Application No.: A.15-01-XXX Exhibit No.: SCE-1 Witnesses: T. Palmisano E. Avella J. Perez (U 338-E) Testimony and Preliminary Report of Southern California Edison Company Regarding 2014 Expenses for San Onofre Nuclear Generating Station (SONGS) Unit Nos. 2&3 Before the Public Utilities Commission of the State of California Rosemead, California January 30, 2015
52
Embed
Testimony and Preliminary Report of Southern California Edison … · Regarding 2014 Expenses for SONGS Unit Nos. List Of Figures Figure Page -iv- Figure IV-1 SONGS Workforce .....8
This document is posted to help you gain knowledge. Please leave a comment to let me know what you think about it! Share it to your friends and learn new things together.
Transcript
Application No.: A.15-01-XXX Exhibit No.: SCE-1 Witnesses: T. Palmisano
E. Avella J. Perez
(U 338-E)
Testimony and Preliminary Report of Southern California Edison Company Regarding 2014 Expenses for San Onofre Nuclear Generating Station (SONGS) Unit Nos. 2&3
Before the
Public Utilities Commission of the State of California Rosemead, California
January 30, 2015
Testimony and Preliminary Report of Southern California Edison Regarding 2014 Expenses for SONGS Unit Nos. 2&3
Table Of Contents
Section Page Witness
-i-
I. INTRODUCTION .............................................................................................1 J. Perez
A. Purpose of Testimony and Summary of Request ...................................1
B. Timing Of SCE’s Preparation Of Preliminary Information ...................1
II. PROCEDURAL BACKGROUND ....................................................................3
III. REASONABLENESS DETERMINATION OF 2014 EXPENSES .................5
IV. OVERVIEW OF SONGS DECOMMISSIONING ORGANIZATION & ACTIVITIES ..................................................................7 T. Palmisano
A. Summary of NRC Decommissioning Phases ........................................7
B. SONGS Workforce And Work Groups And Activities .........................7
a) Decommissioning & Regulatory Affairs .....................10
b) Decommissioning Communications, Strategic Planning, and Analysis .................................12
2. Summary of Decommissioning Organization ..........................12
V. RECONCILIATION OF DECOMMISSIONING EXPENSES TO THE DCE .........................................................................................................13 J. Perez/E. Avella
A. Summary and Reconciliation of 2014 Costs ........................................15
B. Activity Descriptions and Variance Explanations of O&M Expenses ..............................................................................................18
Figure IV-4 SONGS Mesa Site – 2014......................................................................................................35
Testimony and Preliminary Report of Southern California Edison Regarding 2014 Expenses for SONGS Unit Nos.
List Of Tables
Table Page
-v-
Table V-1 Preliminary Comparison Of 2014 Recorded And Forecast Expenses To The
DCE (2014 Dollars in Millions, 100% Level) .....................................................................................16
Table V-2 Preliminary Comparison Of 2014 Recorded And Forecast Expenses To The
DCE By Category (2014 Dollars in Millions, 100% Level) ...............................................................17
1
I. 1
INTRODUCTION 2
A. Purpose of Testimony and Summary of Request 3
The purpose of this testimony is to provide preliminary information1 supporting the Application 4
of Southern California Edison Company (SCE) for a reasonableness review of SONGS 2&3 expenses 5
incurred during 2014. In Decision (D.) 14-11-040 (SONGS OII Decision), the Commission directed 6
SCE and San Diego Gas & Electric Company (SDG&E) (collectively referred to as the Utilities) to file, 7
within 60 days of the effective date of that decision, an application for review of 2014 SONGS 2 & 3 8
expenses.2 The Commission subsequently extended the application due date to January 30, 2015. In this 9
Application, SCE respectfully requests the Commission find that 2014 expenses of $221.3 million 10
(2014$, 100% level) for San Onofre Nuclear Generating Station (SONGS) Units No. 2&3 are 11
reasonable. 12
B. Timing Of SCE’s Preparation Of Preliminary Information 13
Given the deadline’s proximity to year-end 2014, SCE is not yet able to provide final, complete 14
cost information and variance explanations redundant, for a reconciliation of those expenses to the 15
SONGS 2&3 decommissioning cost estimate (DCE) submitted in Application (A.) 14-12-007. In 16
particular, SCE did not complete and submit the DCE to the U.S. Nuclear Regulatory Commission 17
(NRC) until September 2014. Therefore, SCE initially was not able to track 2014 expenses to the DCE, 18
and instead tracked those expenses from its general ledger to its 2014 SONGS budget using the 19
company’s SAP accounting system. As explained below in Section V, SCE needed to reconfigure its 20
accounting system to track expenses to the DCE and by the Work Breakdown Structure (WBS)3 created 21
for the decommissioning project. Beginning January 1, 2015, SCE will manage the decommissioning 22
work and tracking of expenses using the Decommissioning Project Cost System (DPCS). SCE is in the 23
process of remapping recorded expenses to the WBS using the new DPCS. SCE anticipates having this 24
1 In this testimony, SCE is providing recorded expenses through October and forecast expenses for November
and December.
2 D.14-11-040, Ordering Paragraph (OP) No. 4.
3 A work breakdown structure is a project management and cost accounting discipline used to track work and its cost in detail.
