 1 09108/2051 09/08/2051

-J 4 ---4 ~ 458Part 0 License Termination 5102 days06/07/2013 12/24/2032 M'0'-459 Announcement of Cessation of Operations (June 7, 2013) 0 days60 Decon Pd 1 -Transition to Decommissioning 149 days1"'Decon Pd 1 tBegins0 days06/0712013 06/07/2013 w&-An,62 Certification of Permanent Cessation Submitted to NRC (June 12, 2013) 0 days 06/0712013 06/0712013 63 Defuel Unit 3 Reactor 15 days 06/0712013 06/2712013 64 Defuel Unit 2 Reactor 15 days 06/07/2013 06/27/2013 65 Notification of Permanent Fuel Removal (July 23, 2013) 0 days 06/27/2013 06/2712013 6/2766 Disposition of Legacy Wastes 60 days 07/19/2013 10/1012013 67 Decon Pd 1 Ends 0 days 01/01/2014 01/0112014 1168 Decon Pd 2 -Decommissioning Planning and Site Modifications 389 days 111/2014 06/30/2015 69 Decon Pd 2 Begins 0 wks 01/01/2014 01/0112014 11170 Preparation of Decommissioning License Documents 340 days 01/02/2014 04/22/2015 71 Develop Certified Fuel Handler Program 340 days 01/02/2014 04/22/2015 72 Prepare Post-Shutdown QA Plan 340 days 01/02/2014 04/22/2015 73 Prepare Post-Shutdown Security Plan 340 days 01/02/2014 04122/2015 74 Prepare Post-Shutdown Fire Protection Plan 340 days 01/02/2014 04/22/2015 75 Prepare Defueled Radiation Protection Manual 340 days 0110212014 04/22/2015 76 Prepare Preliminary Defueled Technical Specifications 63 days 01/02/2014 03/29/2014 77 NRC Deliverables 364 days 01/02/2014 05/26/2015 78 Prepare Defueled Safety Analysis Report (OSAR) 311 days 01/0212014 03/1212015 79 Submit DSAR to NRC 0 days 03/12/2015 03/12/2015 80 Implement Technical Specification Modifications 30 days 03/1312015 04/2312015 81 Prepare Post-Shutdown Emergency Preparedness Plan 304 days 01/02/2014 03/03/2015 82 Submit Emergency Plan to NRC 0 days 03/03/2015 03/0312015 83 NRC Review of Emergency Plan 60 days 03/04/2015 05/2612015 84 Prepare Post-Shutdown Decommissioning Activities Report (PSDAR) 121 days 01/02/2014 06/19/2014 85 Submit PSDAR to NRC 0 days 06/19/2014 06/19/2014 86 NRC Review of PSDAR 90 days 06120/2014 10/23/2014 87 Public Meeting on PSDAR 30 days 08/01/2014 09/11/2014 88 Prepare Decommissioning Cost Estimate (DCE) 160 days 01/02/2014 08/13/2014 89 Submit DCE to NRC 0 days 06/13/2014 08/1312014 90 NRC Review of Decommissioning Cost Estimate 90 days 08/14/2014 12/17/2014 91 Commencement of Major Decommisisoning Activities Allowable 0 days 10123/2014 10/23/2014 92 Respond to NRC quesitons on PSDAR 220 days 06/20/2014 04/23/2015 93 Disposition of Legacy Wastes 220 days 01/02/2014 11/0512014 94 Contract Award for Historic Site Assessment and Site Characterization 0 wks 01/1612014 01/16/2014 1113/1219130/236 SONGS 2 & 3Detailed Project SchedulePrompt DECON, DOE Repository Opens 2024ID ITask Name DurationI Start I Finish 1112 31415 1 617 1 191101111121t3114115116117118119120121122123124l25t26127128129130131132 3334135136137138139 95Perform Historic Site Assessment and Site Characterization 180 days01/17/2014 09/25/2014 96 Planning and Design For Cold and Dark 90 days 02101/2014 06/06/2014 97 Implement Cold and Dark (Repower Site) 275 days 06107/2014 06/26/2015 98 Install 12kV Service Line to Power Temporary Power Ring 90 days 02/21/2015 06/2612015 99 Drain and De-Energize Non-Essential Systems (DEC Process) 260 days 01/02/2014 12/3112014 100 Select Decommissioning General Contractor (DGC) 318 days 04/1112014 06/30/2015 101 Spent Fuel Pool Isolation 318 days 04/1112014 06/3012015 102 Design Spent Fuel Pool Support System Modifications 160 days 04/11/2014 11/20/2014 103 Design Control Room Relocation 125 days 04/1112014 10/02/2014 104 Design Spent Fuel Security System Modifications 130 days 04/111/2014 10/09/2014 105 Install Spent Fuel Pool System Modifications

-Unit 2 66 days 11/21/2014 02/20/2015 106 Install Spent Fuel Pool System Modifications

-Unit 3 66 days 02/21/2015 05/23/2015 107 Spent Fuel Pool Island System Training 10 days 05126/2015 06/0612015 108 Implement Control Room Modifications 185 days 10/03/2014 06/18/2015 109 Implement Spent Fuel Pool Security Modifications 180 days 10/10/2014 06/1812015 110 Transition Project Modifictations 262 days 06/28/2014 06/30/2015 111 DGC Contract Award 0 days 06/30/2015 06/30/2015 112 Decon Pd 2 Ends 0 wks 06/30/2015 06/30/2015 113 Decon Pd 3 -Decommissioning Preparations and Reactor Internals Segments 1024 days 06/3W2015 0610112019 114 Decon Pd 3 Begins 0 days 06/3012015 06/30/2015 115 DGC Mobilization and Planning 160 days 0710112015 02/09/2016 116 Prepare Integrated Work Sequence and Schedule for Decommissioning 90 days 07/01/2015 11/0312015 117 Prepare Detailed Work Procedures for Decommissioning 160 days 07/01/2015 02/09/2016 118 Planning and Design of Primary System Decontamination 135 days 07/01/2015 01/05/2016 119 Planning and Design of Infrastructure Improvements 60 days 07/0112015 09/22/2015 120 Design Containment Access Modifications 60 days 07/01/2015 09/22/2015 121 System Decon 400 days 01/0612016 07118/2017 122 Perform Primary System Decon- Unit 2 140 days 01/0612016 07/19/2016 123 Perform Primary System Decon- Unit 3 140 days 07/20/2016 01/31/2017 124 Hot Spot Decontamination

-Unit 2 60 days 02/01/2017 04/25/2017 125 Hot Spot Decontamination

-Unit 3 60 days 0412612017 07/18/2017 126 Rx Internals Removal Preparations 255 days 09123/2015 09113/2016 127 Modify Containment Access- Unit 2 90 days 09/2312015 01/26/2016 128 Modify Containment Access- Unit 3 90 days 01/27/2016 05/31/2016 129 Remove and Dispose of Missle Shields -Unit 2 30 days 01/27/2016 03/08/2016 130 Remove and Dispose of Reactor Head -Unit 2 45 days 03/0912016 05/10/2016 131 Remove and Dispose of Missle Shields -Unit 3 30 days 06/01/2016 07/12/2016 132 Remove and Dispose of Reactor Head -Unit 3 45 days 07/13/2016 09/13/2016 133 Reactor Internals Segmentation Planning and Implementation 1020 days 07/01/2015 0S/28/2019 134 Finalize Residual Radiation Inventory (Rx Vessel & Internals) 65 days 07/01/2015 09/29/2015 135 Prepare Activity Specification for Rx Vessel and Internals Segmentation 120 days 09/30/2015 03/15/2016 136 Select Shipping Casks and Obtain Shipping Permits 60 days 03/16/2016 06/07/2016 137 Design, Specify, and Procure Special Items and Materials 175 days 03/16/2016 11115=2016 138 Purchase Dry Storage Modules for GTCC Waste -Unit 2 90 days 07/01/2015 11/03/2015 II6/3000139Purchase Dry Storage Modules for GTCC Waste -Unit 390 days 1 07/01/2015 11103/2015 I---.......

r .-~. r -~1--~w~-l ou osys -i 1,ioiLu]o FI I I140Test Special Cutting and Handling Equipment and I rain uperators 60u days11I/16/2016I 02/07/2017 iiI1rinauze mnremais ana yasser oegmenung uerass -Unix I 31.) uays141Finalize Internals and Vessel Segmenting Details -Unit 2,30udays-IU-11IIvUI1 SONGS 2 & 3Detailed Project SchedulePrompt DECON, DOE Repository Opens 2024ID Task Name [.Duration Start Finish [112131415 142Segment, Package and Ulspose or Reactor Internals

-Unit 224u daysU,03Zzuu I/U02L0/2U18 L143 Transfer Internals Segmentation Equipment to Unit 3 60 days 02/21/2018 05/15/2018 144 Finalize Internals and Vessel Segmenting Details -Unit 3 30 days 05/16/2018 06/26/2018 145 Segment, Package and Dispose of Reactor Internals

-Unit 3 240 days 06/27/2018 05/28/2019 146 Construct new change rooms, hot laundry, in-plant laydown areas 90 days 01/29/2019 06/01/2019 147 Procure Non-Engineered Standard Equipment 120 days 12/18/2018 06/01/2019 148 Decon Pd 3 Ends 0 wks 06/01/2019 06101/2019 149 Decon Pd 4 -Plant Systems and Large Component Removal 865 days 06/01/2019 09124/2022 150 Decon Pd 4 Begins 0 days 06/01/2019 06/01/2019 151 Upgrade Rail Spur 120 days 06/04/2019 11/16/2019 152 Install GARDIAN Bulk Assay System 30 days 06/04/2019 07/13/2019 153 Non Essential System Removal 640 days 07/16/2019 12/25/2021 154 Scaffolding for Non-Essential System Removal 120 wks 07/16/2019 10/30/2021 155 Asbestos Abatement for Non-Essential Systems Removal -Unit 2 60 wks 07/16/2019 09/05/2020 156 Lead Abatement for Non-Essential Systems Removal -Unit 2 60 wks 07/30/2019 09/19/2020 157 Remove, Package and Dispose of Non-Essential Systems -Unit 2 60 wks 09/10/2019 10/31/2020 158 Asbestos Abatement for Non-Essential Systems -Unit 3 60 wks 09/08/2020 10/30/2021 159 Lead Abatement for Non-Essential Systems -Unit 3 60 wks 09/22/2020 11/13/2021 160 Remove, Package and Dispose of Non-Essential Systems -Unit 3 60 wks 11/03/2020 12/25/2021 161 Remove Underground Diesel Tank -Unit 2 30 days 07/16/2019 08/24/2019 162 Remove Underground Diesel Tank -Unit 3 30 days 08/27/2019 10/05/2019 163 Fuel Pool Closure 300 days 06/0412019 07126/2020 164 Remove and Dispose of Spent Fuel Storage Racks -Unit 2 90 days 06/04/2019 10/05/2019 165 Remove and Dispose of Spent Fuel Storage Racks -Unit 3 90 days 10/08/2019 02/08/2020 166 Remove and Dispose of Legacy Class B and C Waste -Unit 2 30 days 10/08/2019 11/16/2019 167 Remove and Dispose of Legacy Class B and C Waste -Unit 3 30 days 11/19/2019 12t28/2019 168 Drain Spent Fuel Pool and Process Liquid Waste -Unit 2 24 wks 11119/2019 05/02/20201 169 Drain Spent Fuel Pool and Process Liquid Waste -Unit 3 24 wks 12/31/2019 06/13/2020 170 Segment, Package and Dispose of Spent Fuel Pool Island Equipment 30 days 06/16/2020 07/25/2020 171 Segment and Dispose of Fuel Pool Bridge Crane -Unit 2 30 days 10/08/2019 11/16/2019 172 Segment and Dispose of Fuel Pool Bridge Crane -Unit 3 30 days 11/19/2019 12/28/2019 173 Essential Systems Removal 180 days 00/16/2020 02/20/2021 174 Flush and Drain Essential Systems Following Fuel Pool Closure 30 days 06116/2020 07/25/2020 175 Scaffolding for Essential System Removal 30 wks 07/28/2020 02/20/2021 176 Asbestos Abatement for Essential Systems 30 wks 07/28/2020 02/20/2021 177 Lead Abatement for Essential Systems Removal 30 wks 07/28/2020 02/20/2021 178 Remove, Package and Dispose of Essential Systems 30 wks 07/28/2020 02/20/2021 179 Removal and Disposal of Spent Resins, Filter Media and Tank Sludge 30 days 01/12/2021 02/20/2021 180 Large Component Removal 865 days 06/04/2019 09/24/2022 181 Reactor Vessel Insulation Removal and Disposal

-Unit 2 90 days 06/04/2019 10/05/2019 182 Segment, Package and Dispose of Reactor Pressure Vessel -Unit 2 260 days 06/04/2019 05/30/2020 183 Transfer Rx Vessel Segmentation Equipment to Unit 3 45 days 06/02/2020 08/01/2020 184 Procure Replacement Non-Engineered Standard Equipment 30 days 06/02/2020 07/11/2020 185 Reactor Vessel Insulation Removal and Disposal

-Unit 3 90 days 08/04/2020 12/0&/2020 186 Segment, Package and Dispose of Reactor Pressure Vessel -Unit 3 260 days 08/04/2020 07/31/2021 187 Remove and Dispose of Steam Generators

