Testimony On 2016 SONGS 1 Decommissioning Cost Estimate

Transcription

1 Application No.: Exhibit No.: Witnesses: XXX SCE-04 Jose L. Perez (U 338-E) Testimony On 2016 SONGS 1 Decommissioning Cost Estimate Before the Public Utilities Commission of the State of California Rosemead, California March 1, 2016

2 SCE-04: Testimony on SONGS 1 Decommissioning Cost Estimate Table Of Contents Section Page Witness I. INTRODUCTION...1 J. Perez II. SONGS 1 DECOMMISSIONING PROJECT OVERVIEW...2 A. B. C. Decommissioning Requirements...2 Status SONGS 1 DCE Summary...3 Key Revisions...4 III SONGS 1 DCE...6 A. Major Assumptions Low-Level Radioactive Waste (LLRW) Disposal...6 Appropriateness and Conservatism of Contingency Factor...6 B. Cost Estimate For Remaining Decommissioning Work License Termination Period...8 a) b) Decon PD 7 Decommissioning During Fuel Storage Unit Decon PD 8 License Termination During Final Site Restoration Unit Spent Fuel Management Period...9 a) b) SNF PD 2 Dry Storage During Decommissioning Unit SNF PD 3 Dry Storage During Decommissioning Units 1, 2, & c) SNF PD 4 Dry Storage Only Units 1, 2, & i-

3 SCE-04: Testimony on SONGS 1 Decommissioning Cost Estimate Table Of Contents (Continued) Section Page Witness d) e) SNF D&D PD 1 ISFSI License Termination...10 SNF D&D PD 2 ISFSI Demolition Site Restoration Period...10 a) b) SR PD 7 Planning for Completion of Unit 1 Site Restoration...10 SR PD 8 Final Site Restoration and Lease Termination Unit IV. RECONCILIATION OF 2016 DCE TO THE 2012 DCE...12 A. Reconciliation of the DCEs Undistributed Costs...13 Full Removal of Offshore Intake/Discharge Conduits...14 License Termination Activities...15 Subsurface Structure Removal...15 Appendix SONGS 1 DCE Appendix 2 Witness Qualifications -ii-

4 SCE-04: Testimony on SONGS 1 Decommissioning Cost Estimate List Of Tables Table Table III-1 Cost Estimate for Remaining SONGS 1 Decommissioning Work Page 100% Share, 2014$ in Millions...8 Table IV-2 Increase in DCE 100% Share, $ in Millions...12 Table IV-3 Changes in 2016 SONGS 1 DCE 100% Share, 2014 $ in Millions...13 Table IV-4 Undistributed Expenses 100% Share, 2014$ in Millions...14 Table IV-5 License Termination Activities 100% Share, 2014$ in Millions iii-

5 SCE-04: Testimony on SONGS 1 Decommissioning Cost Estimate List Of Figures Figure Figure IV SONGS 1 DCE Compared to the 2012 SONGS 1 DCE 100% Share, $ Page in Millions iv-

6 I. INTRODUCTION This testimony demonstrates the reasonableness of the 2016 San Onofre Nuclear Generating Station Unit No. 1 (SONGS 1) Decommissioning Cost Estimate (DCE). 1 The 2016 SONGS 1 DCE will be utilized in Exhibit SCE-06 (Financial Testimony) to support the analysis regarding whether the SONGS 1 nuclear decommissioning trusts (NDTs) are sufficiently funded and whether additional customer contributions are required. The DCE will also serve as the basis for the Commission s reasonableness reviews of SONGS 1 decommissioning costs in the next NDCTP or reasonableness review proceeding designated by the Commission. In this testimony, SCE requests that the Commission approve the 2016 SONGS 1 DCE of $239.4 million (100% share, 2014$) as reasonable. 1 Southern California Edison Company (SCE) and San Diego Gas & Electric Company (SDG&E) own 80% and 20% interests in SONGS 1, respectively. SCE permanently retired SONGS 1 on November 30,

7 II. SONGS 1 DECOMMISSIONING PROJECT OVERVIEW A. Decommissioning Requirements As one of the Nuclear Regulatory Commission (NRC) licensees for SONGS 1, SCE has an obligation, under federal regulations, to decommission SONGS 1. 2 SCE does not own the site upon which SONGS 1, 2, & 3 are located. Instead, SCE is authorized to use the site under a grant of easement from the U.S. Department of the Navy (Navy) and an easement-lease from the California State Lands Commission (CSLC). These documents require SCE to decommission SONGS 1. 3 B. Status SCE has completed a large part of SONGS 1 decommissioning. With the permanent shutdown of SONGS 2&3, the remaining decommissioning work for SONGS 1 will be completed concurrently with SONGS 2&3 decommissioning. SCE plans to retain a decommissioning general contractor (DGC) to complete major SONGS 1, 2, & 3 decommissioning activities. 2 According to 10 C.F.R. 50.2, Decommissioning means to remove a facility or site safely from service and reduce residual radioactivity to a level that permits -- (1) Release of the property for unrestricted use and termination of the license. 10 C.F.R (a)(3) provides that, Decommissioning will be completed within 60 years of permanent cessation of operations. The regulation allows for an extension of this period for multi-unit sites, such as SONGS. 3 Paragraph 12 of the Grant of Easement with the Navy for the onshore site provides, That upon termination of the easement granted herein, the Grantees at their expense may remove, and if desired by the government, shall remove any and all improvements installed or constructed hereunder and shall restore the Premises to a condition satisfactory to the Director, Southwest Division, Bureau of Yards and Docks; except that the Grantees shall not be obligated to restore any natural material cut or filled in the necessary excavation and grading of the Premises. Upon termination of the easement, the Grantees shall also, if required by the Government, decontaminate the Premises and such surrounding area within the Reservation as may have been contaminated by the operation of the Nuclear Station. Paragraph 14 of the Easement Lease P.R.C. No with the California State Lands Commission for the site of the offshore circulating water conduits was amended in 2005 to no longer require the complete removal of the conduits. Under the amended agreement, SCE is required to remove all vertical structures that protrude above the seafloor, and to install mammal barriers over each resulting opening. The remainder of the conduits located below the seafloor will remain in place. SCE retains the liability for any required future removal of the conduits. 2

8 C SONGS 1 DCE 1. Summary The 2016 SONGS 1 DCE identifies the remaining decommissioning work to be completed at SONGS 1, as of January 1, The 2016 SONGS 1 DCE (Appendix 1) prepared by EnergySolutions is based on updated reviews of the known physical work remaining to be completed on-site and allowances for activities such as reactor pressure vessel (RPV) disposal for which detailed cost information is not yet available. SCE will continue to maintain and monitor the SONGS 1 spent fuel at the ISFSI until the spent fuel is removed for shipment to a Department of Energy (DOE) repository. SCE also installed 15 wells as part of the Nuclear Energy Institute (NEI) Ground Water Protection Initiative and will continue to monitor the ground water beneath the SONGS 1 site for the presence of tritium. The SONGS 1 offshore intake and discharge conduits have been modified and will remain in place consistent with an amendment to its easement-lease with the CSLC. 5 Notwithstanding, the DCE includes the cost for completely removing the conduits, because SCE retains the liability for any required future removal of the conduits. The DCE also includes costs for removal and disposal of the SONGS 1 RPV package at a licensed low level radioactive waste (LLRW) disposal facility. There are two LLRW disposal facilities that may be available to accept the SONGS 1 RPV package, EnergySolutions facility in Clive, Utah and Waste Control Specialists (WCS) facility in Andrews County, Texas. SCE, with the DGC, will 4 Phase I decommissioning activities were performed between July 1999 and December 2008, and included, (1) the decontamination, dismantling, and disposal of all contaminated and non-contaminated SONGS 1 equipment, components, and structures that were either installed above-ground or below-ground but above the water table, (2) the installation of low-density concrete within void spaces in structures below the water table to ensure stability of the site, and (3) the licensing and construction of a SONGS 1 spent fuel dry storage facility on the SONGS 1 site, the fabrication of dry storage canisters, and the loading and placement of all SONGS 1 spent fuel stored at SONGS and one canister of Greater Than Class C (GTCC) waste from SONGS 1 into the spent fuel dry storage facility. 5 Amendment of an Easement Lease P.R.C , California State Lands Commission to Southern California Edison Company and San Diego Gas & Electric Company, effective on November 1,

9 evaluate the possibility of shipping the SONGS 1 RPV package for permanent disposal at one of these facilities. The 2016 SONGS 1 DCE generally includes a 25% contingency for the remaining decommissioning work. The 25% contingency follows the 2012 SONGS 1 DCE adopted by the Commission in the 2012 NDCTP Key Revisions In prior decommissioning estimates, SONGS 1 decommissioning comprised a phased approach with: (1) Phase 1 involving major decommissioning activities, including the construction of the Independent Spent Fuel Storage Installation (ISFSI) and placing all SONGS 1 spent fuel on the ISFSI; (2) Phase II involving the maintenance and monitoring of the SONGS 1 spent fuel stored at the SONGS ISFSI and disposition of the offshore conduits; and (3) Phase III involving the removal of any remaining residual radioactivity required for SONGS 1 license termination with the NRC, and termination of the Navy easement, including final site restoration. With the commencement of SONGS 2&3 decommissioning, EnergySolutions conformed the 2016 SONGS 1 DCE to the format and methodology used for the more-recent 2014 SONGS 2&3 DCE, 7 including the same decommissioning cost categories and periods. Therefore, EnergySolutions used license termination, spent fuel management, and site restoration as the cost categories rather than the phased approach used in the 2012 DCE. Going forward, the decommissioning of SONGS 1, 2, & 3 will be coordinated as one decommissioning project with a DGC performing major decommissioning activities. Decommissioning of the ISFSI and termination of the licenses will occur once the DOE has removed all SONGS 1, 2, & 3 spent fuel from the ISFSI. As discussed in Exhibit SCE-01, the DCE includes an updated assumption that the DOE will commence removing spent fuel from the industry in 2028 with no impact to the completion of site restoration in Consistent with the 2028 assumption, and based on SCE s studies developed from the DOE Acceptance Priority Ranking & Annual Capacity Report (DOE/RW-0567), dated July 2004, SCE 6 D , Conclusion of Law No. 10, p A , SCE-01 Testimony on the Nuclear Decommissioning of SONGS 2&3 4