2
process complete within the next month. SCE will submit by April 1, 2015 an updated exhibit providing 1
final 2014 recorded cost information and variance explanations, as provided in D.14-11-040.4 2
In addition, the Commission has directed SCE to work with SDG&E, Energy Division, and other 3
interested parties concerning the tracking and reporting of decommissioning expenses and variances: 4
SCE shall organize a meeting . . . to work with Energy Division, San Diego Gas & Electric 5 Company and other interested parties to determine how SCE’s cost accounting system for 6 San Onofre Nuclear Generating Station Units 2 and 3 appropriately facilitates tracking 7 decommissioning expenditures by major subprojects within a decommissioning phase, allows 8 for comparison to previously approved estimates of activities, costs, and schedule . . .5 9
With the assistance of Energy Division and SDG&E, SCE will organize and conduct a decommissioning 10
cost accounting workshop for all interested parties, to fulfill this requirement and explain the cost-11
accounting system SCE is utilizing to establish “a more transparent accountable format for cost 12
disclosure by SCE,” as referenced in D.14-12-082.6 SCE will schedule this workshop, and notify parties 13
in A.14-12-007 and/or the docket established for this Application. During the workshop, SCE will 14
explain the DPCS, and how it will be utilized to track costs. 15
Chapter II of this testimony provides the procedural background associated with the 16
Commission’s recent review of SONGS costs. Chapter III addresses issues the Commission should 17
consider in its reasonableness determination for 2014 SONGS 2 & 3 expenses. Chapter IV provides an 18
overview of the SONGS decommissioning organization and activities. Chapter V reconciles 2014 19
expenses to the DCE, providing a summary of 2014 expenses by major project area and an explanation 20
of variances between these expenses and the DCE, based upon information available at this time. 21
4 D.14-11-040, OP No. 4.
5 D.14-12-082, OP No. 5.
6 D.14-12-082, p. 3.
3
II. 1
PROCEDURAL BACKGROUND 2
Pursuant to California Public Utilities Code Section 455.5, the Commission issued an Order 3
Instituting Investigation (OII) on October 25, 2012, initiating a multi-part investigation into the actions 4
and expenses of the Utilities associated with the extended outages at SONGS.7 A year and a half later 5
following the parties’ submissions on various issues, two evidentiary hearings, and other procedural 6
matters, SCE, SDG&E, The Utility Reform Network (TURN), Office of Ratepayer Advocates (ORA), 7
Friends of the Earth (FOE), and California Coalition of Utility Employees (CCUE) (collectively referred 8
to as the Settling Parties), filed and served on April 3, 2014 a Joint Motion for Adoption of Settlement 9
that would resolve all issues in the OII and related proceedings. Later, on September 24, 2014, the 10
Settling Parties submitted an Amended and Restated Settlement Agreement, agreeing to certain 11
modifications requested by the assigned Commissioner and Administrative Law Judges for the OII. On 12
November 25, 2014, the Commission issued D.14-11-040 approving the Amended and Restated 13
Settlement Agreement.8 As noted above, Ordering Paragraph 4 directs SCE to file this Application.9 14
On December 21, 2012, in a separate proceeding (not consolidated with the OII) concerning 15
SONGS decommissioning expenses, SCE and SDG&E filed a joint application for the 2012 Nuclear 16
Decommissioning Cost Triennial Proceeding (NDCTP). On December 22, 2014, the Commission 17
issued D.14-12-082. In the decision, the Commission seeks to establish through further discussions and 18
workshops “a more transparent and accountable format for cost disclosure by SCE when estimating and 19
directs SCE to organize a meeting, within 60 days of the date the decision is issued,10 to work with 21
Energy Division, SDG&E, and other interested parties to explain SCE’s cost accounting for SONGS 22
2&3 decommissioning expenses.11 Ordering Paragraph No. 6 requires SCE to develop, in consultation 23
7 D.14-11-040.
8 Although issued November 25, 2014, the effective date of D.14-11-040 is November 20, 2014.
9 D.14-11-040, OP No. 4.
10 The workshop needs to be organized by February 20, 2015 unless otherwise directed by the Commission.
11 D.14-12-082, OP No. 5.
4
with the Energy Division and other interested parties, a cost categorization structure for tracking 1
decommissioning expenses, including the ability to compare actual recorded expenses to the most 2
recently submitted DCE.12 3
On December 10, 2014, SCE and SDG&E jointly filed A.14-12-007, which among other things, 4
requests the Commission to approve: (1) the SONGS 2&3 decommissioning cost estimate; (2) SCE’s 5
request to reduce annual contributions to the SONGS 2&3 decommissioning trusts to zero at this time; 6
(3) an advice letter process for authorizing disbursements from the trusts; and (4) an annual 7
reasonableness review process for the expenses incurred for SONGS 2&3 decommissioning activities 8
completed during each year. If approved, this process will allow for more frequent review of 9
decommissioning activity costs. SCE will utilize the DCE submitted in A.14-12-007 to identify and 10