-Unit 2 240 days 06/02/20201 05/01/2021 6 7 8 9 01oil6/111121314115116117118119b'0121122123124t2527128129130131132133134135136 7138139 5 1II00emve andl Dispose of Pressurizer

-Unit 260 days 1 05/4/Z2021 07/24r2021 SONGS 2 & 3Detailed Project SchedulePrompt DECON, DOE Repository Opens 2024iD !Task Name Duration Start Finish 11121:14151617181 SITi I1,[1213114115116117118119120121 22123t1245126l271281291013132133134b35131 Ih3 7319t041189Remove ana uDspose of Steam tienerators

-Unit 324U days U1u0/03/22I U11 U07/02r,190 Remove and Dispose of Pressurizer

-Unit 3 60 days 07/05/2022 09/24/2022 191 Remove and Dispose of Turbine Gantry Crane -Unit 2 140 days 05/04/2021 11/13/2021 192 Remove and Dispose of Turbine Gantry Crane -Unit 3 140 days 11/16/2021 05/28/2022 193 Prepare License Termination Plan 26 wks 03101/2022 08/27/2022 194 Decon Pd 4 Ends 0 days 09/24/2022 09/24/2022 195 Decon Pd 5 -Building Decontamination 470 days 09124/2022 07/13/2024 196 Decon Pd 5 Begins 0 days 09/24/2022 09/24/2022 197 Unit 3 305 days 09/27/2022 11/25/2023 198 Decon Containment Building

-Unit 3 150 days 09/27/2022 04/22/2023 199 Decon Penetration Building

-Unit 3 85 days 04/25/2023 08/19/2023 200 Decon Safety Equipment and MSIV Building

-Unit 3 70 days 08/22/2023 11/25/2023 201 Decon Fuel Handling Building

-Unit 3 65 days 09/27/2022 12/24/2022 202 Decon Turbine Building

-Unit 3 30 days 09/27/2022 11/05/2022 203 Unit 2 425 days 11/08/2022 06122/2024 204 Decon Containment Building

-Unit 2 150 days 04/25/2023 11/18/2023 205 Decon Penetration Building

-Unit 2 85 days 11/21/2023 03116/2024 206 Decon Safety Equipment and MSIV Building

-Unit 2 70 days 03119/2024 06/22/2024 207 Decon Fuel Handling Building

-Unit 2 65 days 12/27/2022 03/25/2023 208 Decon Turbine Building

-Unit 2 30 days 11/08/2022 12/17/2022 209 Common 470 days 09/27/2022 07113/2024 210 Decon Auxiliary Radwaste Building

-Common 120 days 03/28/2023 09/09/2023 211 Decon Auxiliary Control Building

-Common 20 days 09/12/2023 10/07/2023 212 Decon Condensate Area and Tunnels -Units 2 and 3 80 days 09112/2023 12/30/2023 213 Excavate.

Remove and Dispose of Yard Area Drains 60 days 01/02/2024 03/23/2024 214 Remove and Dispose of Contaminated Sumps, Trenches and Pavement 60 days 01/02/2024 03/23/2024 215 Remove and Dispose of Radiologically Contaminated Soil 30 days 03/26/2024 05/04/2024 216 Dispose of Contaminated Decon Equipment and Tooling 15 days 06/25/2024 07/13/2024 217 Radiological Survey of Structures During Decon 410 days 09/2712022 04/20/2024 218 Decon Pd 5 Ends 0 days 07/13/2024 07/13/2024 219 Decon Pd 6 -License Termination During Demolition 2206 days 07/13/2024 12/24/2032 220 Decon Pd 6 Begins 0 days 07/13/2024 07/13/2024 221 Final Status Survey 1771 days 07/13/2024 04/25/2031 222 ORISE Verification and NRC Approval 18 mons 05/17/2031 10/01/2032 223 Prepare Final Report of Dismantling Program 60 days 10/02/2032 12/24/2032 224 Decon Complete

-Partial License Termination 0 days 12/24/2032 12/24/2032 9/1247/14I II225Decon Pd 6 Ends0 days12/24/2032 12/24/2032 226 Site Restoration 10052 daysI 0810712013 12/16/2051 I: __________

1 II i I..227SK Pd I -Transition to Site Restorauon 38daaysl OW07120131 W3020 15uI228 SR Pd 1 Begins 0 days 06/07/2013 06/07/2013 229 Mesa Site Phase I and II Site Assessment 60 days 04/11/2014 07/03/2014 230 Disposition Hazardous Waste from Mesa Site 30 days 07/04/2014 08/14/2014 231 Mesa Site Characterization Survey 120 days 11/07/2014 04/23/2015 232 Fuel Cancellation Expense 60 days 01/21/2014 04/12/2014 233 SR Pd 1 Ends 0 days 06/30/2015 06/30/2015 234 SR Pd 2 -Building Demolition During Decommissioning 530 days 06/30/20151 0711/2017 p.Itp, /30S5R Pit 2 Beginso daysl OW/0/2U1,5 06/r=/015 SONGS 2 & 3Detailed Project SchedulePrompt DECON, DOE Repository Opens 2024/D -TaskNarne_

.. Duration S ,tan I Fi..nish^i 1 23J4 5 617189 23124125726L27281291301[32[33134135361373813941 Prepare Site Restoration Uemolition I-an ano scneouie12U days07/U0/2015 12Y151 20~15237 Obtain Required Permits For Mesa, South Access and South Yard 90 days 12/1612015 04/19/2016 238 South Access for Decommissioning 150 days 04/2012016 11115/2016 239 Demolish Service Building (K-10, 20, 30) 60 days 04/20/2016 07/12/2016 240 Demolish South Security Processing Facility (K-70) 30 days 07113/2016 08/23/2016 241 Demolish Staging Warehouse 30 days 08/24/2016 10/04/2016 242 Demolish Administration Building (K-40/50) 30 days 10/05/2016 11115/2016 243 South Yard Facility 105 days 04120/2016 09/13/2016 244 Demolish South Yard Area Buildings T-10, 20, 60 and Haz Mat. 90 days 04/20/2016 08/23/2016 245 Demolish REMS Staging Pad 15 days 08/24/2016 09/13/2016 246 Mesa 320 days 04/20/2016 07/11/2017 247 Demolish Mesa Buildings 140 days 04120/2016 11/01/2016 248 Remove Underground Fuel Storage Tanks 30 days 11/02/2016 12/13/2016 249 Demolish Mesa Roads and Parking Lots 60 days 12/14/2016 03/07/2017 250 Finish Grading and Re-vegetate Mesa Site 90 days 03/08/2017 07/11/2017 251 Mesa Area Cleared for Easement Termination 0 days 07/11/2017 07/11/2017 252 SR Pd 2 Ends 0 days 07/11/2017 07/11/2017 253 SR Pd 3 -Subsurface Demolition Engineering and Permitting 1250 days 10101/2019 07/13/2024 254 SR Pd 3 Begins 0 days 10/01/2019 10/01/2019 255 Hydrogeologic Investigation and Outfall Conduit Survey 120 days 10/01/2019 03/14/2020 256 Subsurface Structure Removal Engineering Planning and Design 120 days 03/17/2020 08/29/2020 257 Environmental Impacts Analyses for Lease Termination Activities 700 days 09/01/2020 05/06/2023 258 Final Site Grading and Shoreline Protection Engineering Planning and Design 90 days 05/09/2023 09/09/2023 259 Obtain Required Permits and Approvals 220 days 09/12/2023 07/13/2024 260 SR Pd 3 Ends 0 days 07/13/2024 07/13/2024 261 SR Pd 4 -Building Demolition to 3 Feet Below Grade 1110 days 07/13/2024 10/14/2028 262 SR Pd 4 Begins 0 days 07/13/2024 07/13/2024 263 Procure Building Demolition Equipment 1080 days 07/16/2024 09/02/2028 264 Demolition Preparations 80 days 0711612024 11/02/2024 265 Install Temporary Structures 30 days 07/16/2024 08/24/2024 266 Install Erosion and Sediment Controls 20 days 07/16/2024 08/1012024 267 Remove Cathodic Protection Trench 60 days 08/13/2024 11/02/2024 268 Remove Protected Area Security Fencing 45 days 08/13/2024 10/12/2024 269 Remove Protected Area Pavement 20 days 08/13/2024 09/07/2024 270 Unit 3 870 days 07/16/2024 11113/2027 271 Detension and Remove Unit 3 Containment Builidng Tendons 240 days 07/16/2024 06/14/2025 272 Demolish Diesel Generator Building

-Unit 3 60 days 07/16/2024 10/05/2024 273 Demolish Condensate Building and Transformer Pads -Unit 3 60 days 10/08/2024 12/28/2024 274 Demolish Full Flow Area and Turbine Building

-Unit 3 140 days 12/31/2024 07/12/2025 275 Demolish Unit 3 Fuel Handling Building to 3-Feet Below Grade 120 days 06/30/2026 12/12/2026 276 Demolish Penetration Building

-Unit 3 60 days 06/30/2026 09/19/2026 277 Demolish Safety Equipmentand MSIV Building

-Unit 3 60 days 07/15/2025 10104/2025 278 Demolish Unit 3 Containment Building to 3-Feet Below Grade 240 days 12/15/2026 11/13/2027 71111,7111114279Unit 21020 days11119/2024 280 Detension and Remove Unit 2 Containment Builidng Tendons 240 days281 Demolish Diesel Generator Building

-Unit 2 60 days282 Demolish Condensate Building and Transformer Pads -Unit 2 60 days10114/2028 05/16/2026 02/08/2025 I1 SONGS 2 & 3Detailed Project SchedulePrompt DECON, DOE Repository Opens 2024iO Task Name Duration Start Finish 11213 14 1516171819110111112113114115t 6117]tI 0Ol2t1221231412512612718L2913o0313213313413513371381914114; 283uemolish iull i-ow Area and I urbine Uuilding

-Uni 2140 daysU5I11OILU2O 1 ]11 ii ULO284 Demolish Unit 2 Fuel Handling Building to 3-Feet Below Grade 120 days 12/1512026 05r29/2027 285 Demolish Penetration Building

-Unit 2 60 days 06/01/2027 08/21/2027 286 Demolish Safety Equipment and MSIV Building

-Unit 2 60 days 08124/2027 11113/2027 287 Demolish Unit 2 Containment Building to 3-Feet Below Grade 240 days 11/16/2027 10114/2028 288 Common 510 days 07116/2024 06127/2026 289 Demolish AWS Building 90 days 07/16/2024 11/16/2024 290 Demolish Building L-50 60 days 11/19/2024 02/08,2025 291 Demolish Building B-64/B-65 45 days 07/16/2024 09/14/2024 292 Demolish Building B-62/B-63 45 days 09/17/2024 11/16/2024 293 Demolish Outage Control Center 45 days 02/11/2025 04/12/2025 294 Demolish Building B-49/B-50 45 days 04/15/2025 06/14/2025 295 Demolish Building B-43/B-44 45 days 06/17/2025 08/16/2025 296 Demolish Auxiliary Radwaste Building

-Common 160 days 05/06/2025 12/13/2025 297 Demolish Auxiliary Control Building

-Common 160 days 11/18/2025 06127/2026 298 Remove Systems and Demolish Make-Up Demineralizer Structures 120 days 07/16/2024 12/28/2024 299 Install Concrete Plugs in Intake and Discharge Structures 90 days 08/27/2024 12/28/2024 300 Demolish Intake and Discharge Structures to 3-Feet Below Grade 60 days 11/18/2025 02/07/2026 301 SR Pd 4 Ends 0 days 10/14/2028 10/14/2028 302 SR Pd 5 -Subgrade Structure Removal Below -3 Feet 820 days 10/14/2028 12/05/2031 303 SR Pd 5 Begins 0 days 10/14/2028 10114/2028 304 Procure Subsurface Structure Demolition Equipment 520 days 10/17/2028 10/11/2030 305 Install Sheet Piling and Excavation Shoring 120 days 10/17/2028 03/31/2029 306 Install Dewatering System and Effluent Treatment and Discharge Controls 60 days 04/01/2029 06/22/2029 307 Unit 3 Subsurface Structures 480 days 06/23/2029 0412612031 308 Demolish and Backfill Unit 3 Condensate Storage Area Below -3 Feet 30 days 06/23/2029 08/03/2029 309 Demolish and Backfill Unit 3 Diesel Generator Builidng Below -3 Feet 30 days 08/04/2029 09114/2029 310 Demolish and Backfill Unit 3 Fuel Handling Building Below -3 Feet 120 days 09/15/2029 03/01/2030 311 Demolish and Backfill Unit 3 Radwaste Building Below -3 Feet 120 days 03/02/2030 08/16/2030 312 Demolish and Backfill Unit 3 Turbine Building Structure Below 9 Ft Elevatiot 120 days 06/23/2029 12/07/2029 313 Demolish and Backfill Unit 3 Safety Equipment Building Below -3 Feet 90 days 12/08/2029 04/12/2030 314 Demolish and Backfill Unit 3 Penetration Area Below -3 Feet 60 days 04113/2030 07/05/2030 315 Demolish and Backfill Unit 3 Full Flow Building Below -3 Feet 60 days 07/06/2030 09/27/2030 316 Demolish and Backfill Unit 3 Containment Building Below -3 Feet 180 days 08/17/2030 04/25/2031 317 Unit 2 Subsurface Structures 480 days 06/23/2029 04/25/2031 318 Demolish and Backfill Unit 2 Condensate Storage Area Below -3 Feet 30 days 06/23/2029 08/03/2029 319 Demolish and Backfill Unit 2 Diesel Generator Builidng Below -3 Feet 30 days 08/04/2029 09/14/2029 320 Demolish and Backfill Unit 2 Fuel Handling Building Below -3 Feet 120 days 09/15/2029 03/01/2030 321 Demolish and Backfill Unit 2 Radwaste Building Below -3 Feet 120 days 03/02/2030 08/16/2030 322 Demolish and Backfill Unit 2 Turbine Building Structure Below 9 Ft Elevatiol 120 days 06/23/2029 12/07/2029 323 Demolish and Backfill Unit 2 Safety Equipment Building Below -3 Feet 90 days 12/08/2029 04/12/2030 324 Demolish and Backfill Unit 2 Penetration Area Below -3 Feet 60 days 04/13/2030 07/05/2030 325 Demolish and Backfill Unit 2 Full Flow Building Below -3 Feet 60 days 07/06/2030 09/27/2030 Iq**N18sPIIDemolish and Backfill Unit 2 Containment Building Below -3 Feet180 days08/17/2030 327 Common Subgrade Structures 432 days328 Demolish and Backfill Intake Structure Inside Seawall Below -3 Feet 220 days04/25/2031 10/11/2030 10/11/2030 10/11/2036 1Remove Off :Shore Intake and Outlall C~onduits 432 days SONGS 2 & 3Detailed Project SchedulePrompt DECON, DOE Repository Opens 2024ID ITask Name I Duration start Finish 11 2 3 14 1516 17 18 19110111112113114115116117118119 01222123 24125126127128t29 0131132133134[35136 7138139101114.