10 projects that the DOE will remove the last SONGS 1 spent fuel from the ISFSI in By 2049, all the SONGS 2&3 spent fuel would have been removed from the ISFSI and the remaining activities of the spent fuel management and site restoration periods to complete SONGS 1 decommissioning can be performed. These activities include: (1) removing and disposing of all remaining above-ground structures, except any the Navy requests be left in place; (2) dismantling and disposing of the ISFSI; (3) excavating and disposing of all remaining SONGS 1 below-grade appurtenances and structural foundations, including any remaining radioactively contaminated materials that exceed the NRC standard for license termination; (4) backfilling and compacting the void spaces left after removal of all below-grade structures and foundations; (5) submitting a license termination plan to the NRC and terminating the NRC license; (6) completing the final site restoration work; and (7) terminating the grant of easement from the Navy for the plant site. SCE projects that all decommissioning activities will be completed by 2051, approximately two years after the removal of all SONGS spent fuel from the SONGS ISFSI. As noted in Exhibit SCE-01, the projected dates discussed above are utilized only for the purpose of financial analysis and determining the sufficiency of the NDTs and customer contribution levels. It may be appropriate to adopt different assumptions for other planning purposes. 5

11 1 2 III SONGS 1 DCE A. Major Assumptions 1. Low-Level Radioactive Waste (LLRW) Disposal The 2016 SONGS 1 DCE assumes that only Class A, Class C, and GTCC LLRW still remain at SONGS 1. The estimated disposal cost for the remaining LLRW is $57.3 million (100% share, 2014$), which is incorporated in the cost categories and periods identified in Table III-1 below Appropriateness and Conservatism of Contingency Factor A 25% contingency is generally applied for the remaining decommissioning work. Contingencies are applied to cost estimates to account for unknown or unplanned occurrences during the performance of a project. Contingencies are defined in the American Association of Cost Engineers Project and Cost Engineers Handbook as, specific provision for unforeseeable elements of cost within the defined project scope; particularly important where previous experience relating to estimates and actual costs has shown that unforeseeable events which will increase costs are likely to occur. The consensus in the industry literature, including sources from the DOE 9 and the Association for the 8 The 2016 SONGS 1 DCE assumes that Class A LLRW will be shipped to the EnergySolutions LLRW disposal facility in Clive, Utah, under the terms of the Life-of-Plant Disposal Agreement that SCE has with EnergySolutions. The DCE also assumes that Class C waste will be shipped to the WCS facility in Andrews County, Texas, the only facility in the United States that will accept Class B or C LLRW from waste generators outside the Texas compact. The estimated volumes and costs incurred for the disposal of LLRW remaining at SONGS 1 are shown in the table below: SONGS 1 LLRW 100% Share, 2014 $ in Millions Line Volume Package Transport Burial Disposal 1 Class A 723 cu ft $0.0 $0.0 $0.1 $0.1 2 Class C 7,598 cu ft $0.5 $16.8 $36.3 $ GTCC 167 $0.0 $0.2 $3.4 $3.6 9 Chapter 11 of U.S. Department of Energy Decommissioning Implementation Guide DOE, G , March 28,

12 Advancement of Cost Engineering International (AACE), 10 is that a contingency factor for cost estimates in this stage of development should fall within a range of 15% to 30%. In a previous NDCTP, PG&E prepared a paper entitled, Technical Position Paper for Establishing an Appropriate Contingency Factor for Inclusion in the Decommissioning Revenue Requirements, dated February Based on industry and regulatory documents, the position paper concludes that it is appropriate to add a 25% contingency factor to estimated decommissioning costs because it provides reasonable assurance for unforeseen circumstances 11 that could increase decommissioning costs, and should not be reduced or eliminated simply because foreseeable costs are low. Accordingly, EnergySolutions applied a 25% contingency factor to develop the DCE. B. Cost Estimate For Remaining Decommissioning Work The testimony below briefly discusses the work to be performed in each period. Table III-1 summarizes the estimated costs for the SONGS 1 remaining decommissioning work as of January 1, Association for the Advancement of Cost Engineering International (AACE) Recommended Practice No. 18R-97, at p. 2 of For example, some activities in the remaining decommissioning work (such as reactor vessel segmentation, packaging, shipping, and disposal) are less familiar activities in the industry. In addition, no nuclear facility has performed environmental restoration work to the extent that SCE may be required to terminate the easement with the Navy. 7

13 Table III-1 Cost Estimate for Remaining SONGS 1 Decommissioning Work 100% Share, 2014$ in Millions Line Period No. Description Distributed Cost Undistributed Cost Total 1 2 License Termination 3 Decon Pd 7 Decommissioning During Fuel Storage Decon Pd 8 License Termination During Final Site Restoration Category Total Spent Fuel (SONGS 1 share) 8 SNF Pd SNF Pd 3 Dry Storage During Decommissioning SNF Pd 4 Dry Storage Only SNF D&D Pd 1 ISFSI License Termination SNF D&D Pd 2 ISFSI Demolition Category Total Site Restoration 16 SR Pd 7 Planning for Completion of Unit 1 Site Restoration SR Pd 8 Final Site Restoration and Lease Termination Category Total Grand Total License Termination Period a) Decon PD 7 Decommissioning During Fuel Storage Unit 1 In the 2016 SONGS 1 DCE, this period runs from The SONGS 1 RPV package is being temporarily staged in the northeast corner of the north industrial area (NIA). This period includes distributed costs primarily for disposing the SONGS 1 RPV package. After the DGC has been selected, the disposal options for the SONGS 1 RPV will be evaluated. The engineering and design for the selected disposal option will be implemented and the RPV package will be transported and disposed. Until this is completed, the RPV package will continue to require maintenance, such as radiological surveys and painting. The period also includes undistributed costs for insurance, NRC fees, and ground water monitoring. 8

14 b) Decon PD 8 License Termination During Final Site Restoration Unit 1 In the 2016 SONGS 1 DCE, this period runs from The activities in this period occur during the last two years of the decommissioning project, concurrent with site restoration activities. This period includes distributed costs for preparing and submitting the License Termination Plan to the NRC for review and approval. In addition, the Final Site Survey will be prepared, and subsequently submitted to and reviewed by the NRC and Oak Ridge Institute for Science and Education (ORISE). The period also includes undistributed costs for insurance, NRC fees, materials and services, and utility staff. 2. Spent Fuel Management Period a) SNF PD 2 Dry Storage During Decommissioning Unit 1 In the 2016 SONGS 1 DCE, this period runs The period does not include distributed costs (because there are no physical activities related to SONGS 1), 12 and only includes undistributed costs for nuclear liability insurance. b) SNF PD 3 Dry Storage During Decommissioning Units 1, 2, & 3 In the 2016 SONGS 1 DCE, this period runs from The period does not include distributed costs (because there are no physical activities related to SONGS 1), and includes only undistributed costs for insurance, NRC fees, utility staffing, health physics supplies, security force and related expenses, maintenance, materials and services, energy, and utilities (water, gas, and phone). c) SNF PD 4 Dry Storage Only Units 1, 2, & 3 In the 2016 SONGS 1 DCE, this period runs The period includes distributed costs for removing all SONGS 1 spent fuel and GTCC waste from the ISFSI. The SONGS 1 spent fuel and GTCC waste at the ISFSI will be loaded onto a transporter for shipment by DOE beginning in This period is similar to the previous period and will include the same type of undistributed costs associated with insurance, NRC fees, an increase in utility staffing, health physics supplies, 12 As discussed above, EnergySolutions conformed the 2016 SONGS 1 DCE to the format and methodology of the 2014 SONGS 2&3 DCE. Therefore, EnergySolutions included SNF PD 2 in the 2016 SONGS 1 DCE. However, there are no physical activities and associated distributed costs related to SONGS 1 in this period. 9