explain cost variances between 2014 recorded expenses and the DCE. 11
12 D.14-12-082, OP No. 6.
5
III. 1
REASONABLENESS DETERMINATION OF 2014 EXPENSES 2
The decommissioning of SONGS is an extremely complex undertaking involving several 3
discrete major activities and thousands of sub-activities. Evaluating the reasonableness of 4
decommissioning expenses without considering how the overall expenses compare to the overall 5
estimate, ignores the nature of estimates and overall project expenses. There will always be some 6
variances between estimated and recorded expenses for each discrete activity within a project. SCE 7
expects the costs of many activities in the DCE to match very closely what is estimated in the DCE. It is 8
important for the Commission to recognize, however, that some estimates in the DCE pertain to 9
activities and associated costs that, by their nature, could vary significantly from what is currently 10
estimated. Therefore, for a project of this scope, SCE reasonably expects to be able to utilize savings 11
from underruns (along with contingency) for certain activities, to offset expenses for other activities that 12
are more than estimated. As required by the Commission, SCE will provide adequate evidence that the 13
decisions it makes in the decommissioning of SONGS are prudent and in the ratepayers’ interest. 14
Prudence of an activity for which recorded expenses exceed the corresponding estimate should be 15
judged on the basis of the decisions made for that activity and its impact on the overall project, not 16
solely on activity-by-activity review and the fact that the expenses incurred for a certain discrete activity 17
exceeded the estimate for that activity. 18
In D.03-10-015, the Commission adopted criteria for determining the completion of 19
decommissioning work: 20
A decontamination and dismantling activity is complete if: (1) the activity has been 21 completed in its entirety, or (2) the activity has eliminated a specifically identifiable 22 decommissioning liability. 23
Decommissioning liability is eliminated when material is removed from the SONGS site. 24 For Independent Spent Fuel Storage Installation (ISFSI) design, licensing, and construction 25 work, completed work satisfied a defined regulatory activity or construction milestone. 26 (A.02-03-039, Exhibit SCE-1, p. 13).13 27
13 D.03-10-015, p. 34.
6
SCE anticipates that the Commission generally will apply the same criteria for completed work 1
on the SONGS 2&3 decommissioning project. SCE recommends that the Commission adopt these 2
standards and policies for future reasonableness reviews. 3
The Commission, however, has directed SCE to report 2014 SONGS 2&3 expenses for 4
Commission review at this time, even though certain activities have not been completed. SCE 5
recommends that the reasonableness of 2014 recorded expenses be evaluated based on the sum of all 6
expenses incurred for activities versus the sum of all 2014 estimated expenses (including contingency) 7
for those activities, and ensuring the decommissioning trusts are sufficiently funded for remaining 8
estimated expenses. SCE presents information and variances discussions for the 2014 activities in this 9
supporting testimony. 10
7
IV. 1
OVERVIEW OF SONGS DECOMMISSIONING ORGANIZATION & ACTIVITIES 2
A. Summary of NRC Decommissioning Phases 3
The decommissioning of commercial nuclear power plants in California is principally regulated 4
by the U.S. Nuclear Regulatory Commission (NRC), with cost oversight by the California Public 5
Utilities Commission (Commission). SCE is following the NRC’s Regulatory Guide 1.184 6
“Decommissioning of Nuclear Power Reactors” to decommission SONGS. This guide identifies three 7
phases for decommissioning. The first phase involves decommissioning initial activities, which start on 8
the date of permanent cessation of operations and continues until the licensee either places the power 9
reactor into storage mode or begins major decommissioning activities. The second phase encompasses 10
the major decommissioning activities (i.e., decontamination and dismantling). The third phase consists 11
of the remaining activities required to terminate the facility licenses. 12
B. SONGS Workforce And Work Groups And Activities 13
During 2014, SONGS was in the first phase of the decommissioning process and, as prudent, 14
aligned its work groups and support to the planned work. This resulted in a workforce of 433 SCE 15
employees as of December 31, 2014, which SCE determined was reasonable based on its review of other 16
decommissioning facilities and technical requirements for SONGS. See Figure IV-1 depicting the 17
workforce reductions from June 2013 through December 2014. 18
8
Figure IV-1 SONGS Workforce14
SCE will continue to manage the SONGS workforce throughout the decommissioning project to 1
ensure alignment with the scheduled activities and regulatory requirements. 2
1. SONGS Decommissioning Organization 3
As a result of workforce reductions made, SCE restructured the work groups at SONGS. 4
The SONGS nuclear organization is now known as the SONGS Decommissioning Organization, which 5
has responsibility over all plant activities and decommissioning. The organizational chart in Figure IV-2 6
below depicts the structure of the Decommissioning Organization as of December 2014. A brief 7
discussion of each group and their respective areas of responsibility in 2014 is provided. 8