330Remove Sheet Piling and Excavation Shoring120 days04/2612031 1011012031 331 Remove Dewatering System and Effluent Treatment 90 days 04/26/2031 08/29/2031 332 Finish Grading and Re-Vegetate Site 140 days 04/26/2031 11/07/2031 333 Remove Temporary Structures 20 days 11/08/2031 12/05/2031 334 SR Pd 5 Ends 0 days 12/05/2031 12/05/2031 335 SR Pd 6 -Final Site Restoration and Lease Termination 420 days 05/06/2050 12/1512051 336 SR Pd 6 Begins 0 days 05/06/2050 05/06/2050 337 Obtain Required Permits and Approvals 60 days 05/07/2050 07/29/2050 338 Install Temporary Structures 10 days 07/30/2050 08/12/2050 339 Procure Site Restoration Equipment 265 days 07/30/2050 08/04/2051 340 Install Temporary Seawall or Coffer Dam 120 days 07/30/2050 01113/2051 341 Install Dewatering System and Effluent Treatment and Discharge Controls 45 days 11/12/2050 01/13/2051 342 Remove and Stockpile Existing Seawall Erosion Protection 10 days 07/30/2050 08/12/2050 343 Remove Unit 2 and 3 Seawall and Pedestrian Walkway 90 days 01/14/2051 05/19/2051 344 Remove Remaining Intake and Outfall Box Culvert 60 days 01/14/2051 04/0712051 345 Remove Temporary Seawall or Coffer Dam 90 days 04/08/2051 08/11/2051 346 Backfill and Compaction of Excavation 30 days 08/12/2051 09/22/2051 347 Remove Dewatering System and Effluent Treatment 20 days 05/20/2051 06/16/2051 348 Install Shoreline Erosion Control and Restoration Features 20 days 09/23/2051 10/20/2051 349 Remove Railroad Tracks, Rails and Ballast 60 days 05/20/2051 08/11/2051 350 Remove Gunite Slope Protection 110 days 07130/2050 12/30/2050 351 Remove Access Roads and Parking Lots 30 days 10/21/2051 12101/2051 352 Finish Grading and Re-Vegetate Site 60 days 09/23/2051 12/15/2051 353 Remove Temporary Structures 10 days 12/02/2051 12/15/2051 354 SR Pd 6 Ends 0 days 12/15/2051 12/15/2051 12/IS12115121153 It-inal Easement i erminatlon U oays 12/15/25u1 12 12./Z051 2014 Decommissioning Cost Analysis of theSan Onofre Nuclear Generating Station Units 2 & 3Document No. 164001-DCE-001 Appendix DDetailed Cost Table Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusPOLUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Decommissioning Alternative DECONSpent Fuel Alternative DryFuel Pool Systems ModifiedRepository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalA. License Termination Decon Pd 1 Transition to Deconunissioning Distributed 1.05 Disposition of Legacy Wastes $0 $0 $9,153 $735 $0 $9,888Distributed Subtotal

$0 $0 $9,153 $735 $0 $9,888Undistributed 1.01 Utility Staff $30,049 $0 $0 $0 $0 $30.0491.05 Insurance

$0 $0 $0 $5,352 $0 $5,3521.07 NRC Decommissioning Fees $0 $0 $0 $1,349 $0 $1,3491.08 Materials and Services

$0 $0 $0 $1,007 $0 $1,0071.10 Energy $0 $0 $0 $2,422 $0 $2,4221.17 Association Fees and Expenses

$0 $0 $0 $315 $0 $3151.18 Utilities (Water, gas, phone) $0 $0 $0 $840 $0 $8401.20 Non-Process Computers

$0 $0 $0 $224 $0 $2241.21 Telecommunications

$0 $0 $0 $41 $0 $411.22 Personal Computers

$0 $0 $0 $9 $0 $91.24 Environmental Permits and Fees $0 $0 $0 $818 $0 $818Undistributed Subtotal

$30,049 $0 $0 $12,378 $0 $42,426Decon Pd ISubtotal$30,049$0$9,153$13,113$0$52,315Page 1 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense Status POL Unit 2 Shut Down: 6/7/2013Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013Spent Fuel Alternative Dry Repository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalDecon Pd 2 Decommissioning Planning and Site Modifications Distributed 2.01 Develop Certified Fuel Handler Program $143 $1 $0 $0 $36 $1802.02 Prepare Post-Shutdown QA Plan $427 $1 $0 $0 $107 $5352.03 Prepare Post-Shutdown Security Plan $427 $1 $0 $0 $107 $5352.04 Prepare Post-Shutdown Fire Protection Plan $427 $1 $0 $0 $107 $5352.05 Prepare Defueled Radiation Protection Manual $427 $1 $0 $0 $107 $5352.06 Prepare Preliminary Defueled Technical Specifications

$0 $0 $0 $135 $34 $1692.07 Prepare Defueled Safety Analysis Report (DSAR) $1,279 $5 $0 $0 $321 $1,6052.08 Implement Technical Specification Modifications

$1,332 $5 $0 $0 $334 $1,6712.09 Prepare Post-Shutdown Emergency Preparedness Plan $634 $1 $0 $0 $159 $7932.10 NRC Review of Emergency Preparedness Plan $0 $0 $0 $105 $26 $1312.11 Prepare Post-Shutdown Decommissioning Activities Report (PSDAR) $550 $1 $0 $0 $138 $6882.12 NRC Review of Post-Shutdown Decommissioning Activities Report (PSDAR) $0 $0 $0 $105 $26 $1312.13 Respond to NRC quesitons on PSDAR $34 $1 $0 $0 $9 $432.14 Prepare Decommissioning Cost Estimate (DCE) $1,429 $4 $0 $0 $358 $1,7912.15 NRC Review of Decommissioning Cost Estimate

$0 $0 $0 $105 $26 $1312.16 Disposition of Legacy Wastes $0 $0 $16,457 $0 $4,114 $20,5712.17 Perform Historic Site Assessment and Site Characterization

$6,784 $838 $0 $0 $1,143 $8,7652.18 Planning and Design For Cold and Dark $9.716 $90 $0 $0 $2,451 $12,2572.19 Implement Cold and Dark (Repower Site) $16,141 $17,860 $0 $0 $8,500 $42,5012.20 Install 12kV Service Line to Power Temporary Power Ring $0 $0 $0 $5,250 $1,313 $6,5632.21 Drain and De-Energize Non-Essential Systems (DEC Process)

$822 $183 $1,485 $0 $623 $3,1142.22 Select Decommissioning General Contractor

$645 $8 $0 $0 $163 $8172.23 Design Spent Fuel Pool Support System Modifications

$622 $8 $0 $0 $157 $7872.24 Design Control Room Relocation

$601 $7 $0 $0 $152 $7602.25 Design Spent Fuel Security System Modifications

$459 $5 $0 $0 $116 $5802.26 Install Spent Fuel Pool System Modifications

-Unit 2 $1,863 $4,101 $0 $0 $1,491 $7,4562.27 Install Spent Fuel Pool System Modifications

-Unit 3 $1,863 $4,101 $0 $0 $1,491 $7,4562.28 Spent Fuel Pool System Modification Training

$0 $0 $0 $273 $68 $3412.29 Implement Control Room Modifications

$1,004 $1,519 $0 $0 $631 $3,1532.30 Implement Spent Fuel Pool Security Modifications

$525 $795 $0 $0 $330 $1,6502.31 Transition Project Modifications

$0 $0 $0 $105 $26 $131Page 2 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusPOLUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Decommissioning Alternative DECONSpent Fuel Alternative DryFuel Pool Systems ModifiedRepository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalDistributed Subtotal

$48,154 $29,538 $17,942 $6,077 $24,665 $126,376Undistributed 1.01 Utility Staff $56,478 $0 $0 $0 $14,119 $70,5971.02 Utility Staff HP Supplies

$0 $1,781 $0 $0 $445 $2,2261.03 Security Guard Force $2,087 $0 $0 $0 $522 $2,6091.04 Security Related Expenses

$77 $0 $0 $0 $19 $961.05 Insurance

$0 $0 $0 $4,446 $1,111 $5,5571.06 Site Lease and Easement Expenses

$0 $0 $0 $470 $70 $5401.07 NRC Decommissioning Fees $0 $0 $0 $2,390 $598 $2.9881.08 Materials and Services

$0 $3,208 $0 $0 $802 $4,0101.09 DAW Disposal

$0 $0 $295 $0 $74 $3691.10 Energy $0 $0 $0 $6,338 $1,584 $7,9221.13 Craft Worker Training

$234 $0 $0 $0 $58 $2921.14 Workers Compensation Insurance

$0 $0 $0 $283 $71 $3531.15 Community Outreach

$1,638 $0 $0 $1,830 $867 $4,3351.16 Property Tax $0 $0 $0 $2,350 $588 $2,9381.17 Association Fees and Expenses

$0 $2,350 $0 $0 $588 $2,9381.18 Utilities (Water, gas, phone) $0 $738 $0 $0 $185 $9231.20 Non-Process Computers

$0 $157 $0 $0 $39 $1961.21 Telecommunications

$0 $157 $0 $0 $39 $1961.24 Environmental Permits and Fees $0 $0 $0 $2,977 $744 $3,7211.25 Decommissioning Advisor $0 $0 $0 $1,567 $392 $1,958Undistributed Subtotal

$60,513 $8,391 $295 $22,650 $22,915 $114,764Decon Pd 2Subtotal$108,667$37,928$18,237$28,727$47,581$241,140Page 3 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusPOLUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Decommissioning Alternative DECONFuel Pool Systems ModifiedRepository Opening Date: 1/1/2024Spent Fuel Alternative Dry2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalDecon Pd 3 Deconunissioning Preparations and Reactor Internals Segmentation Distributed 3.01 Prepare Integrated Work Sequence and Schedule for Decommissioning

$952 $0 $0 $0 $238 $1,1903.02 Prepare Detailed Work Procedures and Activity Specifications for Decommissioning

$14,920 $70 $0 $0 $3,748 $18,7383.03 Planning and Design of Primary System Decontamination

$516 $4 $0 $0 $130 $6493.04 Planning and Design Site Infrastructure Improvements

$341 $4 $0 $0 $86 $4313.05 Design Containment Access Modifications

$557 $6 $0 $0 $141 $7053.06 Primary System Decontamination

-Unit 2 $1,447 $1,857 $2,228 $0 $1,383 $6,9143.07 Primary System Decontamination

-Unit 3 $1,447 $1,857 $2,228 $0 $1,383 $6,9143.08 Hot Spot Decontamination

-Unit 2 $580 $887 $743 $0 $552 $2,7613.09 Hot Spot Decontamination

-Unit 3 $580 $913 $743 $0 $559 $2,7943.10 Modify Containment Access- Unit 2 $315 $611 $0 $0 $231 $1,1573.11 Modify Containment Access- Unit 3 $315 $611 $0 $0 $231 $1,1573.12 Remove and Dispose of Missle Shields -Unit 2 $206 $30 $81 $0 $79 $3953.13 Remove and Dispose of Reactor Head -Unit 2 $879 $453 $2,463 $0 $949 $4,7443.14 Remove and Dispose of Missile Shields -Unit 3 $437 $178 $3,375 $0 $997 $4,9873.15 Remove and Dispose of Reactor Head -Unit 3 $879 $453 $2,463 $0 $949 $4,7443.16 Finalize Residual Radiation Inventory