15 security force and related expenses, maintenance, materials and services, energy, utilities (water, gas, and phone), and in addition, includes expenses for the site lease and easement. d) SNF D&D PD 1 ISFSI License Termination In the 2016 SONGS 1 DCE, this period runs from The period includes undistributed costs for insurance, NRC fees, utility staffing, security force and related expenses, materials and services, energy, utilities (water, gas, and phone), and site lease and easement expenses. e) SNF D&D PD 2 ISFSI Demolition In the 2016 SONGS 1 DCE, this period runs from , when the ISFSI will be decommissioned. The period includes distributed costs for ISFSI decommissioning, which will be apportioned between SONGS 1 and SONGS 2&3 based on a weighted average of the quantity of spent fuel from each unit stored in the ISFSI throughout its useful life. The period also includes undistributed costs for utility staffing, health physics supplies, security force and related expenses, DGC staffing, training and supplies, materials and services, LLRW disposal, energy, and utilities (water, gas, and phone). 3. Site Restoration Period a) SR PD 7 Planning for Completion of Unit 1 Site Restoration In the 2016 SONGS 1 DCE, this period runs The period includes distributed costs related to the engineering, planning, and design activities that will take place for subsurface structure removal, final site grading, environmental impact analyses for lease termination and, if necessary, outfall conduit removal. The required permits and approvals for these activities also will be obtained. The period also includes undistributed costs for utility staffing, DGC staffing, and materials and services. b) SR PD 8 Final Site Restoration and Lease Termination Unit 1 In the 2016 SONGS 1 DCE, this period runs from The period includes distributed costs for installation of a dewatering system and excavation, removal, and disposal of several subsurface structures as required by the Navy. In addition, shoreline erosion control and restoration will be installed with the final grading and re-vegetation of the site. 10

16 The period also includes undistributed costs for utility staffing, DGC staffing, and materials and services. At the conclusion of this period, the SONGS site will be completely decommissioned, licenses terminated, site restoration completed, and Navy easement terminated. 11

17 IV. RECONCILIATION OF 2016 DCE TO THE 2012 DCE A. Reconciliation of the DCEs The 2016 SONGS 1 DCE of $239.4 million (100% share, 2014$) is for the remaining decommissioning work to be completed for SONGS 1, as of January 1, In the 2012 NDCTP, the 2012 SONGS 1 DCE of $182.3 million (100% share, 2011$) was determined to be reasonable by the Commission. The 2012 DCE included $12.4 million (100% share, 2011$) for work to be performed in Subtracting the $12.4 million from the 2012 DCE results in a remaining estimate of $169.9 million going forward. The difference between the 2012 and 2016 estimates is identified in Table IV-2 and discussed below. Table IV-2 Increase in DCE 100% Share, $ in Millions Line No. Item Estimate DCE $ DCE $ Increase $ There is an increase of $69.5 million from the 2012 DCE to the 2016 DCE for the remaining decommissioning work beyond January 1, The increase in the 2016 SONGS 1 DCE is due to the following decommissioning activities and items shown in Table IV-3 and Figure IV-1 below. 13 A , Workpapers for Exhibit SCE-1, SONGS 1 Cost Study for Remaining Decommissioning Work, December 2012 Table 2, page

18 Table IV-3 Changes in 2016 SONGS 1 DCE 100% Share, 2014 $ in Millions Line No. Item Variance 1 Undistributed costs Full removal of intake/discharge conduits License termination Subsurface structure removal (38.4) 5Misc Escalation Total increase 69.5 Figure IV SONGS 1 DCE Compared to the 2012 SONGS 1 DCE 100% Share, $ in Millions Undistributed Costs The 2012 DCE did not include certain necessary and unavoidable undistributed costs that SCE will be required to incur from for SONGS 1 decommissioning. The items identified in Table IV-4 have been included in the 2016 DCE: 13

19 Table IV-4 Undistributed Expenses 100% Share, 2014$ in Millions Line No. Item Variance 1 Insurance NRC Fees Energy, Utilities, & Other Ground Water Monitoring Lease/Easement Fees 0.1 6Total The insurance costs are based on information provided to EnergySolutions by SCE for nuclear property and liability, non-nuclear liability, workers compensation, and property insurance. 14 The NRC fees are based on NRC regulatory requirements ($230,000 per year) and NRC inspections ($110,000 per year). 15 Energy, utilities, and other costs were also provided by SCE. 16 Prior to the permanent retirement of SONGS 2&3, SCE was able to use the generation from SONGS 2&3 for SONGS 1 decommissioning energy requirements; therefore, energy costs were not included in prior SONGS 1 DCEs. The energy costs are based on SDG&E retail rates. The ground water monitoring costs ($30,000 for labor and $150,000 for analysis per year) are necessary for SCE to continue to implement the NEI Ground Water Protection Initiative. The easement fees are for the Navy easement for the SONGS 1 site. 2. Full Removal of Offshore Intake/Discharge Conduits Paragraph 14 of the Easement Lease P.R.C. No with the CSLC for the site of the offshore circulating water conduits was amended effective in 2005 to no longer require the complete removal of the conduits. The amended agreement required SCE to remove all vertical structures that protrude above the seafloor, and to install mammal barriers over each resulting opening. The remainder of the conduits located below the seafloor will remain in place. SCE retains the liability for any required 14 EnergySolutions 2016 Decommissioning Cost Analysis of the San Onofre Nuclear Generating Station Unit 1, dated February 16, 2016, Section 5.0, Item 19, page Id., Section 5.0, Items 16, 17, and 18, pages 19 and Id., Section 5.0, Item 20, page

20 future removal of the conduits. Accordingly, SCE has included the cost to comply with this potential liability in the current estimate. The cost in the 2016 DCE to completely remove and dispose of the conduits is $35.7 million. This estimate includes the cost for a survey and environmental assessment, engineering planning and design, permits and approvals, and the actual removal of the conduits. 3. License Termination Activities The 2012 SONGS 1 DCE included $4.5 million in 2011$ ($4.8 million in 2014$) for the ISFSI decommissioning, final site survey, NRC license termination, final site restoration, and Navy easement termination. The 2016 SONGS 1 DCE includes $15.2 million for these activities. Table IV-6 below provides a detailed breakdown of these expenses. Table IV-5 License Termination Activities 100% Share, 2014$ in Millions Line No. Item Estimate 1 ISFSI decommissioning License termination plan 0.7 3Final site survey NRC approval Environmental analyses for lease termination Equipment, final site grading, and shoreline protection Permits and approvals 0.4 8Total There is a $10.4 million variance in license termination expenses between the 2016 SONGS 1 DCE and 2012 SONGS 1 DCE (when the 2012 DCE is escalated to 2014$). The detailed breakdown of the license termination by EnergySolutions in the 2016 SONGS 1 DCE is consistent with activities identified in the 2014 SONGS 2&3 DCE. The estimates are based on EnergySolutions experience with decommissioning projects. 4. Subsurface Structure Removal The 2012 SONGS 1 DCE included $71.1 million in 2011$ ($75.7 million in 2014$) for the removal of foundations and subsurface structures. This scope includes the removal of the containment sphere foundation, sphere enclosure building foundation, miscellaneous storm drain systems, and 15

21 miscellaneous subsurface systems and foundations. The storm drain systems were assumed to be 100% contaminated and the miscellaneous system and foundations were assumed to be 10% contaminated. The contaminated structures were assumed to require disposal at a licensed LLRW facility. The 2016 SONGS 1 DCE identifies $37.3 million (2014$) for the removal of these foundations and subsurface structures. The 2012 DCE estimate is $38.4 million (2014$) higher than the 2016 DCE estimate. The 2016 DCE is lower due to a revised assumption that there will be less contamination of the structures and less of a need for LLRW disposal. This assumption is based on the decay of the radiological activity in the subsurface structures from the time of the shutdown of SONGS 1 in 1992 until the time for site restoration and removal of the subsurface structures in Therefore, a large part of the subsurface structure can be disposed of at a landfill rather than an LLRW disposal facility. 16

22 Appendix SONGS 1 DCE

23 Document No DCE Decommissioning Cost Analysis of the San Onofre Nuclear Generating Station Unit 1 Project No Revision 0 Prepared for: Southern California Edison Walnut Grove Avenue Rosemead, CA Prepared by: EnergySolutions, LLC 1009 Commerce Park Drive Suite 100 Oak Ridge, TN : Robert C. Woodard, Project Director Date Barry S. Sims, Technical Advisor Date X New Report Title Change Report Revision Report Rewrite Effective Date Electronic documents, once printed, are uncontrolled and may become outdated. Refer to Document Control authority for the correct revision. Appendix 1-1

24 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0 TABLE OF CONTENTS Section 1.0 Page EXECUTIVE SUMMARY INTRODUCTION Study Objective Regulatory Framework STUDY METHODOLOGY General Description Schedule Analysis Decommissioning Staff Waste Disposal Final Status Survey Contingency Cost Reporting SITE SPECIFIC TECHNICAL APPROACH Facility Description Decommissioning Status of Unit Decommissioning Periods Decommissioning Staff Spent Fuel Management Staff Spent Fuel Shipments BASES OF ESTIMATE AND KEY ASSUMPTIONS STUDY RESULTS REFERENCES FIGURES Figure 1-1 Summary Schedule...3 Figure 6-1 Summary Schedule...24 TABLES Table 1-1 Decommissioning Cost Summary...2 Table 6-1 Cost and Schedule Summary...25 Table 6-2 Decom Agent Levels...26 Table 6-3 DGC Staff Levels...27 Table 6-4 Waste Disposal Volumes...28 Page i Appendix 1-2

25 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0 APPENDICES Appendix A Appendix B Appendix C Appendix D Appendix E List of Systems and Structures Spent Fuel Shipping Schedule Detailed Project Schedule Detailed Cost Table Annual Cash Flow Table Page ii Appendix 1-3