14 Excludes temporary utility employees, utility employees on leave of absence, and contract workers.
9
Figure IV-2 SONGS Decommissioning Organization
December 2014
In 2014, the SONGS workforce performed a number of initial decommissioning 1
activities, which included maintaining certain original plant systems to meet existing license 2
requirements and ensure safe possession of spent nuclear fuel. Some plant systems that SCE continues 3
to maintain to meet these requirements include: (1) spent fuel pool systems; (2) radiation monitoring 4
system equipment; (3) electrical distribution systems; (4) HVAC systems; and (5) Independent Spent 5
Fuel Storage Installation (ISFSI). SCE must continue to maintain the originally installed Unit 2 and 3 6
spent fuel pool cooling and ancillary systems in order to keep the spent fuel covered with enough water 7
to keep the fuel at the appropriate temperature and limit the radiological dose. After SCE completes the 8
“islanding” of the Unit 2 and 3 spent fuel pools, which are independent cooling systems, and meets 9
related NRC requirements, the spent fuel pool cooling systems will be retired. As SCE completes 10
decommissioning activities, and receives NRC approval of its permanently defueled technical 11
specifications, additional systems will be retired and the maintenance requirements will be reduced. 12
SCE is also required to meet NRC-specified emergency planning requirements under its current 13
licensing basis. The current SONGS workforce is also required to meet the Emergency Response 14
10
Organization (ERO) staffing, security, and other requirements. SCE has submitted a license amendment 1
request with the NRC to approve an updated Emergency Plan (E-Plan) for SONGS to be consistent with 2
a permanently defueled facility and is awaiting NRC’s approval. When approved, the updated E-Plan 3
will allow SCE to reduce the number of emergency response organization positions at SONGS and to 4
reduce the associated expenses commensurate with the reduced risk level at SONGS. 5
The SONGS Decommissioning Organization that performed this and other 6
decommissioning work is headed by a Vice President for SONGS Decommissioning, who has overall 7
responsibility for SONGS decommissioning activities, including state and federal regulatory affairs, 8
external communications with stakeholders, and strategic planning and analysis. As discussed in further 9
detail below, these activities and the associated costs were reasonable, as the work was necessary to 10
comply with existing technical specifications; prepare the facility for decommissioning; ensure the 11
health and safety of the workers and the public; retire plant systems to minimize or eliminate 12
unnecessary costs; and keep the public and stakeholders informed on decommissioning progress. 13
a) Decommissioning & Regulatory Affairs 14
The Decommissioning and Regulatory Affairs group consisted of five sub-groups 15
that worked together to perform decommissioning work during 2014: 16
1. The Decommissioning Initial Activities (DIA)15 group was responsible for the 17
initial post-shutdown analysis and planning effort required to transition 18
SONGS from an operating facility to decommissioning. This group 19
developed and issued a 20-year project plan that specifies and coordinates the 20
major activities and initiatives necessary to decommission the plant. This 21
group was also responsible for negotiating contracts with specialty vendors for 22
various tasks and projects necessary to prepare the facility for 23
decommissioning. 24
15 SCE now refers to this group as the Decommissioning and Dismantling Team (DDT).
11
2. The Engineering group, which includes the Civil, Mechanical, and 1
Electrical/I&C Design engineering programs, was responsible for conducting 2
engineering analyses, preparing scope documents, and providing technical 3
expertise to support DIA. This group also evaluated plant systems to 4
determine the timing for system retirement and developed a design change 5
process. 6
3. The Oversight and Nuclear Safety Concerns group provided quality control 7
and audit functions so that all work associated with the storage of nuclear fuel 8
was performed safely and correctly, and documented accurately. This group 9
also includes the SONGS nuclear safety concerns program. 10
4. The Regulatory and Emergency Preparedness group was responsible for 11
evaluating plant requirements for a defueled facility. This allowed the group 12
to determine what changes were needed to the SONGS licensing basis so that 13
the plant would remain in regulatory compliance. This group also 14
implemented the SONGS emergency plan for protecting the health and safety 15
of workers and the public in the event of a radiological emergency. 16
5. The Shutdown Plant Manager Group included the Operations, Radiological 17
Control and Chemistry, Security, Maintenance and Work Control, and Safety, 18
Human Performance, and Performance Improvement groups, as described 19
below: 20
The Operations group was responsible for operating and inspecting the 21
remaining-in service plant equipment, they isolated and drained retired 22
systems, worked with the Maintenance and Engineering groups to remove 23
plant hazards, and provided support to implement regulatory changes and 24
plant design changes. 25
The Radiological Control and Chemistry group ensured compliance with 26
regulations governing radiation exposure control in addition to 27
12
maintaining chemistry control of systems supporting the spent fuel pools. 1
This group also supported the removal of hazardous waste from the site 2
and was responsible for packaging and shipping the waste in accordance 3
with federal, state, and county regulations. 4
The Security group provided protection for SONGS in accordance with 5
NRC regulations (10 C.F.R. § 73 and 10 C.F.R. § 50.54) and SONGS 6
policy. 7
The Maintenance and Work Control group planned and performed the 8
required maintenance and surveillance testing of SONGS’ mechanical and 9
electrical equipment, instrumentation and controls, and protective devices. 10
This group also supported the removal of hazardous materials from retired 11
systems, and implemented the retirement of designated systems. 12
The Safety, Human Performance, and Performance Improvement group 13
monitored and provided oversight and direction on industrial safety 14
measures, safety performance, human performance issues, and identified 15
areas for improvement. This group then planned and implemented the 16
identified improvements. 17
b) Decommissioning Communications, Strategic Planning, and Analysis 18
This group provided support to the decommissioning project by overseeing public 19
relations and community outreach projects such as coordinating the Community Engagement Panel 20
(CEP) meetings, conducting plant tours, and preparing presentations for industry groups and public 21
officials pertaining to the SONGS decommissioning project. This group also provided support for long 22
term planning and analysis for the decommissioning of SONGS. 23
2. Summary of Decommissioning Organization 24
Each of these groups worked to initiate, assemble, plan, engineer, and implement several 25
projects and activities during 2014. For purposes of this testimony, all of these groups together are 26
referred to as the Decommissioning Team (DT). 27
13
V. 1
RECONCILIATION OF DECOMMISSIONING EXPENSES TO THE DCE 2
The 2014 recorded expenses are $44.3 million below the estimated costs for the activities 3
performed in 2014 as included in the DCE. Accordingly, the 2014 expenses should be deemed 4
reasonable. 5
As discussed earlier, the Commission, in D.14-11-040, ordered SCE to file this Application 6
within 60 days of the effective date of the decision to “. . . recover costs for 2014 operations and 7
maintenance and non-operations and maintenance expenses . . . .” Because this Application is being 8
filed in January 2015, SCE has not yet finalized accounting of all of the recorded expenses in 2014. As 9
noted above, SCE is providing recorded expenses through October, and forecast expenses for November 10
and December.16 11
SCE has grouped the decommissioning activities into Work Breakdown Structure (WBS) 12
elements for the purpose of tracking the cost and schedule performance of each activity from inception 13
through completion. (See Attachment A). SCE discusses below the variances between 2014 expenses 14
and the DCE by major project area. Beginning January 1, 2015, SCE will manage the decommissioning 15
work using the Decommissioning Project Cost System (DPCS). All decommissioning expenses 16
incurred will be charged directly to the DCE WBS structure in DPCS. Decommissioning expenses 17
recorded while the DCE WBS was being created (i.e., prior to January 1, 2015), were recorded to 18
SONGS’ previous cost structure of O&M expense and Capital accounts. SCE is currently mapping each 19
of these expenses to the proper WBS activity. In addition, prior to finalizing the DCE and implementing 20
DPCS, SCE utility employees generally either recorded their labor hours to the base O&M expense 21
accounts for their divisions, or to the accounts for specific activities that were capital projects. This 22
practice was also applied to contract labor. As a result, undistributed labor includes a portion of labor 23
dollars that were incurred to support specific distributed cost activities. Undistributed costs, which are 24
sometimes referred to as collateral costs, are typically time-dependent expenses such as utility and 25