$125 $0 $0 $287 $103 $5163.17 Prepare Activity Specifications

$7,328 $696 $0 $0 $2,006 $10,0313.18 Select Shipping Casks and Obtain Shipping Permits $49 $0 $0 $0 $12 $623.19 Design, Specify, and Procure Special Items and Materials

$972 $5,379 $0 $0 $1,588 $7,9383.22 Test Special Cutting and Handling Equipment and Train Operators

$1,157 $148 $0 $0 $326 $1,6313.23 Finalize Internals and Vessel Segmenting Details -Unit 2 $212 $16 $0 $0 $57 $2843.24 Segment, Package and Dispose of Reactor Internals

-Unit 2 $5,669 $2,036 $62,661 $0 $17,591 $87,9573.25 Transfer Internals Segmentation Equipment to Unit 3 $131 $19 $0 $0 $37 $1873.26 Finalize Internals and Vessel Segmenting Details -Unit 3 $212 $16 $0 $0 $57 $2843.27 Segment, Package and Dispose of Reactor Internals

-Unit 3 $5,669 $2,036 $62,661 $0 $17,591 $87,9573.28 Construct New Change Rooms, Hot Laundry, In-Plant Laydown Areas $0 $1,290 $0 $0 $194 $1,4843.29 Procure Non-Engineered Standard Equipment

$0 $5,454 $0 $0 $1,364 $6,818Distributed Subtotal

$45,893 $25,024 $139,643

$287 $52,583 $263,431Undistributed 1.01 Utility Staff$79,350$0$0$0 $19,837$99,187Page 4 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusFuel Pool SystemsPOLModifiedUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Decommissioning Alternative DECONSpent Fuel Alternative DryRepository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total1.02 Utility Staff HP Supplies

$0 $2,693 $0 $0 $673 $3,3661.03 Security Guard Force $5,484 $0 $0 $0 $1,371 $6,8551.04 Security Related Expenses

$326 $0 $0 $0 $82 $4081.05 Insurance

$0 $0 $0 $8,000 $2,000 $10,0001.06 Site Lease and Easement Expenses

$0 $0 $0 $1,235 $185 $1,4201.07 NRC Decommissioning Fees $0 $0 $0 $6,281 $1,570 $7,8511.08 Materials and Services

$0 $4,582 so $0 $1,145 $5.7271.09 DAW Disposal

$0 $0 $424 $0 $106 $5291.10 Energy $0 $0 $0 $10,226 $2,556 $12,7821.11 Decommissioning General Contractor Staff $62,219 $0 $0 $0 $15,555 $77,7731.12 DGC HP Supplies

$0 $1,558 $0 $0 $389 $1,9471.13 Craft Worker Training

$1,842 $0 $0 $0 $460 $2.3021.14 Workers Compensation Insurance

$0 $0 $0 $742 $186 $9281.15 Community Outreach

$4,303 $0 $0 $4,808 $2,278 $11,3901.16 Property Tax $0 $0 $0 $6,175 $1,544 $7,7191.17 Association Fees and Expenses

$0 $6,175 $0 $0 $1,544 $7,7191.18 Utilities (Water, gas, phone) $0 $1,106 $0 $0 $277 $1,3831.19 Tools and Equipment

$0 $182 $0 $0 $45 $2271.20 Non-Process Computers

$0 $412 $0 $0 $103 $5151.21 Telecommunications

$0 $412 $0 $0 $103 $5151.22 Personal Computers

$0 $0 $0 $89 $22 $1111.24 Environmental Permits and Fees $0 $0 $0 $7,822 $1,955 $9,7771.25 Decommissioning Advisor $0 $0 $0 $4,117 $1,029 $5,146Undistributed Subtotal

$153,524

$17,119 $424 $49,495 $55,017 $275,579Decon Pd 3Subtotal$199,417$42,144$140,067$49,782$107,600$539,009Page 5 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense Status POL Unit 2 Shut Down: 6/7/20 13Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/20 13Spent Fuel Alternative Dry Repository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalDecon Pd 4 Plant Systems and Large Component RemovalDistributed 4.01 Upgrade Rail Spur $0 $0 $0 $3.277 $819 $4,0964.02 Install GARDIAN System $0 $0 $0 $525 $131 $6564.03 Scaffolding for Non-Essential System Removal $3,516 $1,144 $200 $0 $1,215 $6,0754.04 Asbestos Abatement and Hazardous Waste Disposal for Non-Essential Systems -Unit $0 $0 $0 $1,050 $525 $1,5754.05 Lead Abatement for Non-Essential Systems Removal -Unit 2 $2,287 $23 $411 $0 $1,361 $4,0824.06 Remove, Package and Dispose of Non-Essential Systems -Unit 2 $33,512 $5,597 $31,969 $0 $17,769 $88,8474.07 Asbestos Abatement and Hazardous Waste Disposal for Non-Essential Systems -Unit $0 $0 $0 $1,050 $525 $1,5754.08 Lead Abatement for Non-Essential Systems -Unit 3 $2,287 $399 $411 $0 $1,549 $4,6474.09 Remove, Package and Dispose of Non-Essential Systems -Unit 3 $36,851 $6,313 $36,610 $0 $19,944 $99,7184.10 Remove Underground Diesel Tank -Unit 2 $111 $45 $0 $41 $49 $2474.11 Remove Underground Diesel Tank -Unit 3 $111 $45 $0 $41 $49 $2474.12 Remove and Dispose of Spent Fuel Storage Racks -Unit 2 $42 $36 $4.922 $0 $1.250 $6,2504.13 Remove and Dispose of Spent Fuel Storage Racks -Unit 3 $42 $36 $4,922 $0 $1,250 $6,2504.14 Remove and Dispose of Legacy Class B and C Waste -Unit 2 $0 $0 $500 $0 $125 $6254.15 Remove and Dispose of Legacy Class B and C Waste -Unit 3 $0 $0 $500 $0 $125 $6254.16 Drain Spent Fuel Pool and Process Liquid Waste -Unit 2 $557 $703 $0 $0 $315 $1,5754.17 Drain Spent Fuel Pool and Process Liquid Waste -Unit 3 $557 $703 $0 $0 $315 $1,5754.18 Segment.

Package and Dispose of Spent Fuel Pool Island Equipment

$11 $2 $107 $0 $30 $1504.19 Segment and Dispose of Fuel Pool Bridge Crane -Unit 2 $85 $12 $168 $0 $66 $3324.20 Segment and Dispose of Fuel Pool Bridge Crane -Unit 3 $85 $12 $168 $0 $66 $3324.21 Flush and Drain Essential Systems Following Fuel Pool Closure $226 $181 $2,970 $0 $844 $4,2214.22 Scaffolding for Essential System Removal $989 $322 $56 $0 $342 $1,7084.23 Asbestos Abatement and Hazardous Waste Disposal for Essential Systems $0 $0 $0 $788 $394 $1,1814.24 Lead Abatement for Essential Systems Removal $332 $58 $59 $0 $225 $6744.25 Remove, Package and Dispose of Essential Systems $33,774 $5,869 $17,264 $0 $14,227 $71,1344.26 Removal and Disposal of Spent Resins. Filter Media and Tank Sludge $90 $40 $7,425 $0 $1,889 $9,4454.27 Reactor Vessel Insulation Removal and Disposal

-Unit 2 $105 $12 $147 $0 $66 $3314.28 Segment.

Package and Dispose of Reactor Pressure Vessel -Unit 2 $1,044 $2,834 $29,313 $0 $8,298 $41,4894.2 9 Transfer Rx Vessel Segmentation Equipment to Unit 3 $122 $18 $0 $0 $35 $1754.30 Procure Replacement Non-Engineered Standard Equipment

$0 $454 $0 $0 $114 $5684.31 Reactor Vessel Insulation Removal and Disposal

-Unit 3 $105 $12 $147 $0 $66 $331Page 6 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusFuel Pool SystemsPOLModifiedUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Decommissioning Alternative DECONSpent Fuel Alternative DryRepository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total4.32 Segment, Package and Dispose of Reactor Pressure Vessel -Unit 3 $1,044 $2,834 $29,313 $0 $8,298 $41.4894.33 Remove and Dispose of Steam Generators

-Unit 2 $2,789 $1,288 $18,154 $0 $5,558 $27,7884.34 Remove and Dispose of Pressurizer

-Unit 2 $462 $70 $2,620 $0 $788 $3,9404.35 Remove and Dispose of Steam Generators

-Unit 3 $2,789 $1,288 $18,154 $0 $5,558 $27,7884.36 Remove and Dispose of Pressurizer

-Unit 3 $462 $70 $2,620 $0 $788 $3,9404.37 Remove and Dispose of Turbine Gantry Crane -Unit 2 $445 $229 $0 $4 $170 $8484.38 Remove and Dispose of Turbine Gantry Crane -Unit 3 $445 $229 $0 $4 $170 $8484.39 Prepare License Termination Plan $1,646 $149 $0 $0 $449 $2,244Distributed Subtotal

$126,926

$31,029 $209,131

$6,779 $95,755 $469,620Undistributed 1.01 Utility Staff1.02 Utility Staff HP Supplies1.03 Security Guard Force1.04 Security Related Expenses1.05 Insurance 1.06 Site Lease and Easement Expenses1.07 NRC Decommissioning Fees1.08 Materials and Services1.09 DAW Disposal1.10 Energy1.11 Decommissioning General Contractor Staff1.12 DGC HP Supplies1.13 Craft Worker Training1.14 Workers Compensation Insurance 1.15 Community Outreach1.16 Property Tax1.18 Utilities (Water. gas, phone)1.19 Tools and Equipment 1.20 Non-Process Computers 1.21 Telecommunications 1.24 Environmental Permits and Fees1.25 Decommissioning Advisor$71,956$0$4,638$1,007$0$0$0$0$0$0$125,798$0$7,788$0$3,639$0$0$0$0$0$0$0$0$2,715$0$0$0$0$0$4,204$0$0$0$5,834$0$0$0$0$1,007$423$348$348$0$0$0$0$0$0$0$0$0$0$1,568$0$0$0$0$0$0$0$0$0$0$0$0$0$0$0$0$0$3,653$1,044$5,312$0$0$7,568$0$0$0$628$4,066$5,222$0$0$0$0$6,615$2,611$17,989$679$1,159$252$913$157$1,328$1,051$392$1,892$31,449$1,458$1,947$157$1,926$1,306$252$106$87$87$1,654$653$89,945$3,394$5,797$1,259$4,566$1,201$6,639$5,255$1,960$9,460$157,247$7,292$9,735$785$9,632$6,528$1,258$529$435$435$8,268$3,264Page 7 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageDecommissioning Alternative DECONSpent Fuel Alternative DryLicense Status POLFuel Pool Systems ModifiedRepository Opening Date: 1/1/2024Unit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/20132014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalUndistributed Decon Pd 4SubtotalSubtotal$214,826$341,752$14,879$45,908$1,568$210,699$36,718$43,497$66,893$162,649$334,884$804,504Page 8 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusPOLUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Decommissioning Alternative DECONSpent Fuel Alternative DryFuel Pool Systems ModifiedRepository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalDecon Pd 5 Building Decontamination Distributed 5.01 Decon Containment Building

-Unit 3 $6,056 $3,318 $54,825 $0 $16,050 $80,2495.02 Decon Penetration Building

-Unit 3 $1,065 $351 $2,933 $0 $1,087 $5,4375.03 Decon Safety Equipment and MSIV Building

-Unit 3 $905 $390 $5,562 $0 $1,715 $8,5735.04 Decon Fuel Handling Building

-Unit 3 $1,275 $577 $16,101 $0 $4,488 $22,4425.05 Decon Turbine Building

-Unit 3 $100 $95 $3,925 $0 $1,030 $5,1505.06 Decon Containment Building

-Unit 2 $6,056 $3,318 $54,825 $0 $16,050 $80,2495.07 Decon Penetration Building

-Unit 2 $1,065 $351 $2.933 $0 $1,087 $5,4375.08 Decon Safety Equipment and MSIV Building

-Unit 2 $911 $396 $5,777 $0 $1,771 $8,8545.09 Decon Fuel Handling Building

-Unit 2 $1,275 $577 $16,101 $0 $4,488 $22,4425.10 Decon Turbine Building

-Unit 2 $100 $95 $3,925 $0 $1,030 $5,1505.11 Decon Auxiliary Radwaste Building

-Common $943 $691 $17,999 $0 $4,908 $24,5415.12 Decon Auxiliary Control Building-Common $198 $163 $38 $0 $100 $4995.13 Decon Condensate Area and Tunnels -Units 2 & 3 $375 $316 $403 $0 $274 $1,3685.14 Excavate, Remove and Dispose of Yard Area Drains $1,159 $128 $240 $0 $382 $1,9085.15 Remove and Dispose of Contaminated Sumps, Trenches and Pavement

$185 $21 $746 $0 $238 $1,1915.16 Remove and Dispose of Radiologically Contaminated Soil $192 $216 $1,158 $0 $392 $1,9585.17 Segment, Package and Dispose of Contaminated Decon Equipment and Tooling $38 $6 $92 $0 $34 $1705.18 Radiological Survey of Structures During Decon $4,702 $3,666 $0 $0 $1,255 $9,623Distributed Subtotal