26 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0 ACRONYMS AND ABBREVIATIONS AHSM AIF ALARA CFR CPM DAW DGC DOE DSC FEMA FSS FTE GE GSA GTCC HP IFMP ISFSI LLRW LLW LLWPA LOP MARSSIM MPC MWt NDT NRC NSSS ORISE PG&E PSDAR PWR RIF RPV SCE SONGS STRUCT WBS WCS UCF Advanced Horizontal Storage Modules Atomic Industrial Forum As Low As Reasonably Achievable Code of Federal Regulations Critical Path Method Dry Active Waste Decommissioning General Contractor U.S. Department of Energy Dry Shielded Canister Federal Emergency Management Agency Final Status Survey Full Time Equivalent General Electric U.S. General Services Administration Greater Than Class C Health Physics Irradiated Fuel Management Plan Independent Spent Fuel Storage Installation Low-Level Radioactive Waste Low Level Waste Low-Level Waste Policy Act Life-of-Plant Multi-Agency Radiation Survey and Site Investigation Manual Multi-Purpose Canister Megawatt thermal Nuclear Decommissioning Trust Nuclear Regulatory Commission Nuclear Steam Supply System Oak Ridge Institute for Science and Education Pacific Gas & Electric Post-Shutdown Decommissioning Activities Report Pressurized Water Reactor Reduction In Force Reactor Pressure Vessel Southern California Edison San Onofre Nuclear Generating Station Structure Work Breakdown Structure Waste Control Specialists LLC Unit Cost Factor Page iii Appendix 1-4

27 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision EXECUTIVE SUMMARY This report presents the 2016 Decommissioning Cost Estimate Study of the San Onofre Nuclear Generating Station (SONGS) Unit 1, hereinafter referred to as U1-DCE The San Onofre Nuclear Generating Station is operated by the Southern California Edison Company (SCE). This study is an update to the SONGS Unit 1 Cost Study for Remaining Decommissioning Work, dated March 2009 (Ref. No. 1). This study is integrated with the 2014 SONGS 2 & 3 DCE (Ref. No. 2) to ensure a consistent and efficient station decommissioning strategy. This study has been performed to furnish an estimate of the costs for: (1) decommissioning SONGS Unit 1 to the extent required to terminate the plant s operating license pursuant to 10 CFR 50.75(c); (2) post-shutdown management of spent fuel pursuant to 10 CFR 50.54(bb); (3) demolition of uncontaminated structures and restoration of the site in accordance with the United States Department of Navy Grant of Easement (Ref. No. 3); and the California State Lands Commission Easement Lease (Ref. No. 4); and (4) Independent Spent Fuel Storage Installation (ISFSI) decommissioning pursuant to 10 CFR EnergySolutions has established a Work Breakdown Structure (WBS) and cost accounting system to differentiate between these project accounts. All spent fuel from Unit 1 (and some Greater-than-Class-C (GTCC) waste generated during segmentation of the reactor vessel internals) was transferred to the ISFSI between October 2003 and September The spent fuel from Unit 1 that was stored in fuel pools at Units 2 and 3 was transferred to the ISFSI between May and June In total there are 395 spent fuel assemblies from Unit 1 stored in 17 Multi-Purpose Canisters (MPCs) at the ISFSI (plus one MPC containing GTCC waste). An additional 270 spent fuel assemblies from Unit 1 are being stored by General Electric-Hitachi Nuclear America, LLC (hereinafter GE) in their spent fuel pool located in Morris, Illinois (hereinafter GE-Morris). The 270 spent fuel assemblies were shipped to GE-Morris before the ISFSI was constructed. Per the SONGS Units 2 & 3 Irradiated Fuel Management Plan (IFMP), the costs associated with ongoing storage of Unit 1 spent fuel at GE-Morris are currently funded from sources other than the Nuclear Decommissioning Trusts (NDT). SCE s December 2012 testimony to the CPUC provided the basis for previous estimated spent fuel management costs, based on a DOE start date assumption of This report uses a DOE start date assumption of 2028; the adjustment was made to account for the four years since the 2012 testimony, with no progress by DOE that would make a 2024 start date a credible assumption. This study analyzes the following technical approach to decommissioning as defined by SCE: Deferred completion of decommissioning and final site restoration pending completion of the transfer to DOE of all spent fuel located at the ISFSI. A total of 395 Unit 1 spent fuel assemblies are being stored in transportable MPCs at the ISFSI. An additional 270 Unit 1 spent fuel assemblies are being stored at GE Morris (the cost of which is not included in this estimate). Page 1 Appendix 1-5

28 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0 A dry transfer facility will not be necessary for transfer of spent fuel canisters for transport. DOE begins accepting spent fuel from the industry in 2028 and completes the removal of Unit 1 spent fuel from the ISFSI by 2034, and from GE-Morris by Remaining Unit 1 decommissioning and site restoration activities will be performed by a Decommissioning General Contractor (DGC), concurrent with the decommissioning of Units 2 & 3, with oversight by an entity defined by the coparticipants, hereafter referred to as the Decom Agent. Incorporation of Life-of-Plant (LOP) Disposal Rates for Class A Low-Level Radioactive Waste (LLRW). Incorporation of disposal rates for Class B and C LLRW based on recent quotes for disposal at the Waste Control Specialists LLC (WCS) site in Andrews County, Texas. The cost estimate results are provided in Table 1-1. Table 1-1 gives License Termination costs (which correspond to 10 CFR (c) requirements); Spent Fuel Management costs (which correspond to 10 CFR (bb) requirements); Site Restoration costs (which correspond to activities such as clean building demolition and site grading and end-state preparation as required under the Site Easement) and ISFSI decommissioning pursuant to 10 CFR Table 1-1 Decommissioning Cost Summary (2014 Dollars in Thousands) Cost Account Total License Termination 50.75(c) $117,530 Spent Fuel Management 50.54(bb) $30,541 Site Restoration $91,365 Totals $239,436 The estimate is based on site-specific plant systems and buildings inventories. These inventories, and EnergySolutions proprietary Unit Cost Factors (UCFs), were used to generate required man-hours, activity schedule hours and costs, and waste volume, weight, and classification. Based on the activity schedule hours and a decommissioning activities analysis, a Critical Path Method (CPM) analysis was performed to determine the decommissioning schedules. These schedules reflect the effects of sequenced activity-dependent or distributed decommissioning elements such as planning and preparations, major component removal, building decontamination, and spent fuel shipping. The schedules are divided into project phases (periods) and presented, as noted previously, by cost account License Termination, Spent Fuel Management, or Site Restoration. The summary schedule is shown in Figure 1-1, and may also be found in Section 6.0 of this report. Page 2 Appendix 1-6

29 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0 Figure 1-1 Summary Schedule Page 3 Appendix 1-7

30 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision Study Objective 2.0 INTRODUCTION This report presents the 2016 Decommissioning Cost Estimate Study of the San Onofre Nuclear Generating Station (SONGS) Unit 1. The Unit 1 portion of the San Onofre Nuclear Generating Station is owned by the Southern California Edison Company (SCE) and the San Diego Gas & Electric Company (SDG&E). SCE is an 80% owner and SDG&E is a 20% owner. Unit 1 was operated by SCE on behalf of the co-participants. This study is an update to the SONGS Unit 1 Cost Study for Remaining Decommissioning Work, dated March 2009 (Ref. No. 1). This study, hereinafter referred to as the U1-DCE-2016, is integrated with the 2014 SONGS 2 & 3 DCE (Ref. No 2) to ensure a consistent and efficient station decommissioning strategy. This study develops and presents the Unit 1 apportioned estimated costs for: (1) decommissioning what remains of Unit 1 to the extent required to terminate the plant s operating license; (2) post-shutdown management of Unit 1 spent fuel until acceptance by the U.S. Department of Energy (DOE); (3) demolition of uncontaminated structures and restoration of the site in accordance with the U.S. Department of Navy Grant of Easement (Ref. No. 3), and the California State Lands Commission Easement Lease (Ref. No. 4); and (4) decommissioning and demolition of the Unit 1 portion of the ISFSI. The study methodology follows the basic approach originally presented in the Atomic Industrial Forum/National Environmental Studies Project Report AIF/NESP-036, Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates, (Ref. No. 5). The report was prepared in accordance with Nuclear Regulatory Commission (NRC) Regulatory Guide 1.202, Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors, (Ref. No. 6). The estimate is based on compliance with current regulatory requirements and proven decommissioning technologies. NRC requirements, set forth in Title 10 of the Code of Federal Regulations (CFR), differentiate between the post-shutdown costs associated with the decommissioning of the nuclear plant facility, those associated with storage of spent fuel on-site, and those associated with the decommissioning of the spent fuel storage facility. The Code of Federal Regulations, however, does not address the entire scope of the decommissioning liability for each nuclear facility. 10 CFR 50.75(c) requires funding by the licensee(s) of the facility for the decommissioning program, but specifically excludes the cost of removal and disposal of spent fuel and structures that do not require disposal as radioactive material. 10 CFR 50.75(c) also excludes the cost of site restoration activities that do not involve the removal of residual radioactivity necessary to terminate the NRC license(s). 10 CFR (bb) requires the licensee(s), within two years following permanent cessation of operation of the reactor or five years before expiration of the operating license(s), whichever occurs first, to submit written notification to the NRC for its review and preliminary approval of the program by which the licensee intends to manage and provide funding for the management of all irradiated fuel at the reactor upon expiration of the reactor operating license until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository. 10 CFR requires funding for decommissioning of the on-site spent fuel storage facility after the irradiated fuel is accepted by the DOE. Page 4 Appendix 1-8