16 For certain types of costs, year-end forecasts included some recorded expenses past October 2014.
14
decommissioning general contractor staff, property taxes, insurance, regulatory fees and permits, energy 1
costs, and security staff.17 Distributed expenses are activity specific and include planning and 2
preparation expenses as well as expenses for decontamination, packaging, disposal, and removal of 3
major components and systems.18 As part of the finalization of 2014 expenses, SCE will map these 4
expenses to the appropriate DCE WBS activities. SCE will provide the final mapping in an updated 5
exhibit that will be filed by April 1, 2015. 6
As explained in A.14-12-007, Exhibit SCE-01, the DCE used in this cost reconciliation was 7
developed for the purpose of being used as the basis for an executable decommissioning plan and 8
schedule, and included the evaluation of various alternative sequences and schedules for the 9
decommissioning work to achieve the decommissioning core principles and fundamental values of 10
safety, stewardship, and engagement.19 SCE, however, was not compelled to perform each 11
decommissioning activity precisely in accordance with the schedule assumed in the DCE. As SCE 12
commenced the actual planning and performance of certain decommissioning activities, SCE 13
encountered circumstances that required it to deviate from the DCE schedule. These real-time business 14
needs have required, and will continue to require, SCE to perform some activities earlier or later than 15
assumed in the DCE schedule. As a result, some activities that were estimated to be performed in 2013 16
or 2014 were performed in whole or part in a different year, or were rescheduled until 2015 or later. 17
SCE describes several instances of such timing changes in the variance explanations below. 18
Deviations in the timing of activity performance from the DCE did not necessarily result in 19
changes to the overall estimated cost for any particular activity. For some activities, the incurred costs 20
were, or are expected to be, very close to the estimated costs. For others, SCE incurred higher of lower 21
costs than estimated in the DCE. For still others, SCE did not complete activities that were estimated to 22
17 2014 Decommissioning Cost Analysis of the San Onofre Nuclear Generating Station Units 2 & 3
(“DCE”), page 12.
18 Id. For example, expenses for the segmentation, packaging, and disposal of the reactor internal components are distributed costs.
19 A.14-12-007, Exhibit SCE-01, page 8.
15
have been completed in 2014, and the total cost will not be known until the activity is completed in 2015 1
or later. SCE, therefore, also describes such circumstances in the variance explanations below. 2
3
A. Summary and Reconciliation of 2014 Costs 4
Table V-1 and Table V-2 below provide the summary of the 2014 expenses for SONGS in
comparison to the DCE.20 A description of the forecast variances is provided below and further detail of
lower level variances is provided in Attachment A. The forecast variances explained in this testimony
are against the estimated amount for 2014 expenses provided in Attachment B. The variances reported
in this testimony may change when final, recorded expenses for November and December are included.
For example, some variances currently forecasted as being less than estimated in the DCE, may
ultimately be more than estimated, and vice versa, when final, recorded costs are included. Therefore,
SCE will provide greater detail regarding the variances between recorded costs and the DCE in SCE’s
updated exhibit on April 1, 2015.
20 SCE and SDG&E jointly filed A.14-12-007 requesting the Commission to find the DCE reasonable. The
decommissioning activities described in this testimony section, such as the Cold & Dark (C&D) activities and selection of the Decommissioning General Contractor (DGC), are described in further detail in the supporting testimony, Exhibit SCE-1, for A.14-12-007.
16
Table V-1
Preliminary Comparison Of 2014 Recorded And Forecast Expenses To The DCE
(2014 Dollars in Millions, 100% Level)
17
Table V-2
Preliminary Comparison Of 2014 Recorded And Forecast Expenses To The DCE By
Category
(2014 Dollars in Millions, 100% Level)
Account Category DCERecorded/ Forecast Variance
Distributed Cold and Dark 45.6$ 18.9$ 26.7$ Distributed Decommissioning General Contractor 0.5 1.9 (1.4) Distributed Historical Site Assessment 8.8 2.6 6.2 Distributed Regulatory Compliance 6.6 1.9 4.7 Distributed Radioactive Material Disposal 20.6 11.2 9.4
Plan (PDEP),42 and the Certified Fuel Handler Program, as discussed further below. 15
Technical specifications (or “tech specs”) define safety limits for 16
key parameters that are established to protect the integrity of physical barriers against the uncontrolled 17
release of radioactivity. They contain Limiting Conditions for Operation (LCOs) that establish the 18
minimum performance levels for reactor operating configurations. Technical specifications have 19
surveillance requirements for testing and inspections that are unique to the type of reactor at the facility. 20
Upon the announcement of permanent cessation of operations at SONGS, DT began working on 21
modifying the technical specifications that were required during operations to tech specs for a 22
permanently defueled facility and the subsequent license amendment request (LAR) to revise the facility 23
operating license to incorporate the PDTS. These activities were necessary and reasonable in light of 24
the fact that SONGS is a permanently shutdown facility. 25
42 See, e.g., 10 C.F.R. Part 50, Appendix E “Emergency Planning and Preparedness for Production and
Utilization Facilities.”