$26,600 $14,676 $187,585

$0 $56,379 $285,240Undistributed 1.01 Utility Staff1.02 Utility Staff HP Supplies1.03 Security Guard Force1.04 Security Related Expenses1.05 Insurance 1.06 Site Lease and Easement Expenses1.07 NRC Decommissioning Fees1.08 Materials and Services1.09 DAW Disposal1.10 Energy$29,516$0$2,520$560$0$0$0$0$0$0$0$997$0$0$0$0$0$1,668$0$0$0$0$0$0$0$0$0$0$464$0$0$0$0$0$1,985$567$2,886$0$0$2.336$7,379$249$630$140$496$85$722$417$116$584$36,895$1,247$3,150$701$2,481$652* $3,608$2,086$580$2,920Page 9 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusFuel Pool SystemsPOLModifiedUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Decommissioning Alternative DECONSpent Fuel Alternative DryRepository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total1.11 Decommissioning General Contractor Staff $56,286 $0 $0 $0 $14,071 $70,3571.12 DGC HP Supplies

$0 $3,170 $0 $0 $792 $3,9621.13 Craft Worker Training

$1,693 $0 $0 $0 $423 $2,1161.14 Workers Compensation Insurance

$0 $0 $0 $341 $85 $4261.15 Community Outreach

$862 $0 $0 $964 $457 $2,2831.16 Property Tax $0 $0 $0 $2,837 $709 $3,5471.18 Utilities (Water, gas, phone) $0 $413 $0 $0 $103 $5171.19 Tools and Equipment

$0 $204 $0 $0 $51 $2551.20 Non-Process Computers

$0 $189 $0 $0 $47 $2361.21 Telecommunications

$0 $189 $0 $0 $47 $2361.22 Personal Computers

$0 $0 $0 $71 $18 $881.24 Environmental Permits and Fees $0 $0 $0 $3,594 $899 $4,4931.25 Decommissioning Advisor $0 $0 $0 $825 $206 $1,031Undistributed Subtotal

$91,437 $6,832 $464 $16,406 $28,728 $143,866Decon Pd 5Subtotal$118,037$21,508$188,049$16,406$85,106$429,106Page 10 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusPOLUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Decommissioning Alternative DECONSpent Fuel Alternative DryFuel Pool Systems ModifiedRepository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalDecon Pd 6 License Termination During Demolition Distributed 6.01 Final Status Survey $9,613 $3,088 $0 $2,360 $2,259 $17,3206.02 Prepare Final Report of Dismantling Program $164 $4 $0 $0 $42 $210Distributed Subtotal

$9,777 $3,091 $0 $2,360 $2,301 $17,530Undistributed 1.01 Utility Staff $1,378 $0 $0 $0 $345 $1,7231.04 Security Related Expenses

$4 $0 $0 $0 $1 $51.07 NRC Decommissioning Fees $0 $0 $0 $13,535 $3,384 $16,9191.08 Materials and Services

$0 $47 $0 $0 $12 $581.09 DAW Disposal

$0 $0 $62 $0 $16 $781.10 Energy $0 $0 $0 $1,872 $468 $2,3401.11 Decommissioning General Contractor Staff $651 $0 $0 $0 $163 $8141.12 DGC HP Supplies

$0 $301 $0 $0 $75 $3761.15 Community Outreach

$2,386 $0 $0 $2,666 $1,263 $6,3151.18 Utilities (Water, gas, phone) $0 $10 $0 $0 $3 $13Undistributed Subtotal

$4,420 $357 $62 $18,074 $5,728 $28,641Decon Pd 6Subtotal$14,197$812,119$3,449$150,936$62 $20,434$8,029$410,965$46,171$2,112,246 A. License Termination Subtotal$566,266$171,959Page 11 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusFuel Pool SystemsPOLModifiedUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Decommissioning Alternative DECONSpent Fuel Alternative DryRepository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalB. Spent FuelSNF Pd 1 Spent Fuel Management Transition Distributed 7.01 Security Shut Down Strategy

$0 $0 $0 $8.388 $0 $8,3887.02 Design and Fabricate Spent Fuel Canisters

$0 $0 $0 $8,842 $0 $8,8427.03 Post Fukushima Modifications

-Unit 2 $0 $0 $0 $126 $0 $1267.05 Cyber Security Modifications so $0 $0 $1,901 $0 $1,901Distributed Subtotal

$0 $0 $0 $19,258 $0 $19,258Undistributed 2.01 Utility Spent Fuel Staff $38,478 $0 $0 $0 $0 $38,4782.04 Security Guard Force $69,889 $0 $0 $0 $0 $69,8892.09 Emergency Preparedness Fees $0 $0 $0 $2,340 $0 $2,3402.10 Spent Fuel Maintenance

$0 $0 $0 $32 $0 $32Undistributed Subtotal

$108,367

$0 $0 $2,372 $0 $110,739SNF Pd 1Subtotal$108,367$0$0 $21,630$0 $129,997Page 12 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusFuel Pool SystemsPOLModifiedUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Deconmmissioning Alternative DECONSpent Fuel Alternative DryRepository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalSNF Pd 2 Spent Fuel Transfer to Dry StorageDistributed 8.01 Security Shut Down Strategy

$0 $0 $0 $2,855 $714 $3,5698.02 Decay Heat Analysis

$0 $0 $0 $105 $26 $1318.03 Zirconium Fire/ Shine Analysis

$0 $0 $0 $105 $26 $1318.05 NRC Review of Irradiated Fuel Management Plan $0 $0 $0 $105 $26 $1318.07 ISFSI Pad Study $0 $0 $0 $103 $26 $1298.08 Design ISFSI Expansion

$0 $0 $0 $3,150 $788 $3,9388.09 Construct ISFSI Expansion

$0 $0 $0 $33,600 $8,400 $42,0008.10 Purchase and Fabrication of Spent Fuel Canisters and AHSMs -Unit 2 $0 $49,613 $0 $0 $12,403 $62,0168.11 Purchase and Fabrication Spent Fuel Canisters and AHSMs -Unit 3 $0 $50,794 $0 $0 $12,698 $63,4928.12 Deliver and Load Spent Fuel Canisters and Transfer to ISFSI -Unit 2 $71,338 $17,478 $0 $0 $22,204 $111,0218.13 Deliver and Load Spent Fuel Canisters and Transfer to ISFSI -Unit 3 $73,037 $17,894 $0 $0 $22,733 $113,664Distributed Subtotal

$144,375

$135,779

$0 $40,023 $80,044 $400,221Undistributed 2.01 Utility Spent Fuel Staff $90,824 $0 $0 $0 $22,706 $113,5302.02 Utility Staff HP Supplies

$0 $6,590 $0 $0 $1,647 $8,2372.04 Security Guard Force $112,313

$0 $0 $0 $28,078 $140,3912.05 Security Related Expenses

$1,334 $0 $0 $0 $333 $1,6672.06 Insurance

$0 $0 $0 $4,408 $1,102 $5,5102.08 NRC Spent Fuel Fees $0 $0 $0 $1,107 $277 $1,3832.09 Emergency Preparedness Fees $0 $0 $0 $18,756 $4,689 $23,4452.10 Spent Fuel Maintenance

$0 $0 $0 $2,131 $533 $2,6642.11 Materials and Services

$0 $5,848 $0 $0 $1,462 $7,3102.12 DAW Disposal

$0 $0 $275 $0 $69 $3432.13 Energy $0 $0 $0 $3,991 $998 $4,9892.15 Craft Worker Training

$2,119 $0 $0 $0 $530 $2,6492.18 Utilities (Water, gas, phone) $0 $3,572 $0 $0 $893 $4,4652.22 Personal Computers

$0 $0 $0 $14 $3 $17Undistributed Subtotal

$206,590

$16,010 $275 $30,406 $63,320 $316,601SNF Pd 2Subtotal$350,965$151,789$275$70,429$143,364$716,822Page 13 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusFuel Pool SystemsPOLModifiedUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Decommissioning Alternative DECONSpent Fuel Alternative DryRepository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalSNF Pd 3 Dry Storage During Decommnissioning

-Units 1, 2 and 3Undistributed 2.01 Utility Spent Fuel Staff $39,894 $0 $0 $0 $9,973 $49,8672.02 Utility Staff HP Supplies

$0 $1,487 $0 $0 $372 $1,8592.04 Security Guard Force $45,944 $0 $0 $0 $11,486 $57,4302.05 Security Related Expenses

$2,556 $0 $0 $0 $639 $3,1952.08 NRC Spent Fuel Fees $0 $0 $0 $2,302 $576 $2,8782.10 Spent Fuel Maintenance

$0 $0 $0 $1,478 $370 $1,8482.11 Materials and Services

$0 $2,017 $0 $0 $504 $2,5222.13 Energy $0 $0 $0 $1,209 $302 $1,5112.18 Utilities (Water, gas, phone) $0 $1,380 $0 $0 $345 $1,7252.22 Personal Computers

$0 $0 $0 $12 $3 $15Undistributed Subtotal

$88,393 $4,884 $0 $5,001 $24,570 $122,849SNF Pd 3Subtotal$88,393$4,884$0$5,001$24,570$122,849Page 14 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusPOLUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Decommissioning Alternative DECONSpent Fuel Alternative DryFuel Pool Systems ModifiedRepository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalSNF Pd 4 Dry Storage Only -Units 1, 2 and 3Undistributed 2.01 Utility Spent Fuel Staff $12,687 $0 $0 $0 $3,172 $15,8592.02 Utility Staff HP Supplies

$0 $882 $0 $0 $220 $1,1022.03 Additional Staff for Spent Fuel Shipping

$1,119 $0 $0 $0 $280 $1,3982.04 Security Guard Force $14,949 $0 $0 $0 $3,737 $18,6872.05 Security Related Expenses

$2,506 $0 $0 $0 $626 $3,1322.06 Insurance

$0 $0 $0 $2,538 $634 $3,1722.07 Site Lease and Easement Expenses

$0 $0 $0 $1,154 $173 $1,3272.08 NRC Spent Fuel Fees $0 $0 $0 $1,638 $409 $2,0472.10 Spent Fuel Maintenance

$0 $0 $0 $481 $120 $6012.11 Materials and Services

$0 $778 $0 $0 $194 $9722.13 Energy $0 $0 $0 $393 $98 $4922.16 Workers Compensation Insurance

$0 $0 $0 $694 $173 $8672.17 Property Tax $0 $0 $0 $6,412 $1,603 $8,0152.18 Utilities (Water, gas, phone) $0 $475 $0 $0 $119 $5942.20 Non-Process Computers

$0 $192 $0 $0 $48 $2402.21 Telecommunications

$0 $192 $0 $0 $48 $2402.22 Personal Computers

$0 $0 $0 $15 $4 $18Undistributed Subtotal

$31,261 $2,519 $0 $13,325 $11,661 $58,765SNF Pd 4 Subtotal

$31,261 $2,519 $0 $13,325 $11,661 $58,765Page 15 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusFuel Pool SystemsPOLModifiedUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Decommissioning Alternative DECONSpent Fuel Alternative DryRepository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalSNF Pd 5 Dry Storage Only -Units 2 and 3Undistributed 2.01 Utility Spent Fuel Staff $48,480 $0 $0 $0 $12,120 $60,6012.02 Utility Staff HP Supplies

$0 $3,369 $0 $0 $842 $4,2112.03 Additional Staff for Spent Fuel Shipping

$4,275 $0 $0 $0 $1,069 $5,3442.04 Security Guard Force $57,126 $0 $0 $0 $14,281 $71,4072.05 Security Related Expenses

$4,124 $0 $0 $0 $1,031 $5,1552.06 Insurance

$0 $0 $0 $9,698 $2,425 $12,1232.07 Site Lease and Easement Expenses

$0 $0 $0 $4,409 $661 $5,0712.08 NRC Spent Fuel Fees $0 $0 $0 $6,259 $1,565 $7,8232.10 Spent Fuel Maintenance

$0 $0 $0 $1,838 $459 $2,2972.11 Materials and Services

$0 $2,972 $0 $0 $743 $3,7152.13 Energy $0 $0 $0 $1,503 $376 $1,8792.16 Workers Compensation Insurance

$0 $0 $0 $2,651 $663 $3,3142.17 Property Tax $0 $0 $0 $22,053 $5,513 $27,5662.18 Utilities (Water, gas, phone) $0 $1,816 $0 $0 $454 $2,2702.20 Non-Process Computers

$0 $735 $0 $0 $184 $9192.21 Telecommunications

$0 $735 $0 $0 $184 $9192.22 Personal Computers

$0 $0 $0 $32 $8 $40Undistributed Subtotal

$114,005

$9,627 $0 $48,443 $42,578 $214,653SNF Pd 5Subtotal$114,005$9,627$0 $48,443$42,578$214,653Page 16 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusFuel Pool SystemsPOLModifiedUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Decommissioning Alternative DECONSpent Fuel Alternative DryRepository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalSNF D&D Pd 1 ISFS1 License Ternination Distributed 12.01 Preparation and NRC Review of License Termination Plan $116 $0 $0 $163 $70 $349Distributed Subtotal

$116 $0 $0 $163 $70 $349Undistributed 2.01 Utility Spent Fuel Staff $366 $0 $0 $0 $91 $4572.02 Utility Staff HP Supplies

$0 $11 $0 $0 $3 $142.04 Security Guard Force $181 $0 $0 $0 $45 $2262.05 Security Related Expenses