31 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0 In addition to the NRC Decommissioning requirements described above, the Grant of Easement from the Government states: That upon termination of the easement granted herein, the Grantees at their own expense may remove, and if desired by the Government, shall remove, any and all improvements installed or constructed hereunder, and shall restore the Premises to a condition satisfactory to the Director, Southwest Division, Bureau of Yards and Docks; This estimate includes the costs for removal of all Unit 1 subsurface structures. This study analyzes the following technical approach to decommissioning as defined by SCE and the co-owners: Deferred completion of decommissioning and final site restoration pending completion of the transfer to DOE of all spent fuel located at the ISFSI. A total of 395 Unit 1 spent fuel assemblies are being stored in transportable Multi- Purpose Canisters (MPCs) at the ISFSI. An additional 270 Unit 1 spent fuel assemblies are being stored at GE Morris (the cost of which is not included in this estimate). A dry transfer facility will not be necessary for transfer of spent fuel canisters for transport. DOE begins accepting spent fuel from the industry in 2028 and completes the removal of Unit 1 spent fuel from the ISFSI by 2034, and from GE-Morris by Remaining Unit 1 decommissioning and site restoration activities will be performed by a Decommissioning General Contractor (DGC), concurrent with the decommissioning of Units 2 & 3, with oversight by the Decom Agent. Incorporation of Life-of-Plant (LOP) Disposal Rates for Class A Low-Level Radioactive Waste (LLRW). Incorporation of disposal rates for Class B and C LLRW based on recent quotes for disposal at the Waste Control Specialists LLC (WCS) site in Andrews County, Texas. 2.2 Regulatory Framework Provisions of current laws and regulations affecting decommissioning, waste management, and spent fuel management are as follows: 1. NRC regulations require a license for on-site storage of spent fuel. On-site dry storage of spent fuel at an ISFSI is licensed by either: (a) the general license set forth in 10 CFR , which requires that a Part 50 license be in place; or (b) a site-specific ISFSI license issued pursuant to 10 CFR Part CFR 50.75(c) requires funding by the licensee(s) of the facility for decommissioning CFR (bb) requires the licensee(s), within two years following permanent cessation of operation of the reactor or five years before expiration of the Page 5 Appendix 1-9

32 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0 operating license(s), whichever occurs first, to submit written notification to the NRC for its review and preliminary approval of the program by which the licensee intends to manage and provide funding for the management of all irradiated fuel at the reactor upon expiration of the reactor operating license until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository CFR 961 (Ref. No. 7), Appendix E, requires spent fuel to be cooled for at least five years before it can be accepted by DOE as standard spent fuel CFR requires funding by the licensee for termination of the ISFSI license. Decommissioning Alternatives The three basic methods for decommissioning are DECON, SAFSTOR, and ENTOMB, which are summarized as follows: 1. DECON: The equipment, structures, and portions of the facility and site that contain radioactive contaminants are promptly removed or decontaminated to a level that permits termination of the license after cessation of operations. 2. SAFSTOR: The facility is placed in a safe, stable condition and maintained in that state (safe storage). The facility is decontaminated and dismantled at the end of the storage period to levels that permit license termination. NRC regulations require decommissioning to be completed within 60 years of cessation of operation. 3. ENTOMB: Radioactive structures, systems, and components are encased in a structurally long-lived substance, such as concrete. The entombed structure is appropriately maintained and monitored until radioactivity decays to a level that permits termination of the license. Since entombment will exceed the requirement for decommissioning to be completed within 60 years of cessation of operation, NRC handles entombment requests on a case-by-case basis. Post-Shutdown Spent Fuel Management Alternatives The options for long-term post-shutdown spent fuel management currently available to power plant operators are: (1) wet storage consisting of continued maintenance and operation of the spent fuel pool, and (2) dry storage consisting of transfer of spent fuel from the fuel pool to onsite dry storage modules after a cooling period, or any combination of the two as is the present case at SONGS. Maintaining the spent fuel pool for an extended duration following cessation of operations prevents termination of the Part 50 license and typically has a higher annual maintenance and operating cost than the dry storage alternative. Transfer of spent fuel to an ISFSI requires additional expenditures for purchase and construction of the ISFSI and dismantlement and disposal of the ISFSI following completion of spent fuel transfer to DOE. The spent fuel shipping schedules furnished by SCE for this study are based on projections that DOE will commence accepting spent fuel from domestic commercial nuclear power plants in Page 6 Appendix 1-10

33 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision , and that the DOE will accept spent fuel at the rate published in DOE s July 2004 Acceptance Priority Ranking & Annual Capacity Report (DOE/RW-0567) (Ref. No. 8). SCE s December 2012 testimony to the CPUC provided the basis for previous estimated spent fuel management costs, based on a DOE start date assumption of This report uses a the DOE start date assumption of 2028; the adjustment was made to account for the four years since the 2012 testimony, with no progress by DOE that would make a 2024 start date a credible assumption. Page 7 Appendix 1-11

34 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision General Description 3.0 STUDY METHODOLOGY EnergySolutions maintains a proprietary decommissioning cost model based upon the fundamental technical approach established in AIF/NESP-036, Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates, dated May 1986 (Ref. No. 5). The cost model has been updated frequently in accordance with regulatory requirements and industry experience. The cost model includes elements for estimating distributed and undistributed costs. Distributed costs are activity specific and include planning and preparation costs as well as costs for decontamination, packaging, disposal, and removal of major components and systems. For example, costs for the disposition of the Unit 1 reactor vessel are distributed costs. Undistributed costs, sometimes referred to as collateral costs, are typically time dependent costs including, but not limited to Decom Agent and decommissioning general contractor staff, property taxes, insurance, regulatory fees and permits, energy costs, and security staff. The methodology for preparing cost estimates for a selected decommissioning alternative requires development of a site-specific detailed work activity sequence based upon the plant inventory. The activity sequence is used to define the labor, material, equipment, energy resources, and duration required for each activity. In the case of major components, individual work sequence activity analyses are performed based on the physical and radiological characteristics of the component, and the packaging, transportation, and disposal options available. In the case of structures, small components and equipment such as piping, pumps, and tanks, the work durations and costs are calculated based on UCFs. UCFs are economic parameters developed to express costs per unit of work output, piece of equipment, or time. They are developed using decommissioning experience, information on the latest technology applicable to decommissioning, and engineering judgment. The total cost of a specific decommissioning activity can be determined by multiplying the total number of units associated with that activity by the UCF, expressed as $/unit, for that activity. For example, the estimated demolition cost of a non-contaminated concrete structure can be obtained by multiplying the volume of concrete in the structure by the UCF for non-contaminated reinforced concrete demolition, expressed in $/unit volume. Each UCF has associated with it a man-hours/unit and schedule-hours/unit. From these values, total man-hours and total schedule-hours can be estimated for a particular activity. 3.2 Schedule Analysis After the work activity durations are calculated for all distributed activities, a critical path schedule analysis is performed using MS Project. The schedule accounts for constraints such as spent fuel cooling periods and regulatory reviews. The schedule is typically delineated into phases or time periods (hereinafter referred to as period or periods) that differentiate manpower requirements and undistributed costs. In order to differentiate between License Termination, Spent Fuel, and Site Restoration elements of the entire decommissioning scope of work, EnergySolutions has established a Work Breakdown Structure (WBS) and cost accounting system to treat each element as a subproject. Page 8 Appendix 1-12

35 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0 Accordingly, the overall project schedule is divided into interrelated periods with major milestones defining the beginning and ending of each period. The major milestones also serve as the basis for integrating the periods of the three subprojects. 3.3 Decommissioning Staff This U1-DCE-2016 assumes that the remaining Unit 1 decommissioning activities will be performed as part of an integrated SONGS site-wide program for decommissioning Units 2 & 3, spent fuel management, ISFSI decommissioning, and site restoration. This DCE is based on the work being performed by a qualified DGC with oversight and management of the decommissioning operations performed by the Decom Agent. It is also assumed that the Decom Agent will be supplemented by a professional engineering consulting firm. The sizes of the staffs are varied in each period in accordance with the requirements of the work activities. The SCE existing salary structure is the basis for calculating Decom Agent labor costs. EnergySolutions used industry data to develop DGC salary costs. Staffing has been organized into the following departments or functional groups: Decommissioning Engineering Maintenance and Work Control Oversight and Nuclear Safety Radiation Protection and Chemistry Regulatory and Emergency Planning Security Administration Security Guard Force Site Management and Administration Additional Staff for Spent Fuel Shipping DGC Staff 3.4 Waste Disposal Waste management costs comprise a significant portion of the decommissioning cost estimate. Waste Control Specialists (WSC) is currently the only licensed facility for receipt of Class B and C waste; WCS rate structure is used for estimating costs for Class B and C disposal. EnergySolutions approach to estimating waste disposal costs is discussed in the following paragraphs. Waste Classification Regulations governing disposal of radioactive waste are stringent in order to ensure control of the waste and preclude adverse impact on public health and safety. At present, LLRW disposal is controlled by 10 CFR 61, which went into effect in December This regulation stipulates the criteria for the establishment and operation of shallow-land LLRW burial facilities. Embodied within this new regulation are criteria and classifications for packaging LLRW such that it is acceptable for burial at licensed LLRW disposal sites. For each waste classification, 10 CFR 61 stipulates specific criteria for physical and chemical properties that the LLRW must meet in order to be accepted at a licensed disposal site. The Page 9 Appendix 1-13