24
The PDEP provides the transition from an emergency plan for an 1
operating nuclear facility to an emergency plan for a permanently defueled facility. The PDEP provides 2
the scope of how SONGS will respond to potential radiological emergencies at the station and how 3
SONGS will coordinate a response with off-site federal agencies and county organizations, considering 4
SONGS’ permanently shut down and defueled status. 5
Pursuant to NRC regulation, upon permanent removal of fuel from 6
the SONGS 2 & 3 reactor vessels, the 10 C.F.R. Part 50 license no longer authorizes reactor operation or 7
placement or retention of fuel in the reactor vessels. As a result, licensed reactor operators are no longer 8
required to support plant operating activities. Instead, approval of a Certified Fuel Handler training and 9
retraining program was needed to facilitate activities associated with decommissioning and the 10
management and handling of irradiated fuel. The NRC approved the SONGS Certified Fuel Handler 11
Qualification training and retraining program on September 30, 2014. Again, SCE’s activities to 12
establish this program are also reasonable given the status of SONGS. 13
In addition, SCE was required to develop an updated DCE and a 14
PSDAR for submittal to the NRC. The site specific DCE is a “bottoms up” estimate and addresses the 15
expenses associated with onsite wet spent fuel storage and dry spent fuel storage as well as the eventual 16
transfer of spent fuel to the DOE; radiological decontamination and termination of the 10 C.F.R. Part 50 17
license; and final site restoration, including all costs required to terminate the site easements granted by 18
the U.S. Department of the Navy and the California State Lands Commission, and any costs associated 19
with compliance with other State of California laws and regulations. The PSDAR provides a high-level 20
summary of decommissioning plans and includes the DCE and Environmental Report (ER). On 21
December 27, 2014, the 90 day public comment period expired and SCE is permitted to perform major 22
decommissioning activities under NRC regulations, pending SCE’s obtaining all required environmental 23
permits. SCE’s work to complete these required submissions was necessary and reasonable to meet 24
NRC requirements and to plan for decommissioning. 25
25
(b) Variance Explanation 1
The estimated cost in the DCE for these regulatory compliance 2
activities in 2014 was $6.6 million.43 SCE incurred $1.9 million,44 or $4.7 million less than estimated.45 3
The primary reason for this variance was that many of the expenses were recorded as undistributed labor 4
expenses as discussed above. In SCE’s updated reconciliation of 2014 decommissioning costs, to be 5
submitted to the Commission by April 1, 2015, SCE will assign the appropriate portion of the 6
undistributed labor expenses to these activities. 7
(5) Radioactive Material Disposal 8
(a) Description 9
SCE used many tools and equipment in radioactive areas of the 10
plant to perform and support online maintenance activities and refueling outages. SCE also accumulated 11
quantities of radioactive resins, mixed wastes, and other legacy radioactive materials during plant 12
operations. These materials did not require the demolition of any buildings or structures in order to be 13
prepared for disposal. Beginning shortly after SONGS 2 & 3 were permanently retired, on June 7, 2013, 14
and continuing into 2014, SCE surveyed, packaged, and shipped many of these types of materials to 15
licensed disposal facilities for Class A, B, and C Low-Level Radioactive Waste (LLRW). These 16
activities were necessary and reasonable to dispose radioactive materials in a safe and responsible 17
manner. 18
(b) Variance Explanation 19
The estimated cost for this activity during 2014 was $20.6 20
million.46 SCE incurred $11.2 million,47 or $9.4 million less than estimated.48 SCE was able to dispose 21
43 See Attachment A, line 32.
44 Id.
45 Id.
46 See Attachment A, line 34.
47 Id.
48 Id.
26
of the materials for a lower cost than estimated in the DCE because SCE was able to successfully 1
employ volume reduction techniques that were not assumed in the DCE and obtain lower LLRW 2
disposal rates than were assumed in the DCE. 3
b) Undistributed 4
Undistributed license termination expenses are labor and non-labor expenses that 5
were not allocated to specific license termination activities. In the DCE, the estimated undistributed 6
expenses associated with Decon Period 2 were $76.7 million49 in 2014. SCE incurred $75.5 million50 7
for these types of expenses in 2014, or $1.2 million less than estimated.51 8
(1) Labor 9
(a) Description 10
Subsequent to the permanent retirement of the units, SCE 11
evaluated the functions that would continue to be required to support the transition from plant operations 12
to decommissioning. By December 2014, SCE reduced SONGS labor force to 433 utility workers. In 13
addition to the SCE labor costs, undistributed labor also includes the contract labor expenses for staff 14
augmentation. The total labor expenses were allocated between License Termination and Spent Fuel 15
Management based on the split assumed in the DCE. License Termination labor also included the 16
expenses for the Decommissioning Advisor (DA).52 As discussed above, the current workforce is 17
required to perform the decommissioning activities, and maintain the remaining plant systems needed to 18
meet current license requirements. 19
49 See Attachment A, line 63.
50 Id.
51 Id.
52 The SONGS Decommissioning Advisor is a subject matter expert in decommissioning, decontamination and dismantlement (D&D), engineering, licensing, and regulatory affairs. The DA is knowledgeable in environmental issues, spent fuel storage, project management, and low level waste management, and is capable of supporting both the preparation and the review of regulatory submittals.