$70 $0 $0 $0 $18 $882.06 Insurance

$0 $0 $0 $215 $54 $2692.07 Site Lease and Easement Expenses

$0 $0 $0 $98 $15 $1122.08 NRC Spent Fuel Fees $0 $0 $0 $75 $19 $942.11 Materials and Services

$0 $17 $0 $0 $4 $212.13 Energy $0 $0 $0 $102 $26 $1282.16 Workers Compensation Insurance

$0 $0 $0 $59 $15 $732.17 Property Tax $0 $0 $0 $543 $136 $6792.18 Utilities (Water, gas, phone) $0 $7 $0 $0 $2 $9Undistributed Subtotal

$617 $36 $0 $1,092 $426 $2,172SNF D&D Pd 1Subtotal$733$36$0$1,255$496$2,520Page 17 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusFuel Pool SystemsPOLModifiedUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Decommissioning Alternative DECONSpent Fuel Alternative DryRepository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalSNF D&D Pd 2 ISFSI Demolition Distributed 13.01 Install GARDIAN Bulk Assay System $0 $0 $0 $525 $131 $65613.02 Decon AHSMs $339 $147 $443 $0 $232 $1,16113.03 Final Status Survey of ISFSI $1,589 $256 $0 $0 $277 $2,12213.04 Clean Demolition of ISFSI AHSMs and Pad $4,094 $2,590 $3,333 $0 $2,504 $12,52113.05 Clean Demolition of ISFSI Support Structures

$1,126 $458 $1,372 $0 $739 $3,69613.06 Restore ISFSI Site $246 $161 $0 $0 $102 $50913.07 Preparation of Final Report on Decommissioning and NRC Review $52 $0 $0 $0 $13 $65Distributed Subtotal

$7,446 $3,612 $5,148 $525 $3,998 $20,729Undistributed 2.01 Utility Spent Fuel Staff $1,801 $0 $0 $0 $450 $2,2512.02 Utility Staff HP Supplies

$0 $72 $0 $0 $18 $902.04 Security Guard Force $704 $0 $0 $0 $176 $8802.05 Security Related Expenses

$37 $0 $0 $0 $9 $462.11 Materials and Services

$0 $93 $0 $0 $23 $1162.12 DAW Disposal

$0 $0 $7 $0 $2 $82.13 Energy $0 $0 $0 $268 $67 $3342.14 Decommissioning General Contractor Staff $4,525 $0 $0 $0 $1,131 $5,6562.15 Craft Worker Training

$189 $0 $0 $0 $47 $2362.18 Utilities (Water, gas, phone) $0 $35 $0 $0 $9 $432.24 DGC HP Supplies

$0 $159 $0 $0 $40 $199Undistributed Subtotal

$7,255 $359 $7 $268 $1,972 $9,861SNF D&D Pd 2B. Spent FuelSubtotalSubtotal$14,701$708,425$3,972$172,826$5,154$5,429$793$160,876$5,970$228,639$30,590$1,276,196 Page 18 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusFuel Pool SystemsPOLModifiedUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Decommissioning Alternative DECONSpent Fuel Alternative DryRepository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalC. Site Restoration SR Pd 1 Transition to Site Restoration Distributed 14.01 Mesa Site Phase I and H Site Assessment

$0 $0 $0 $42 $11 $5314.02 Disposition Hazardous Waste from Mesa Site $0 $0 $0 $211 $106 $31714.03 Mesa Site Characterization Survey $988 $261 $0 $0 $312 $1,56114.04 Fuel Cancellation Expense $0 $0 $0 $17,679 $0 $17,679Distributed Subtotal

$988 $261 $0 $17,932 $428 $19,610Undistributed 3.05 Site Lease and Easement Expenses

$0 $0 $0 $1,030 $0 $1,0303.11 Severance

$0 $0 $0 $109,850

$0 $109,850Undistributed Subtotal

$0 $0 $0 $110,880

$0 $110,880SR Pd 1Subtotal$988$261$0$128,812$428$130,489Page 19 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusFuel Pool SystemsPOLModifiedUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Decommissioning Alternative DECONSpent Fuel Alternative DryRepository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalSR Pd 2 Building Demolition During Deconmmissioning Distributed 15.01 Prepare Site Restoration Demolition Plan and Schedule

$684 $10 $0 $0 $173 $86615.02 Obtain Required Permits For Mesa, South Access and South Yard $209 $4 $0 $0 $53 $26615.03 Demolish Service Building (K-10, 20, 30) $250 $189 $481 $0 $230 $1,15015.04 Demolish South Security Processing Facility (K-70) $46 $44 $122 $0 $53 $26415.05 Demolish Staging Warehouse

$67 $55 $126 $0 $62 $31115.06 Demolish Administration Building (K-40/50)

$367 $258 $565 $0 $297 $1,48715.07 Demolish South Yard Area Buildings T-10, 20, 60 and Haz Mat. $670 $590 $1,370 $0 $658 $3,28815.08 Demolish REMS Staging Pad $98 $184 $549 $0 $208 $1,03815.09 Demolish Mesa Buildings

$2,788 $1,879 $6,006 $0 $2,668 $13,34115.10 Remove Underground Fuel Storage Tanks $56 $22 $0 $21 $25 $12315.11 Demolish Mesa Roads and Parking Lots $582 $400 $0 $0 $245 $1,22715.12 Finish Grading and Re-vegetate Mesa Site $299 $404 $0 $0 $176 $878Distributed Subtotal

$6,114 $4,038 $9,219 $21 $4,848 $24,239Undistributed 3.01 Utility Staff $2,563 $0 $0 $0 $641 $3,2043.03 Security Related Expenses

$898 $0 $0 $0 $224 $1,1223.05 Site Lease and Easement Expenses

$0 $0 $0 $4,266 $640 $4,9063.06 Materials and Services

$0 $134 $0 $0 $34 $1683.08 Decommissioning General Contractor Staff $4,248 $0 $0 $0 $1,062 $5,3103.09 Craft Worker Training

$318 $0 $0 $0 $80 $3983.11 Severance

$0 $0 $0 $8,688 $2,172 $10,8603.13 Utilities (Water, gas, phone) $0 $29 $0 $0 $7 $36Undistributed Subtotal

$8,027 $164 $0 $12,955 $4,860 $26,005SR Pd 2Subtotal$14,141$4,201$9,219$12,975$9,708$50,245Page 20 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusPOLUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Decommissioning Alternative DECONFuel Pool Systems ModifiedRepository Opening Date: I/1/2024Spent Fuel Alternative Dry2014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalSR Pd 3 Subsurface Demolition Engineering and Permitting Distributed 16.01 Hydrogeologic Investigation and Outfall Conduit Survey $297 $131 $0 $105 $133 $66716.02 Subsurface Structure Removal Engineering Planning and Design $1,264 $33 $0 $0 $324 $1,62116.03 Environmental Impacts Analyses for Lease Termination Activities

$581 $50 $0 $525 $289 $1,44516.04 Final Site Grading and Shoreline Protection Engineering Planning and Design $242 $13 $0 $0 $64 $31916.05 Obtain Required Permits and Approvals

$1,856 $20 $0 $263 $535 $2,673Distributed Subtotal

$4,240 $248 $0 $893 $1,345 $6,726Undistributed 3.03 Security Related Expenses

$275 $0 $0 $0 $69 $3443.11 Severance

$0 $0 $0 $24,674 $6,168 $30,842Undistributed Subtotal

$275 $0 $0 $24,674 $6,237 $31,186SR Pd 3Subtotal$4,516$248$0$25,566$7,582$37,912Page 21 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense Status POL Unit 2 Shut Down: 6/7/2013Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013Spent Fuel Alternative Dry Repository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalSR Pd 4 Building Demolition to 3 Feet Below GradeDistributed 17.01 Procure Clean Building Demolition Equipment

$0 $10,691 $0 $0 $2,673 $13,36317.02 Install Temporary Structures

$11 $190 $0 $0 $30 $23017.03 Install Erosion and Sediment Controls

$123 $14 $0 $0 $34 $17217.04 Remove Cathodic Protection Trench $1,813 $1,527 $22 $0 $840 $4,20117.05 Remove Protected Area Security Fencing $57 $18 $0 $0 $19 $9517.06 Remove Protected Area Pavement

$139 $97 $755 $0 $248 $1,23917.07 Detension and Remove Unit 3 Containment Builidng Tendons $0 $0 $0 $4.200 $1,050 $5,25017.08 Demolish Diesel Generator Building

-Unit 3 $618 $245 $794 $0 $414 $2,07217.09 Demolish Condensate Building and Transformer Pads -Unit 3 $1,067 $1,755 $3,183 $0 $1,501 $7,50517.10 Demolish Full Flow Area and Turbine Building

-Unit 3 $3,221 $1,149 $3,444 $0 $1,953 $9,76717.11 Demolish Unit 3 Fuel Handling Building to 3-Feet Below Grade $306 $354 $1,470 $0 $533 $2,66317.12 Demolish Penetration Building-Unit 3 $293 $167 $642 $0 $275 $1,37717.13 Demolish Safety Equipment and MSIV Building

-Unit 3 $336 $403 $1,858 $0 $649 $3,24617.14 Demolish Unit 3 Containment Building to 3-Feet Below Grade $2,418 $1,351 $6,198 $0 $2,492 $12,45917.15 Detension and Remove Unit 2 Containment Builidng Tendons $0 $0 $0 $4,200 $1,050 $5,25017.16 Demolish Diesel Generator Building

-Unit 2 $128 $168 $787 $0 $271 $1,35317.17 Demolish Condensate Building and Transformer Pads -Unit 2 $1,067 $1,755 $3,183 $0 $1,501 $7,50517.18 Demolish Full Flow Area and Turbine Building

-Unit 2 $3,734 $1,186 $3,447 $0 $2,092 $10,45817.19 Demolish Unit 2 Fuel Handling Building to 3-Feet Below Grade $306 $354 $1,470 $0 $533 $2,66317.20 Demolish Penetration Building

-Unit 2 $99 $136 $639 $0 $219 $1,09317.21 Demolish Safety and MSIV Equipment Building

-Unit 2 $336 $403 $1,859 $0 $649 $3,24717.22 Demolish Unit 2 Containment Building to 3-Feet Below Grade $2,418 $1,351 $6,198 $0 $2,492 $12,45917.23 Demolish AWS Building

$1,108 $1,050 $2,925 $0 $1,271 $6,35417.24 Demolish Building L-50 $59 $33 $67 $0 $40 $19817.25 Demolish Maintenance Building 4 (B-64/B-65)

$24 $13 $25 $0 $16 $7817.26 Demolish Maintenance Building 5 (B-62/B-63)

$35 $20 $37 $0 $23 $11517.27 Demolish Outage Control Center $98 $57 $148 $0 $76 $37817.28 Demolish Maintenance Building 2 (B-49/B-50)

$49 $32 $82 $0 $41 $20517.29 Demolish Maintenance Building I (B-43/B-44)

$163 $196 $857 $0 $304 $1,52017.30 Demolish Auxilary Radwaste Building

-Common $1,521 $1,984 $9.214 $0 $3,180 $15,89817.31 Demolish Auxilary Control Building

-Common $1,491 $811 $3.219 $0 $1,380 $6.901Page 22 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusFuel Pool SystemsPOLModifiedUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Decommissioning Alternative DECONSpent Fuel Alternative DryRepository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total17.32 Remove Systems and Demolish Make-Up Demineralizer Structures

$737 $122 $471 $0 $332 $1,66217.33 Install Concrete Plugs in Intake and Discharge Structures

$272 $1,614 $0 $0 $472 $2,35817.34 Demolish Intake and Discharge Structures to 3-Feet Below Grade $82 $114 $535 $0 $183 $914Distributed Subtotal

$24,128 $29,358 $53,530 $8,400 $28,834 $144,249Undistributed 3.01 Utility Staff $12,553 $0 $0 $0 $3,138 $15,6913.02 Security Guard Force $2,480 $0 $0 $0 $620 $3,1003.03 Security Related Expenses

$1,158 $0 $0 $0 $290 $1,4483.04 Insurance

$0 $0 $0 $3,995 $999 $4,9933.05 Site Lease and Easement Expenses

$0 $0 $0 $1,340 $201 $1,5413.06 Materials and Services

$0 $751 $0 $0 $188 $9383.07 Energy $0 $0 $0 $1,184 $296 $1,4803.08 Decommissioning General Contractor Staff $50,906 $0 $0 $0 $12,727 $63,6333.09 Craft Worker Training

$1,999 $0 $0 $0 $500 $2,4983.10 Workers Compensation Insurance

$0 $0 $0 $806 $201 $1,0073.11 Severance

$0 $0 $0 $7,273 $1,818 $9,0913.12 Property Tax $0 $0 $0 $6,701 $1,675 $8,3773.13 Utilities (Water, gas, phone) $0 $214 $0 $0 $53 $2673.14 Tools and Equipment

$0 $156 $0 $0 $39 $1953.15 Non-Process Computers

$0 $223 $0 $0 $56 $2793.16 Telecommunications

$0 $223 $0 $0 $56 $279Undistributed Subtotal

$69,096 $1,567 $0 $21,298 $22,856 $114,817SR Pd 4Subtotal$93,224$30,924$53,530$29,698$51,690$259,066Page 23 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense Status POL Unit 2 Shut Down: 6/7/2013Decommissioning Alternative DECON Fuel Pool Systems Modified Unit 3 Shut Down: 6/7/2013Spent Fuel Alternative Dry Repository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalSR Pd 5 Subgrade Structure Removal Below -3 FeetDistributed 18.01 Procure Subsurface Structure Demolition Equipment