36 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0 LLRW disposal criteria of 10 CFR 61 require that LLRW generators determine the proportional amount of a number of specific radioactive isotopes present in each container of disposable LLRW. This requirement for isotopic analysis of each container of disposable LLRW is met by employing a combination of analytical techniques such as computerized analyses based upon scaling factors, sample laboratory analyses, and direct assay methods. Having performed an isotopic analysis of each container of disposable LLRW, the waste must then be classified according to one of the classifications (Class A, B, C, or Greater Than Class C (GTCC)) as defined in 10 CFR 61. EnergySolutions classification of LLRW resulting from decommissioning activities is based on AIF/NESP-036 (Ref. No. 5), NUREG/CR-0130 (Ref. No. 10), NUREG/CR-0672 (Ref. No. 11), and recent industry experience. Information regarding the classification of waste in the Unit 1 Reactor Pressure Vessel was furnished by SCE. Packaging Selection of the type and quantity of containers required for Class B and C wastes is based on the most restrictive of either curie content, dose-rate, container weight limit, or container volume limit. GTCC wastes from segmentation of the reactor vessel internals is packaged in custom designed canisters. The selection of container type for Class A waste is based on the transportation mode (rail, truck, barge, etc.) and waste form. The quantity of Class A waste containers is determined by the most restrictive of either container weight limit or container volume limit. Large components, such as steam generators, pressurizers, and reactor recirculation pumps, are shipped as their own containers with additional shielding as required. Container costs are obtained from manufacturers specializing in the design and fabrication of storage containers for nuclear materials. Shielded transport cask and liner costs are obtained from the cask owners and operators. Transportation Transportation routes to processing and disposal facilities are determined based on available transportation modes (truck, rail, barge, or combinations). Transportation costs for the selected routes and modes are obtained from vendor quotes or published tariffs whenever possible. Class A Disposal Options and Rates In accordance with the existing Life-of-Plant Disposal Agreement (Ref. No. 12), all Class A waste that meets the waste acceptance criteria are to be disposed of at EnergySolutions LLRW disposal facility in Clive, Utah. All reported waste disposal costs include packaging, transportation, and any applicable surcharges. Class B and C Disposal Options and Rates Currently, within the United States, there are only three operational commercial near-surface disposal facilities licensed to accept Class B and C LLRW: the Barnwell facility, operated by EnergySolutions in Barnwell, South Carolina; the U.S. Ecology facility in Richland, Washington; and the recently licensed facility in Andrews County, Texas operated by Waste Page 10 Appendix 1-14

37 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0 Control Specialists. Barnwell only accepts waste from states within the Atlantic Compact and U.S. Ecology only accepts waste from states within the Northwest and Rocky Mountain Compacts. However, the WCS facility will accept waste from the Texas Compact (comprised of Texas and Vermont) and from non-compact generators. The Texas Compact Commission on March 23, 2012 approved amendments to rules allowing the import of non-compact generator LLRW for disposal at the WCS Andrews County facility. Greater Than Class C (GTCC) Wastes identified as 10 CFR 61 Class A, B, and C may be disposed of at near-surface disposal facilities. Certain components are highly activated and may exceed the radionuclide concentration limitations for 10 CFR 61 Class C waste. In accordance with 10 CFR 61, these components, which are referred to as Greater Than Class C (GTCC) wastes, cannot be disposed of in a near-surface LLRW disposal facility and must be transferred to a geologic repository or a similar site approved by the NRC. Highly activated sections of the reactor vessel internals will result in GTCC waste. Presently, a facility does not exist for the disposal of wastes exceeding 10 CFR 61 Class C limitations. EnergySolutions assumes that the DOE will accept this waste along with spent fuel. Although courts have held that DOE is obligated to accept and dispose of GTCC, issues regarding potential costs remain potentially unsettled. Therefore, EnergySolutions conservatively estimates a GTCC waste disposal cost. EnergySolutions assumes that the GTCC waste will be packaged in custom designed canisters and will be shipped to a storage or disposal facility operated by DOE along with the spent fuel. Additionally, EnergySolutions assumes shipping costs for GTCC waste to be equivalent to the commercial cost of shipping a Type B licensed, shielded cask such as the CNS 8-120B cask, which is owned and operated by EnergySolutions. LLRW Volume Reduction Because current Class A LLRW disposal rates are significantly lower than LLRW volume reduction rates, EnergySolutions does not assume on-site volume reduction techniques such as waste compaction or an aggressive decontamination, survey and release effort. Non-Radioactive Non-Hazardous Waste Disposal EnergySolutions assumes that recyclable, non-radioactive scrap metal resulting from the decommissioning program will be sold to a scrap metal dealer. However, no cost credit is assumed in the estimate for the value of the scrap metal. Clean (non-contaminated) concrete and demolition debris is assumed to be removed off site to an out of state Class III landfill consistent with the Governor of the State of California Executive Order D (Ref. No. 13). Hazardous and Industrial Waste Disposal Non-Radioactive contaminated surfaces coated with tightly adhering and undamaged lead based paint will be removed as non-hazardous building demolition debris. Any chemicals or hazardous materials present at Unit 1 will be removed and properly disposed of during decommissioning and site restoration. Page 11 Appendix 1-15

38 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision Final Status Survey The cost of performing a final status survey (FSS) is based on NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), (Ref. No. 14). Estimates of MARSSIM Class I, II, and III survey designations are based on radiological assumptions regarding contamination resulting from small and large component removal activities. The FSS activity cost calculation includes the in-place remote survey of underground metal and concrete pipe, soil, and groundwater sampling and analysis. Estimated costs for NRC and Oak Ridge Institute for Science and Education (ORISE) verification are also included, and the NRC review period is incorporated into the project schedule. 3.6 Contingency Contingencies are applied to cost estimates primarily to allow for unknown or unplanned occurrences during the actual program, e.g., increased radioactive waste materials volumes over that expected; equipment breakdowns, weather delays, and labor strikes. This is consistent with the definition provided in the DOE Cost Estimating Guide, DOE G , (DOE G) (Ref. No. 15). Contingency covers costs that may result from incomplete design, unforeseen and unpredictable conditions, or uncertainties within the defined project scope. EnergySolutions has applied a 25% contingency to all costs in this study, with the exception of Site Characterization Surveys at a 15% contingency. Extensive surveys performed during Phase I of SONGS Unit 1 decommissioning provide data to support a lower contingency for future surveys. 3.7 Cost Reporting Total project costs are aggregated from the distributed activity and undistributed costs into the following categories Labor, Materials and Equipment, Waste Disposal, and Other costs. Other costs include property taxes, insurance, license fees, permits, and energy. Waste Disposal costs are the summation of packaging, transportation, base disposal rate, and any applicable surcharges. Health physics (HP) supplies and small tool costs are calculated as a component of each distributed activity cost and included in the category of Material and Equipment, with the exception that HP supplies for the Decom Agent HP staff are calculated and reported as an undistributed line item. A line item specific contingency is then calculated for each activity cost element. Page 12 Appendix 1-16

39 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision Facility Description 4.0 SITE SPECIFIC TECHNICAL APPROACH The San Onofre Nuclear Generating Station Unit 1 site is located in southern California on the shore of the Pacific Ocean, about 62 miles Southeast of Los Angeles and approximately 51 miles Northwest of San Diego. The station is located entirely within the Camp Pendleton Marine Corps Base. The current Grant of Easement for the site from the United States Department of the Navy is currently scheduled to expire May 11, 2024 (Ref. No. 3). Units 2 & 3 occupy 52.8 acres of the 84 acre site. Approximately 16 acres are occupied by the North Industrial Area (formerly Unit 1), which is where the existing ISFSI is located. The facility currently has an existing ISFSI containing spent fuel that was transferred into MPCs to facilitate decommissioning of Unit 1. This study also assumes that the MPCs will be licensed under a 10 CFR Part 72 general license, using the manufacturer s Certificate of Compliance. The 10 CFR Part 50 license will be maintained until decommissioning is complete and all spent fuel has been transferred to DOE. 4.2 Decommissioning Status of Unit 1 Unit-1 was permanently retired on November 30, Following an evaluation in the fall of 1997 a decision was made to proceed with active decommissioning of Unit 1. In December of 1997, SCE and SDG&E advised the California Public Utility Commission (CPUC) and the U. S. Nuclear Regulatory Commission (NRC) of their intent to commence decommissioning Unit 1. SCE submitted an updated Post Shutdown Decommissioning Activities Report (PSDAR) to the NRC on December 15, Subsequently, in Decision D , the CPUC approved SCE's request to the CPUC to commence Unit 1 decommissioning. The following paragraphs describe the decommissioning phases implemented by SCE. Phase-I Decommissioning Phase I decommissioning activities were performed between July 1999 and December 2008, and included: (1) the decontamination, dismantling, and disposal of all contaminated and noncontaminated Unit 1 equipment, components, and structures that were either installed aboveground or below-ground but above the water table; (2) the installation of low-density concrete within void spaces in structures below the water table to ensure stability of the site; and (3) the licensing and construction of a spent fuel dry storage facility on the Unit 1 site, the fabrication of dry storage canisters, and the loading and placement of all Unit 1 spent fuel stored at SONGS and one canister of GTCC waste into the spent fuel dry storage facility. Phase-II Decommissioning Phase II Decommissioning commenced on January 1, 2009 upon completion of Phase I and will continue until all spent fuel has been removed from the ISFSI. Phase II of the Unit 1 decommissioning project will primarily consist of maintaining and monitoring the Unit 1 spent fuel in ISFSI until it is removed by the U.S. Department of Energy (DOE). SCE currently projects that the DOE will remove the last Unit 1 fuel from the site in Other Phase II activities will include the final disposition of the Unit 1 offshore conduits, and the disposition of the Unit 1 Reactor Pressure Vessel (RPV) as further discussed below. Page 13 Appendix 1-17