27
(b) Variance Explanation 1
In the DCE, the estimated staffing cost for this period was $50.4 2
million.53 SCE incurred $60.9 million,54 or $10.5 million more than estimated.55 This variance occurred 3
in part because some labor expenses incurred to support distributed cost activities were initially recorded 4
as undistributed labor expenses as discussed above. These expenses will be reallocated in SCE’s 5
updated exhibit that will be submitted to the Commission by April 1, 2015. In addition, SCE exceeded 6
the estimated cost for the DA because DA resources were used to perform third party independent 7
review functions that were not included in the DCE. SCE reasonably incurred these additional expenses 8
to ensure SCE’s decommissioning plans and activities were vetted by an independent expert with 9
decommissioning experience. This allowed SCE to prepare high-quality submissions to the NRC and 10
successfully implement other decommissioning activities. In addition, SCE engaged the DA to obtain 11
independent, expert reviews and information as necessary to respond to questions from external 12
stakeholders, upholding a core decommissioning value of community engagement. Similar to utility 13
labor, therefore, some of these expenses will also be reallocated to specific distributed activities. 14
(2) Non-Labor 15
(a) Description 16
In 2014, SCE incurred non-labor expenses necessary to support the 17
work being performed at the plant. Some non-labor expenses corresponded exclusively to License 18
Termination, consistent with their estimated expenses in the DCE. Non-labor expenses applicable only 19
to License Termination in 2014 included association fees and expenses, CEP costs, environmental 20
permits and fees, non-process computer costs, telecommunications costs, and workers’ compensation 21
insurance. Other non-labor expenses were allocated among the License Termination, Spent Fuel 22
Management, and Site Restoration cost categories, consistent with their estimated expenses in the DCE. 23
53 See Attachment A, line 43.
54 Id.
55 Id.
28
Non-labor expenses partially allocated to License Termination in 2014 included utility staff Health 1
Due to the earlier-than-planned retirement of SONGS, DT 8
developed a plan and conducted initial engineering activities to identify the scope and requirements for 9
off-loading the remaining 2668 irradiated fuel assemblies from the spent fuel pools to the ISFSI by 10
2019. This acceleration required DT to evaluate a variety of locations for ISFSI expansion and conduct a 11
thorough evaluation of available systems that could be used at SONGS. Based on a rating scale that 12
included evaluating the technical qualities and costs of the systems, the required NRC license 13
amendments, local and state permits, environmental impacts, and system maintenance, one technology 14
and location was considered the optimum choice – the Holtec system in the current ISFSI site location, 15
which would be expanded.64 SCE elected to change vendors because the overall spent fuel storage cost 16
would be reduced, while maintaining the same level of performance and safety. 17
The distributed spent fuel management expenses include the cost 18
to store spent fuel both in wet storage in the spent fuel pools and in dry storage in the ISFSI; and the cost 19
to expand onsite dry storage capacity and to transfer the fuel that remains in wet storage to dry storage. 20
60 See Attachment A, line 106.
61 As noted previously, 2014 incurred expenses include actual and forecasts.
62 See Attachment A, line 106.
63 Id.
64 The system currently in use at SONGS is an AREVA system, which is a horizontal, above ground dry storage system. The Holtec system is a vertical below ground system. SONGS is planning to manage both systems until the DOE accepts transfer of the used fuel.
30
(b) Variance Explanation 1
During 2014, SCE incurred $18.8 million65 for ISFSI activities 2
compared to an estimated cost of $13.5 million,66 or $5.3 million more than estimated.67 This variance 3
occurred due to the initial milestone payment to Holtec, the new vendor. 4
(2) Regulatory Compliance 5
(a) Description 6
The regulatory compliance activities associated with spent fuel 7
management includes post-Fukushima spent fuel pool modifications, the spent fuel pool decay heat 8
analysis, the spent fuel pool zirconium fire/shine analysis, and the development of the SONGS Irradiated 9
Fuel Management Plan (IFMP).68 10
(b) Variance Explanation 11
SCE incurred $0.3 million69 in expenses associated with 12
Regulatory Compliance relative to an estimated cost of $0.3 million70 resulting in zero variance. 13
(3) Security 14
(a) Description 15
SCE activities that support the security of the SONGS 2&3 spent 16
fuel include the NRC cyber security program, in accordance with 10 C.F.R. § 73.54, and the SONGS 17
Security Shutdown Strategy. 18
65 See Attachment A,, line 72.
66 Id.
67 Id.
68 The IFMP provides the NRC with a description of the program by which SCE intends to manage and provide funding for the management of the irradiated fuel following the permanent cessation of operation of the reactor until SCE transfers title to and possession of the fuel to the DOE.