$0 $6,630 $0 $0 $1,658 $8,28818.02 Install Sheet Piling and Excavation Shoring $8,468 $17,219 $0 $0 $6,422 $32,10918.03 Install Dewatering System and Effluent Treatment and Discharge Controls

$0 $0 $0 $9,651 $2,413 $12,06418.04 Demolish and Backfill Unit 3 Condensate Storage Area Below -3 Feet $179 $305 $912 $0 $349 $1,74618.05 Demolish and Backfill Unit 3 Diesel Generator Builidng Below -3 Feet $130 $173 $442 $0 $186 $93218.06 Demolish and Backfill Unit 3 Fuel Handling Building Below -3 Feet $271 $696 $1,170 $0 $534 $2,67118.07 Demolish and Backfill Unit 3 Radwaste and Control Building Below -3 Feet $1,367 $3,268 $5,249 $0 $2,471 $12,35518.08 Demolish and Backfill Unit 3 Turbine Building Structure Below 9 Ft Elevation

$3,956 $9,277 $12,551 $0 $6,446 $32,23118.09 Demolish and Backfill Unit 3 Safety Equipment Building Below -3 Feet $717 $1,883 $2,713 $0 $1,328 $6,64118.10 Demolish and Backfill Unit 3 Penetration Area Below -3 Feet $294 $586 $1,285 $0 $541 $2,70618.11 Demolish and Backfill Unit 3 Full Flow Building Below -3 Feet $167 $527 $411 $0 $276 $1,38218.12 Demolish and Backfill Unit 3 Containment Building Below -3 Feet $1,211 $2,214 $4,636 $0 $2.015 $10,07718.13 Demolish and Backfill Unit 2 Condensate Storage Area Below -3 Feet $179 $305 $912 $0 $349 $1,74618.14 Demolish and Backfill Unit 2 Diesel Generator Builidng Below -3 Feet $130 $173 $442 $0 $186 $93218.15 Demolish and Backfill Unit 2 Fuel Handling Building Below -3 Feet $271 $696 $1,170 $0 $534 $2,67118.16 Demolish and Backfill Unit 2 Radwaste and Control Building Below -3 Feet $1,415 $3,308 $5,249 $0 $2,493 $12,46618.17 Demolish and Backfill Unit 2 Turbine Building Structure Below 9 Ft Elevation

$3,959 $9,277 $12,551 $0 $6,447 $32,23418.18 Demolish and Backfill Unit 2 Safety Equipment Building Below -3 Feet $717 $1,883 $2,713 $0 $1,328 $6,64118.19 Demolish and Backfill Unit 2 Penetration Area Below -3 Feet $294 $586 $1,285 $0 $541 $2,70618.20 Demolish and Backfill Unit 2 Full Flow Building Below -3 Feet $167 $527 $411 $0 $276 $1,38218.21 Demolish and Backfill Unit 2 Containment Building Below -3 Feet $1,211 $2,214 $4,636 $0 $2,015 $10,07718.22 Demolish and Backfill Intake Structure Below -3 Feet $6,664 $12,970 $36,706 $0 $14,085 $70,42618.23 Remove Off Shore Intake and Outfall Conduits

$12,406 $44,308 $19,580 $0 $19,073 $95,36718.24 Remove Sheet Piling and Excavation Shoring $11,776 $0 $0 $0 $2,944 $14,72118.25 Remove Dewatering System and Effluent Treatment

$0 $0 $0 $2,308 $577 $2,88518.26 Finish Grading and Re-Vegetate Site $945 $813 $0 $0 $440 $2,19818.27 Remove Temporary Structures

$58 $48 $0 $0 $16 $122Distributed Subtotal

$56,952 $119,889

$115,025

$11,959 $75,946 $379,772Undistributed 3.01 Utility Staff $7,082 $0 $0 $0 $1,771 $8,853Page 24 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusFuel Pool SystemsPOLModifiedUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Decommissioning Alternative DECONSpent Fuel Alternative DryRepository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total3.02 Security Guard Force $1,830 $0 $0 $0 $458 $2,2883.03 Security Related Expenses

$139 $0 $0 $0 $35 $1733.04 Insurance

$0 $0 $0 $2,948 $737 $3,6853.05 Site Lease and Easement Expenses

$0 $0 $0 $989 $148 $1,1373.06 Materials and Services

$0 $415 $0 $0 $104 $5193.07 Energy $0 $0 $0 $814 $204 $1,0183.08 Decommissioning General Contractor Staff $26,176 $0 $0 $0 $6,544 $32,7203.09 Craft Worker Training

$983 $0 $0 $0 $246 $1,2293.10 Workers Compensation Insurance

$0 $0 $0 $595 $149 $7433.11 Severance

$0 $0 $0 $2,050 $513 $2,5633.12 Property Tax $0 $0 $0 $4,946 $1,237 $6,1833.13 Utilities (Water, gas, phone) $0 $128 $0 $0 $32 $1603.14 Tools and Equipment

$0 $73 $0 $0 $18 $913.15 Non-Process Computers

$0 $165 $0 $0 $41 $2063.16 Teleconmunications

$0 $165 $0 $0 $41 $206Undistributed Subtotal

$36,211 $946 $0 $12,343 $12,276 $61,775SR Pd 5Subtotal$93,163$120,834$115,025$24,302$88,222$441,547Page 25 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageLicense StatusPOLUnit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/2013Decommissioning Alternative DECONSpent Fuel Alternative DryFuel Pool Systems ModifiedRepository Opening Date: 1/1/20242014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency TotalSR Pd 6 Final Site Restoration and Lease Termination Distributed 19.01 Obtain Required Permits and Approvals

$404 $20 $0 $131 $139 $69319.02 Install Temporary Structures

$6 $35 $0 $0 $6 $4819.03 Procure Site Restoration Equipment

$0 $404 $0 $0 $101 $50519.04 Install Temporary Seawall or Coffer Dam $8,551 $17,624 $0 $0 $6,544 $32,71819.05 Install Dewatering System and Effluent Treatment and Discharge Controls

$0 $0 $0 $1,427 $357 $1,78419.06 Remove and Stockpile Existing Seawall Erosion Protection

$6 $11 $0 $0 $4 $2119.07 Remove Unit 2 and 3 Seawall and Pedestrian Walkway $3,206 $3,060 $4,558 $0 $2,706 $13,53019.08 Remove Remaining Intake and Outfall Box Culvert $336 $468 $2,188 $0 $748 $3.73919.09 Remove Temporary Seawall or Coffer Dam $11,791 $143 $0 $0 $2,983 $14,91719.10 Backfill and Compaction of Excavation

$1,471 $2,238 $0 $0 $556 $4,26519.11 Remove Dewatering System and Effluent Treatment

$0 $0 $0 $592 $148 $74019.12 Install Shoreline Erosion Control and Restoration Features

$10 $144 $0 $0 $38 $19219.13 Remove Railroad Tracks, Rails and Ballast $63 $35 $0 $0 $24 $12219.14 Remove Gunite Slope Protection

$262 $366 $1,710 $0 $585 $2,92319.15 Remove Access Roads and Parking Lots $240 $181 $0 $0 $105 $52719.16 Finish Grading and Re-Vegetate Site $27 $28 $0 $0 $14 $6819.17 Remove Temporary Structures

$8 $7 $0 $0 $2 $18Distributed Subtotal

$26,380 $24,763 $8,456 $2,151 $15,061 $76,810Undistributed 3.01 Utility Staff3.04 Insurance 3.05 Site Lease and Easement Expenses3.06 Materials and Services3.07 Energy3.08 Decommissioning General Contractor Staff3.09 Craft Worker Training3.10 Workers Compensation Insurance 3.11 Severance 3.12 Property Tax3.13 Utilities (Water, gas, phone)$2,219$0$0$0$0$8,062$504$0$0$0$0$0$0$0$142$0$0$0$0$0$0$31$0$0$0$0$0$0$0$0$0$0$0$0$605$507$0$418$0$0$305$6,077$2,536$0$555$151$76$35$104$2,016$126$76$1,519$634$8$2,773$756$583$177$522$10,078$630$381$7,596$3,169$38Page 26 of 27 Table 1SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry StorageDecommissioning Alternative DECONSpent Fuel Alternative DryLicense Status POLFuel Pool Systems ModifiedRepository Opening Date: 1/1/2024Unit 2 Shut Down:Unit 3 Shut Down:6/7/20136/7/20132014 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total3.14 Tools and Equipment

$0 $24 $0 $0 $6 $31Undistributed SubtotalSR Pd 6 SubtotalC. Site Restoration Subtotal$10,785$37,165$243,198$1,763,742

$197 $0$24,960 $8,456$181,428

$186,230$10,446$12,597$233,951$566,786$5,307$20,367$177,997$26,735$103,545$1,022,804

$4,411,246 Total$505,191$757,925$817,601Page 27 of 27 2014 Decommissioning Cost Analysis of theSan Onofre Nuclear Generating Station Units 2 & 3Document No. 164001-DCE-001 Appendix EAnnual Cash Flow Table SONGS Annual Cost By AccountPrompt DECON Base Case, 2024 DOE Acceptance, Dry StorageUnit No: Unit 2 2014 Dollars in Thousands Year License Spent Fuel Site Restoration TotalTermination 201320142015201620172018201920202021202220232024202520262027202820292030203120322033203420352036203720382039204020412042204320442045204620472048$25,749$79,799$69,196$54,541$111,903$47,520$108,328$185,482$79,081$54,785$158,207$37,930$2,922$2,922$2,922$2,922$2,922$2,922$2,055$2,122$0$0$0$0$0$0$0$0$0$0$0$0$0$0$0$0$63,891$35,719$106,308$59,308$59,308$59,308$27,554$4,908$4,908$4,908$4,908$4,908$4,908$4,908$4,908$4,908$4,908$4,908$5,089$7,214$7,214$7,214$7,228$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$49,067$15,089$7,439$3,730$1,957$0$13,539$36$36$1,927$36$16,848$44,621$19,412$22,469$31,688$66,873$71,867$23,181$0$0$0$0$0$0$0$0$0$0$0$0$0$0$0$0$0$138,706$130,607$182,943$117,579$173,168$106,828$149,420$190,426$84,026$61,621$163,151$59,687$52,451$27,243$30,299$39,518$74,704$79,697$30,325$9,336$7,214$7,214$7,228$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665Page 1 of 4 SONGS Annual Cost By AccountPrompt DECON Base Case, 2024 DOE Acceptance, Dry StorageUnit No: Unit 2 2014 Dollars in Thousands Year License Spent Fuel Site Restoration TotalTermination 2049205020512052Total$0$0$0$0$1,034,230

$7,667$9,974$6,573$0$623,209$0$20,177$11,928$1,377$423,297$7,667$30,151$18,500$1,377$2,080,735 Page 2 of 4 SONGS Annual Cost By AccountPrompt DECON Base Case, 2024 DOE Acceptance, Dry StorageUnit No: Unit 32014 Dollars in Thousands Year License Spent Fuel Site Restoration TotalTermination 201320142015201620172018201920202021202220232024202520262027202820292030203120322033203420352036203720382039204020412042204320442045204620472048$26,566$78,964$74,096$61,451$40,631$86,348$96,521$120,873$194,090$135,313$114,581$26,874$2,922$2,922$2,922$2,922$2,922$2,922$2,055$2,122$0$0$0$0$0$0$0$0$0$0$0$0$0$0$0$0$66,105$40,156$112,024$64,405$64,405$64,405$29,675$4,908$4,908$4,908$4,908$4,908$4,908$4,908$4,908$4,908$4,908$4,908$5,089$7,214$7,214$7,214$7,228$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$49,067$15,969$9,390$25,227$3,799$0$13,908$2,135$575$2,467$1,511$36,778$40,655$21,676$25,848$20,945$117,321$116,672$25,501$0$0$0$0$0$0$0$0$0$0$0$0$0$0$0$0$0$141,739$135,089$195,509$151,083$108,835$150,753$140,104$127,916$199,574$142,688$121,000$68,560$48,485$29,507$33,678$28,776$125,151$124,503$32,645$9,336$7,214$7,214$7,228$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665$7,665Page 3 of 4 SONGS Annual Cost By AccountPrompt DECON Base Case, 2024 DOE Acceptance, Dry StorageUnit No: Unit 3 2014 Dollars in Thousands Year License Spent Fuel Site Restoration TotalTermination 2049205020512052$0$0$0$0$7,667$9,974$6,573$0$0$23,120$45,566$1,377$7,667$33,094$52,139$1,377Total$1,078,016

$652,987$599,507$2,330,511 Page 4 of 4 2014 Decommissioning Cost Analysis of theSan Onofre Nuclear Generating Station Units 2 & 3Document No. 164001-DCE-001 Appendix FSDG&E SONGS Decommissioning Costs (100%)

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

I. BACKGROUND As the 20% minority owner, SDG&E is contractually obligated to pay its 20% ownership share of decommissioning expenses for SONGS. These costs, outlined in the DCE, will beincurred by the decommissioning agent and SDG&E will receive invoicing for its proportional share.II. SDG&E COSTSTable F-1SDG&E SONGS DECOMMISSIONING COSTS (1,000's,

$2014)Total SDG&E Other/ TotalUnits 2 & 3 Labor Non-Labor CostsLicenseTermination

$3,832 $1,047 $4,879Spent FuelManagement

$2,729 $417 $3,147Management SiteRe $1,904 $401 $2,305Restoration Total $8,465 $1,865 $10,330In addition to SDG&E's 20% share of the costs outlined in the DCE, SDG&E also incursinternal costs related to its SONGS ownership.