40 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0 Phase-III Decommissioning Phase III of Unit 1 decommissioning will include the removal of any remaining residual radioactivity as required to terminate the NRC License for the Unit 1 site, and removal of remaining site structures and improvements as required for final site restoration and termination of the easement-leases from the U.S. Department of the Navy (Navy). Phase III of Unit 1 decommissioning will be completed concurrently with Unit 2 & 3 decommissioning. This is not expected to occur until after the DOE removes the last spent fuel from Units 2 & 3 from the ISFSI, which is currently projected to occur in Unit 1 Reactor Pressure Vessel The Unit 1 RPV package, which contains both the RPV and many of the segmented pieces of the RPV s internal components, is grouted and sealed inside a large shipping container and is awaiting shipment to a disposal facility that is licensed to accept Class C LLRW. There are three options for U1 Reactor disposal 1) Ship via barge around cape horn to Texas, 2) Segment and ship over land to Texas, 3) Keep in the existing shipping container and utilize total volume averaging to allow for disposal in the class A disposal facility in Clive, UT. Due to the logistical challenges associated with shipping such a large, heavy, radioactive package, SCE believes it may be necessary to cut or segment the RPV package into several smaller, lighter pieces to allow transportation to the disposal site. SCE currently projects that, if necessary, it would perform the segmentation of the Unit 1 RPV package concurrently with the segmentation of the Units 2 & 3 RPVs. SCE believes that Options 1 & 3 above are the most likely scenarios for RPV disposal, and that a 25% contingency is appropriate. Segmentation of a Class C RPV package similar to the RPV has not been performed by the nuclear industry, and therefore, a 40% contingency is an appropriate value for Option 2. This study will be updated to reflect any changes in RPV disposal assumptions or methodology. Appendix A provides a list of the SONGS Unit 1 systems and structures included in the material inventory for this study. 4.3 Decommissioning Periods As described above, the basis for this estimate is that the completion of the Unit 1 decommissioning and site restoration activities will occur concurrently with Units 2 & 3 decommissioning and the ISFSI decontamination and demolition. The project periods consist of eight License Termination periods, seven Spent Fuel Management periods (two of which are ISFSI decontamination and demolition periods), and eight Site Restoration periods. As shown in Figure 1-1, the periods for each of these project areas are independent from (do not compete with) the periods for the other project areas. The project periods defined for this site-specific study and the major activities performed during each period are as follows: Page 14 Appendix 1-18

41 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0 License Termination Periods Decon Pd 1 Transition to Decommissioning Units 2 & 3 Activities Only Decon Pd 2 Decommissioning Planning and Site Modifications Units 2 & 3 Activities Only Decon Pd 3 Decommissioning Preparations and Reactor Internal Segmentation Units 2 & 3 Activities Only Decon Pd 4 Plant Systems and Large Component Removal Units 2 & 3 Activities Only Decon Pd 5 Building Decontamination Units 2 & 3 Activities Only Decon Pd 6 License Termination During Decommissioning Units 2 & 3 Activities Only Decon Pd 7 Decommissioning During Fuel Storage Unit 1 Engineering Analysis of Transportation and Disposal Options for Unit 1 RPV Engineering Planning and Design for Unit 1 RPV Disposition Transportation and Disposal of Unit 1 RPV Decon Pd 8 License Termination During Decommissioning Prepare License Termination Plan Unit 1 Perform Final Status Survey Unit 1 ORISE Verification and NRC Approval Unit 1 Spent Fuel Management Periods SNF Pd 1 Spent Fuel Transfer Management Transition Units 2 & 3 Activities Only SNF Pd 2 Dry Storage During Decommissioning Unit 1 Unit 1 portion of ISFSI Related Nuclear Property and Liability Insurance SNF Pd 3 Dry Storage During Decommissioning Units 1, 2, & 3 Operation, Maintenance and Surveillance of ISFSI SNF Pd 4 Dry Storage Only Units 1, 2, & 3 Operation, Maintenance and Surveillance of ISFSI SNF Pd 5 Dry Storage Only Units 2 & 3 Units 2 & 3 Activities Only SNF D&D Pd 1 ISFSI License Termination Preparation and NRC Review of License Termination Plan Page 15 Appendix 1-19

42 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0 SNF D&D Pd 2 ISFSI Demolition Verification Survey of Horizontal Storage Modules Clean Demolition of ISFSI AHSMs and Pads Clean Demolition of ISFSI Support Structures Restore ISFSI Site Preparation of Final Report on Decommissioning and NRC Review Site Restoration Periods SR Pd 1 Transition to Site Restoration Units 2 & 3 Activities Only SR Pd 2 Building Demolition During Decommissioning Units 2 & 3 Activities Only SR Pd 3 Subsurface Demolition Engineering & Permitting Units 2 & 3 Activities Only SR Pd 4 Building Demolition to 3 Feet Below Grade Units 2 & 3 Activities Only SR Pd 5 Subgrade Structure Removal Below 3 Feet Units 2 & 3 Activities Only SR Pd 6 Final Site Restoration and Easement Termination Units 2 & 3 Activities Only SR Pd 7 Planning for Completion of Unit 1 Site Restoration Subsurface Structure Removal Engineering Planning and Design Unit 1 Environmental Impacts Analyses for Lease Termination Activities Unit 1 Final Site Grading and Shoreline Protection Engineering Planning and Design Unit 1 Obtain Required Permits and Approvals Unit 1 SR Pd 8 Final Site Restoration and Easement Termination Unit 1 Install Dewatering System Unit 1 Excavate and Remove Slurry Backfill Unit 1 Excavate and Remove Containment Foundation Unit 1 Excavate and Remove Turbine Pedestal Foundation Unit 1 Excavate and Remove Circulating Water Structures Unit 1 Excavate and Remove Sewage Treatment Plant Unit 1 Excavate and Remove Auxiliary Feedwater Foundation and Trench Unit 1 Excavate and Remove Underground Utilities Unit 1 Excavate and Remove Storm Drains, Catch Basins and Manholes Unit 1 Remove and Stockpile Existing Seawall Erosion Protection Unit 1 Remove Seawall and Pedestrian Walkway Unit 1 Finish Grading and Re-vegetate Site Unit 1 Page 16 Appendix 1-20

43 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision Decommissioning Staff EnergySolutions developed staffing based on the assumption that decommissioning will be performed by an experienced and qualified DGC, with oversight and management of the decommissioning operations performed by the Decom Agent. It is also assumed that the Decom Agent will be supplemented by a professional engineering consulting firm. The sizes of the Decom Agent and DGC staffs are varied in each period in accordance with the requirements of the work activities. Details on the staff levels, by functional group, during each period are provided in Section Spent Fuel Management Staff The largest spent fuel staff is in place while the fuel pool is operational during the spent fuel cooling period and when the fuel assemblies are being transferred to dry storage. After all spent fuel has been removed from the spent fuel pool, the staff is reduced. During spent fuel pool operations and the dry storage period, the full-time spent fuel management staff is supplemented with part-time staff to support fuel movements. Details on the staff levels, by functional group, during each period are provided in Section Spent Fuel Shipments The spent fuel shipping schedules are based in part on the DOE s Acceptance Priority Ranking & Annual Capacity Report, dated July (Ref. No. 8). The information regarding existing fuel inventory, planned transfers to dry storage and DOE s projected date of 2028 for acceptance of spent fuel is based on information provided by SCE. The spent fuel shipping schedule is provided in Appendix B. The spent fuel shipment schedule is based upon best current information and assumptions, as qualified and described elsewhere in this study, including in Section 2.2 above. Page 17 Appendix 1-21

44 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision BASES OF ESTIMATE AND KEY ASSUMPTIONS The bases of, and key assumptions for, this site-specific decommissioning estimate are presented below: 1. All decommissioning cost data used in this study is current as of 2014 and uses 2014 $. Totals and subtotals have been rounded to significant figures. 2. EnergySolutions developed this estimate based on a project schedule integrated with Units 2 & 3 that commences on June 7, The decommissioning will be performed using currently available technologies. 4. DOE currently has no plans, program, or schedule in place for acceptance of spent fuel. However, for purposes of this decommissioning cost estimate, certain simplifying assumptions must be made regarding the schedule and rate of DOE performance. Therefore, while DOE s Standard Contract governing the acceptance of SCE s spent fuel allows for alternative removal schedules, including priority for shutdown reactors and exchanges of allocations, for purposes of this estimate DOE acceptance from the industry is assumed to commence in The spent fuel shipment schedules are based upon the assumption that the DOE will accept spent fuel at the rate published in DOE s July 2004 Acceptance Priority Ranking & Annual Capacity Report (DOE/RW-0567) (Ref. No. 8). 5. This estimate is based on building inventories derived from SCE furnished drawings of remaining above and below grade Unit 1 structures, the existing ISFSI and conceptual drawings of the ISFSI expansion required to transfer Units 2 & 3 spent fuel to dry storage. 6. Cost for transportation of clean scrap metal to a recycler is included in the estimate; however, no credit is taken for the value of the scrap metal. Concrete debris and all other demolition debris is assumed to be removed from the site and disposed of at an out of state Class III landfill, consistent with the Governor of the State of California Executive Order D (Ref. No. 13). 7. The estimate is based on final site restoration, in which all existing and proposed structures, with the exception of the switchyard, access roads and related communications will be removed. Clean demolition costs are based on the assumption that all site improvements will be removed in their entirety. Following demolition and removal of subsurface structures, clean backfill will be imported and placed to reestablish the existing grade. The entire disturbed area of the site will then be graded, to ensure proper management of storm-water runoff and seeded for stabilization and erosion protection. 8. All Class A waste is assumed to be disposed of at EnergySolutions facility in Clive, Utah, in accordance with the existing Life-of-Plant Disposal Agreement between EnergySolutions and Southern California Edison, dated January 18, 2014 (Ref. No. 12). The following 2014 disposal rates will be applied: Page 18 Appendix 1-22