SDG&E incurs 100% of these Labor and Non-Labor costs related to SDG&E's oversight activities.

These costs are apportioned into SCE'sDCE categories of License Termination, Spent Fuel Management, and Site Restoration bydetermining the percentage of costs SCE allocated to each category and multiplying SDG&E'sPage 1 of 5 Appendix FSDG&E SONGS Decommissioning Costs (100%)costs by that same percentage for each category.

SDG&E estimates that its total internal costsover the decommissioning period to be $10.33 million (2014$).a. SDG&E LABORThe first category, "SDG&E Labor" includes SDG&E staff who provide oversight ofSONGS costs and activities.

SDG&E's internal staffing efforts are expected to mirror sitestaffing where the three (3) full-time equivalents

("FTEs")

are reduced after 2016 to two (2)FTEs, then to one (1) FTE after 2025, and eventually to zero (0) FTEs after 2032. After 2032,invoicing and oversight activities are anticipated to be minor during this period. Once ISFSIdecommissioning is initiated on or around 2049, SDG&E plans to identify one (1) full-time equivalent through 2052.These costs are shown in Table F-1 under the column heading of "SDG&E Labor" andare apportioned into SCE's categories of License Termination, Spent Fuel Management, and SiteRestoration.

b. OTHER/NON-LABOR The second type of SDG&E-specific costs are "Other/Non-Labor",

which consist ofoutside decommissioning consultants and direct costs related to oversight activities.

To provide oversight of decommissioning activities, SDG&E has retained an externaldecommissioning consultant who has the expertise SDG&E requires.

The external consultant isutilized to a greater extent through 2016 and then the consultant services are tapered off annuallythrough 2025.SDG&E also incurs direct costs related specifically to SDG&E's oversight activities atSONGS. These costs, which include travel reimbursement, phone services,

training, and wirelessPage 2 of 5 Appendix FSDG&E SONGS Decommissioning Costs (100%)communication from SONGS, will coincide with the number of SDG&E SONGS oversight personnel FTEs.These costs are shown in Table F- 1 under the column heading of Other/Non-labor and areapportioned into SCE's categories of License Termination, Spent Fuel Management, and SiteRestoration.

III. CONCLUSION All of SDG&E's internal decommissioning costs presented in Table F-1 are separate anddistinct from the costs incurred by the decommissioning agent and invoiced to SDG&E.SDG&E will seek authority to access its nuclear decommissioning trust funds to pay forits proportional share of SONGS related decommissioning expenses and for its internaldecommissioning costs incurred through a Commission-approved advice letter process consistent with the terms of the SDG&E Master Trust Agreement, and relevant rules and regulations of theInternal Revenue Service and the Nuclear Regulatory Commission.

Page 3 of 5 SDG&E SONGS Detailed Annual Expenditures Base Case:Prompt DECON, Time Reasonable

Schedule, DOE Repository Opening 2024, Utility and DGC, Dry Storage(2014 Dollars in Thousands)

Account Totals Unit 2 Unit I T.1alS pent Fuel M a rtag am o ot 3491 so 01Site Restoration 1 $7611 "01 13 $1.14304-.94

$ 41 $235$4,016 $0 $823 $4,450 $0 $1,041 $8,465 $0 $1,86S $10,330Unit 2 Unit 3Fort 58.OW- Oý -.Oo 5715213 085 $0 4 0 08 01.1 0 50$Do W; 12 $08 $08 581 08 15 0 8 so S $08 08 02014 $24Q $0 $41 $122 $0 1 so 0. 128 $0 $5 SO 235 so $41 $122 so s3 S2 $0' $28 08 so $0201 1.25, $0 020 $S233 10 08 8o t $5 so$01 so, $0B 03 1 23 $123 $71 $15 $0 $5 $08 08 s$1133 so 141 120 0o $ $10 so 308 so3 1134 10 85 5200 $0 so 5 3 0 so $020S1 see so $77 $130 SO $23 $4 0 12 10 $6 so' 171 so 533 $138 $0 534 $0 so $4 S0 soso2010 $74 0o 34 $144 08 $24 so $0 $0 so! 0so So $13 so 567 $145 $0 036 50 so s0 so $0 s02019 $162 $0 $47 178 so 57 $0 so $21' s0 so $127 0 546$79 $0 $10 $1 0 121 50 0 so2020 S24 s0 $8 I11 s0 $1 so 08 so sot $01 s0 $174 so0 s0 11' $0 $1 $5 s0 50 so so $02021 $19 so $35 $13 08: $ 08 s0 so 08 08 $X12 $0 594 $13 $0 $1 $1 s0 so so so 020224 08 $M 12 $1 so so $5 so so 08 so 03 120 $0 $1 $1 so $0 $0 $0 $020 13 $0 $57 $ $52 $0- $0o so 11 8 S -12 512ozq1 $79 $51 $20 so 7 o $ 21O So $$1 $7 SoS 5s: 2"$ $1 $O So S2024 1139 0. $14 139! so 1 54.... $21 so SO' 8 $125, so $13 $20' $7' $08 so2025 $0 so 123 so! so 50 S so SO 8 $0O $0 s: ' $23 $0 08 $030 $0 $0 so $027 so $ 1 930 08 so 574 so 17 $.0 0 so9 7 08 I 130 so $0 50 so $0 $0 so $022 17 $1 $3 s$ 0 so so $0 s52027 $7 08so $1 127 01 50$ 1 7 10 .02030 7 so $ $3 so 0 8 51 0 so $10 5 10' $$ so $0 $21 50' so $70 so $5 $0 0 8 so20329 080 0 0 0' $ 0 0 $ 8 0' $s $0 $8 0 $0 08: $00 so $02 $0 $0 $0203 5 08 00 I $0 so so 08 08 0 so so0 0o $0 1 52034 $0 so $0 $ ' $0' so $0 so $7 30 08 08 $0 $01 50 $0 08 $0 $115 0 o 00 $022030 08 $ $0 $0 $1 08 so $0 so0 so! $$ 0 $0 $0 $ $25 so 0 $08 10 $0 $0 so so2036 $08 o8 0 $0 $0 008 $0 0 $ 9 $0 08 $0 0 $ $0 30 $0,14 08 $00 $ 0203 08 08 08 08 $0 SO' $0 SO' $0 so $0 $0o1 $0 so, to $0 $0o $0 $0108 $0203 08 08 so $0' 50 o so $0 so $0; to $0 so $0 $0' so s0 $0 08 so s0 $0 O' $0 so203$ so so $0 $0' to so $08 $0 $0 so; $0 8$ 8 $ 00 0$ 0 $ 023S~ so: 08 $w8$' $ 0 $ $0 8 so 08* $0 $0o0 $0 so $0$ $ 0 $0 so $0201$0 so 08 $0 so so so SO' $0 s0 $0 08 so so. 0 0ý 08 08 $0 so $0 $0 $0 $02542 so 08 $0 $0 $0' so so s0 s0 So 5 o 08 $0o0 $0 $0 so $0 $0 $0 $0 $0 so $0so4 $0o0 $0 $0ý so 0 so so $0 so soj $0 so ~ $0 $0' so so $0 $0 08 $0 $0 so so $203a $0 so so SO' $0' $0 $0 so so 08 $0 $0, $0 so 10 $0 so $0 $0 $0 $0o0 $0 s2049 s0 so $0 $0, $0 08 $0 so $0 so SO' so $0 $0' so 08 t0o0 $0 $0 $0 $0- 08 082047 so 08 to so so 08 08' $0 $0 $0 s5o $0$ $0 w $0 so $0' 08* $0 s $0 $0 $0 $0 s24 so $0 $0 $0, so so so 08 $0' $0 $0 $0 $0' so so $0 00ý 08 so $0 $0 $0 so $07048 so 08 08 $11 08! so $0 08 08 $0D $0' $0 $0 $0 $08 s11 08' $0 $08 $0 so $0' $08 $0204 08 so so, 50 $2 0111 08 so 5so so 08 $0i $06 08ý $40s o $0 83 $0$0 $0 so 08 o020451 $0, 08 5s2o0 1 50 8 1 8 0 8 0 0 2 8 $ $ 15 $0' $1 $0 so $02056 s0 08 08 $0 $08 $0 so 08 so $08 $0 08 $0 $0 $0 124 08' $1 $16 $0 s1o $0 08 082 51 .0o08 s $ 247 0.4 so, 514 1761 So' $15 $0 so SO' $162 $0 so4 $1240 $08 $5 81,12 so 8$41 so $0 $Page 4 of 5 SDG&E SONGS Detailed Annual Expenditures Base Cal Prompt DECON, Time Reasonable

Schedule, DOE Repository Opening 2024, Utility end DGC, Dry Storage(2014 Dollars in Thousands)

Account Totals unit 2 Unit 3 ToedUoeýs Termination1!3sI see.Resoratasion 1 7611 153 1.431 Sol $241 1 1,9041 N$"I1 $0 $523 S4,450 $0 $1,041 $8,466 $0 sI866 $10,360Unit 2 and 3 Total Unit 2 and 3 Project Totals20M3 1-0 SO 01 10S O1 0182: $3 $2362014 0474 $0 1243 so SI 12 SO 1$6 0 so 1007 5294 106 $9062015 5453 10 14 0240 $0 $137 $21 0 S10 1 0 10 s 0 W, 2 531 "M2016 26 5 u 66 0 ' 00 553 144 so1 541 10 SO so 532 0462 SO0 $0201,7 $19 so $100 1 S0 s 7 $0o so S1 SO $0 10 12 34 $15 5610201 $157 so $101 52 s0 s 1 so 10 10 10 10 10 $258 134' 10 0621 86 10 503 $107 80 SI1 $1 10 042 10 10. 10 $ $5173 543 10002020 146 10s $130 523 so S2 $5 10 so 10 10 s0 1007 525 10 15082021 S41$ 10 129 $260 0 $2 S1 S1 10 so 10 so $548 620 82 10762022 $404 10 $107 $41 so 13 12 10 111 10' 10 10 $511 so3 $13 106202 S309 W, .. ...0 $3 so SO ,, so ý 'S S5011 S" .... 56.2024 $264 10 02 M0 $0 $2 .124 10. 572 10 so 10 $261 S06 $116 154202 so 10 4 14 s1 1171 10 s? 1o0 10 10 512 56 16 02462026 51 $0 ST 166 10 $1 5153 so $15 10 10 10 $Is 16 1V66 124622$1ý4 so 12 107 10 $1, $157 $6 s 51G 06 1 151617 1172 $42029 $13 10 52 152 10 $ 5161 16 $16 so 1 0 14 1177 12462025 10 S0 10 120 10 10 5170 10* $1 06 10 so 110 136 Sts? 124662030 $10 so so 042 so $6 $176 $so Vs so so 1 542 t$10 2M2031 to 10 2: 100 10 $1 $172 10 $15 so 10 10 $0 101 V867 12462032 10 10 $6 $6 10 10 $6 10 10 s so s 10 10 $62033 so 10 $6 $6 10 $6 10 10 10 $6 10 10 so 1o 10 so2034 10 so so 10 10 10 10 10 $6 s0 so so so so so1 $2035 so 10 so 10 1o 10 1 so s $o so $ so 10 so 10 $62036 so 0 s$ 0 so so so so so so SO $6 $6 $6 SO1 1 $2037 so. so s so so so so so 0' SO' so so so , 50 s2113 so so SO' so s so" so w so SO' so so so: so $2020 so 00 10 10* 10 so 10 10 10 S* $6' 10 so 10 10 102020 0 1 0 1' 1 6 1 10O10 $6 10 10 00 10 10 $62040 so so$ so 10 10 so 10 10 10 $6 $6 $6 S' so $6 $201 o 1o 0 $6 1o $6 so 10 1 o S10 $ so 10 1o 1 So1204 0 so $6 s $o s1 s0 $ o 1 $6 o 6 10o 10 so $ so2003 0 so $ o 1 0 0 so 1 so $0 so w1 0 so $6 $6 s1 102046 1 so 1o 10 so so S00 SO1' $6 0 $6 10 $6 to 10 so2U7 10 $6 s0 510 0 so 6 10 10 10' 10' 10 so $6 102046 1 0 to 10 0 0 10 0 t 0o $ so 10 $6SO' so$ 102007 so so $6 $221 $s 1' 10 10 10 10 S10 so $0 $26 1 122050 SO' $ so 10 so $ 1&0 so 14 6 $0 s0 $6 $6 S10 S102w o s o $8 so s3 $87, "6 Si o t o$ $1 23 S2052 00 SO 1 54 00 $3 17 10 $0 14 $ W so $6 11' 1203 $253"3An1 so S1 T U170 U 6417' S1.164 is 451 0 1 S O S#t7 51",47 16 $2,3 IG.=Page 5 of 5