45 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0 Demolition Debris and Soil - $57.97/Cubic Foot plus 5% Utah taxes Oversized Debris - $111.31/Cubic Foot plus 5% Utah taxes Containerized Waste Facility - $214.50/Cubic Foot plus 12% Utah taxes Large Components - $289.87/Cubic Foot plus 5% Utah taxes Cask Shipments - $44,059/Cask plus 12% Utah taxes Class A waste includes Dry Active Waste (DAW) arising from the disposal of contaminated protective clothing and health physics supplies. 9. Class B, C, and GTCC waste disposal costs are based on recent quotes for disposal of activated hardware and resins at the WCS facility. All resins and filter wastes are assumed to be Class B. 10. Shipping costs for the Class B and C waste are based on a distance of 1,079 miles one way from SONGS to the WCS site. 11. The spent fuel shipments are based upon best current information and assumptions, as qualified and described elsewhere in this study, including in Section 2.2 above. 12. The cost of maintenance and operation of the ISFSI is distributed between Units 1, 2, and 3 based on the relative percentages of spent fuel assemblies that will be in storage at the completion of the transfer of Units 2 & 3 fuel into dry storage. The percentages are 10%, 45%, and 45% for Units 1, 2, and 3, respectively. These percentages will be applied until all Unit 1 spent fuel has been transferred to DOE. The exception is that all property taxes are solely the liability of Units 2 & 3. Following completion of the transfer of Unit 1 spent fuel to DOE at the conclusion of SNF Pd 4 Dry Storage Only Units 1, 2, and 3, all ISFSI maintenance and operating costs are assigned to Units 2 & 3 until the ISFSI D&D. During ISFSI D&D costs are distributed to all three units in the same percentages of 10%, 45%, and 45%. 13. DOE has not committed to accept SCE s canistered spent fuel. But for purposes of this estimate, it is assumed that an SCE-funded dry storage facility will not be necessary. 14. Costs for ISFSI demolition are included in this estimate. SCE assumes that portions of the AHSM concrete will be activated. This cost is distributed between Units 1, 2, and 3 as stated in Item No. 12 above. 15. EnergySolutions has assumed that the 10 CFR Part 50 license will be maintained until DOE has taken possession of the spent fuel, and all radiological decommissioning activities have been completed, including decommissioning of the ISFSI. 16. EnergySolutions has included the annual NRC fees as required by 10 CFR (c)(2) for reactors in decommissioning of $231,000 per year until Unit 1 decommissioning is completed as a license termination expense. 17. EnergySolutions has included the annual NRC fees as required by 10 CFR (c)(2) for an ISFSI of $231,000 per year until decommissioning of the ISFSI is completed as a spent fuel management expense. This cost is distributed between Units 1, 2, and 3 as Page 19 Appendix 1-23

46 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0 stated in Item No. 12 above during the periods where Unit 1 spent fuel is stored in the ISFSI and during the ISFSI D&D period. 18. EnergySolutions has included NRC inspection fees during spent fuel management periods based on the type and level of activities being performed. This cost is distributed between Units 1, 2, and 3 as stated in Item No. 12 above during the periods where Unit 1 spent fuel is stored in the ISFSI. 19. Annual insurance premiums, in 2014 dollars as supplied by SCE, allocated to SONGS Unit 1 are as follows: Nuclear Property and Liability - $168,212 Additional Liability, Non-Nuclear - $33,565 Workers Compensation - $8,000 Property Insurance - $3, Site operating expenses expected to be incurred during spent fuel management and site restoration are included in the estimate. These costs include materials and services, utilities (water, gas, phone), telecommunications equipment, non-process computers, personal computers and tools and equipment. These costs were calculated based on information provided by SCE and adjusted by EnergySolutions to match the requirements of each period, based on staffing levels. These costs are distributed between Units 1, 2, and 3, as stated in Item No. 12 above, during the periods where Unit 1 spent fuel is stored in the ISFSI and during the ISFSI D&D period. 21. Decom Agent positions and average direct burdened salary (i.e., total compensation) data in 2014 dollars were supplied by SCE. 22. No severance costs are assigned to Unit DGC staff salaries, including overhead and profit, were determined by EnergySolutions and represent EnergySolutions standard assumptions for these rates. 24. The professional personnel used for the planning and preparation activities, and DGC personnel, are assumed to be paid per diem at the rate of $204/day, based on per diem rates from U.S. General Services Administration (GSA) for Orange County, California. 25. Craft labor rates were taken from the CA Union Craft Rate Sheet, dated January 9, Craft labor rates for disciplines not provided in the rate sheet have been taken from the 2014 RS Means Labor Rates for the Construction Industry (Ref. No. 16), for Anaheim, CA. Since the skilled laborers are assumed to be supplied by the local union hall, they will not be paid per diem. 26. The security guard force included in this estimate has been sized in accordance with the current Design Basis Threat assessment. 27. This study follows the occupational exposure principles of As Low As Reasonably Achievable (ALARA) through the use of productivity loss factors that incorporate such Page 20 Appendix 1-24

47 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0 items as the use of respiratory protection and personnel protective clothing. These factors increase the work duration and cost. 28. The costs of all required safety analyses and safety measures for the protection of the general public, the environment, and decommissioning workers are included in the cost estimates. This reflects the requirements of: 10 CFR 20 Standards for Protection Against Radiation 10 CFR 50 Domestic Licensing of Production and Utilization Facilities 10 CFR 61 Licensing Requirements for Land Disposal of Radioactive Waste 10 CFR 71 Packaging of Radioactive Material for Transport 10 CFR 72 Licensing Requirements for the Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste 29 CFR 1910 Occupational Safety and Health Standards 49 CFR Department of Transportation Regulations Governing the Transport of Hazardous Materials Reg. Guide Assuring the Availability of Funds for Decommissioning Nuclear Reactors 29. Activity labor costs do not include any allowance for delays between activities, nor is there any cost allowance for craft labor retained on site while waiting for work to become available. Page 21 Appendix 1-25

48 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision STUDY RESULTS This study analyzes the following technical approach to decommissioning as defined by SCE: Deferred completion of decommissioning and final site restoration pending completion of the transfer to DOE of all spent fuel located at the ISFSI. A total of 395 Unit 1 spent fuel assemblies are being stored in transportable Multi- Purpose Canisters (MPCs) at the ISFSI. An additional 270 Unit 1 spent fuel assemblies are being stored at GE Morris (the cost of which is not included in this estimate). A dry transfer facility will not be necessary for transfer of spent fuel canisters for transport. DOE begins accepting spent fuel from the industry in 2028 and completes the removal of Unit 1 spent fuel from the ISFSI by 2034, and from GE-Morris by Remaining Unit 1 decommissioning and site restoration activities will be performed by a DGC, concurrent with the decommissioning of Units 2 & 3, with oversight by the Decom Agent. Incorporation of Life-of-Plant (LOP) Disposal Rates for Class A Low-Level Radioactive Waste (LLRW). Incorporation of disposal rates for Class B and C LLRW based on recent quotes for disposal at the Waste Control Specialists LLC (WCS) site in Andrews County, Texas. Spent Fuel Shipping Schedule The spent fuel shipping schedule is provided in Appendix B. Spent fuel shipments from the industry to DOE will begin in The spent fuel shipment schedules are based upon best current information and assumptions, as qualified and described elsewhere in this study. Cost and Schedule Figure 6-1 is a summary project schedule. A detailed schedule is provided in Appendix C. Table 6-1 summarizes the period durations and total costs, including contingency, for License Termination, Spent Fuel, and Site Restoration activities. A detailed cost table is provided in Appendix D, and a table of annual expenditures is provided in Appendix E. Project Staffing This scenario is based on the assumption that decommissioning will be performed by an experienced and qualified DGC, with oversight and management of the decommissioning operations performed by the Decom Agent. Decom Agent staffing levels, by organizational department and function, for each period are provided in Table 6-2. The DGC staffing levels, by organizational department and function, for each period are provided in Table 6-3. Page 22 Appendix 1-26

49 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0 LLRW Disposal Volumes LLRW disposal is a significant element of the decommissioning project. The estimated cubic feet of waste are summarized as follows: Class A 723 Class B & C 7,598 GTCC 167 Waste disposal volumes and costs, itemized by packaging, transportation, surcharges and disposal costs by waste class and facility, are provided in Table 6-4. The waste disposal costs provided in Table 6-4 do not include contingency. Page 23 Appendix 1-27

50 2016 Decommissioning Cost Analysis of the Document No DCE-017 San Onofre Nuclear Generating Station Unit 1 Revision 0 Figure 6-1 Summary Schedule Page 24 Appendix 1-28