69 See Attachment A, lines 75, 76, and 77 ($0.2 + $0.1 + $0.0 = $0.3).
70 See Attachment A, lines 75, 76, and 77 ($0.1 + $0.1 + $0.1 = $0.3).
31
(b) Variance Explanation 1
SCE incurred $6.0 million71 in expenses associated with the NRC 2
cyber security program for SONGS and for the SONGS Security Shutdown Strategy in 2014 relative to 3
an estimated cost of $3.6 million,72 or $2.4 million more than estimated.73 This variance occurred 4
because a portion of the SONGS Security Strategy work that was estimated to occur in 2013 was 5
performed in 2014. As a result, the increased expenses incurred in 2014 partially offset an underspend 6
relative to estimated Spent Fuel Management security expenses in 2013.74 7
b) Undistributed 8
Undistributed spent fuel management expenses are labor and non-labor expenses 9
that are not allocated to specific spent fuel management activities. In the DCE, the estimated 10
undistributed expenses associated with SNF Period 2 were $47.3 million75 in 2014. SCE incurred $52.6 11
million76 for these types of costs, or $5.3 million more than estimated.77 12
(1) Labor 13
(a) Description: 14
Subsequent to the permanent retirement of the units, SCE 15
evaluated functions that would continue to be required to support the transition to decommissioning. 16
The total labor expenses were allocated between License Termination and Spent Fuel Management 17
based on the split assumed in the DCE as discussed above. 18
71 See Attachment A, line 82.
72 Id.
73 Id.
74 In 2013, SCE incurred $4.7 million in security expenses associated with Spent Fuel Management relative to an estimated cost of $10.3 million, or $5.6 million less than estimated.
75 See Attachment A, line 104.
76 Id.
77 Id.
32
(b) Variance Explanation: 1
In the DCE, the estimated staffing cost for this period was $47.3 2
million.78 SCE incurred $52.6 million,79 or $5.3 million more than estimated.80 This variance occurred 3
in part because some labor expenses that should have been allocated to distributed cost activities were 4
initially recorded as undistributed labor expenses as discussed above. These expenses will be 5
reallocated in SCE’s updated exhibit that will be submitted to the Commission by April 1, 2015. 6
(2) Non-Labor 7
(a) Description 8
In 2014, SCE incurred non-labor expenses necessary to support the 9
work being performed at the plant. Some non-labor expenses corresponded exclusively to Spent Fuel 10
Management activities, consistent with their estimated expenses in the DCE. Non-labor expenses 11
applicable only to Spent Fuel Management in 2014 included emergency preparedness fees, personal 12
computer costs, and spent fuel maintenance costs. Other non-labor expenses were allocated among the 13
License Termination, Spent Fuel Management, and Site Restoration cost categories, consistent with their 14
estimated expenses in the DCE. Non-labor expenses partially allocated to Spent Fuel Management in 15
2014 included utility staff HP supplies, security-related expenses, NRC spent fuel fees, dry active waste 16
disposal, materials and services, energy, utilities, and insurance fees. 17
(b) Variance Explanation: 18
The estimated cost was $11.0 million,81 for these non-labor items. 19
SCE incurred $8.4 million82 or $2.6 million less than estimated.83 Incurred expenses have been split 20
between accounts based on the allocation percentages assumed in the DCE. In addition, as noted above, 21
78 See Attachment A, line 89.
79 Id.
80 Id.
81 Id.
82 See Attachment A, line 102.
83 Id.
33
SCE performed less work in radiological areas, and therefore, incurred lower than estimated expenses 1
for HP supplies during 2014. SCE also incurred lower energy expenses than estimated in 2014. 2
3. Site Restoration, SR Pd 1 3
Site Restoration expenses are for all activities required, in addition to license termination 4
and spent fuel management activities, to complete its obligation to decommission both the onshore and 5
offshore portions of the SONGS facility, terminate the site easements and leases, and return the site to 6
the landowners. In addition to site lease and easement related payments, the expenses to terminate the 7
pre-existing nuclear fuel purchase and fabrication contracts, as well as utility worker severance 8
payments and performance incentive (results sharing) program payments are included in this category. 9
The estimated cost for site restoration activities for 2014 was $31.1 million.84 SCE 10
incurred85 $23.2 million86 dollars, or $7.9 million less than estimated.87 11
a) Distributed 12
The distributed site restoration expenses incurred during 2014 included the 13
expenses for the Historical Site Assessment and Characterization Survey for the SONGS Mesa site, the 14
expenses to prepare to surrender the SONGS Mesa site to the U.S. Department of the Navy (Navy), and 15
regulatory compliance costs. 16
(1) Historical Site Assessment and Characterization Survey – Mesa 17
(a) Description 18
The SONGS site consists of the plant site and the Mesa site. The 19
Mesa site is on the east side of the I-5 freeway and housed major equipment and buildings such as the 20
warehouse and office facilities. The Mesa site assessment and characterization survey mirrors the HSA 21
for the plant site as described above and identifies potential sources of contamination and radionuclides 22
84 See Attachment A, line 128.
85 As noted previously, 2014 incurred expenses include actual and forecasted expenditures
86 See Attachment A, line 128.
87 Id.
34
of concern; differentiates impacted and non-impacted areas; assesses the likelihood of contaminant 1
migration; and provides input to characterization surveys, remediation, and final status surveys. 2
(b) Variance Explanation 3
The DCE estimated that the cost to perform the Mesa site 4
assessment and characterization survey during 2014 would be $0.6 million.88 SCE incurred $1.4 5
million89 in 2014, or $0.8 million more than estimated.90 This variance occurred because much of the 6
work was accelerated from 2015 to support the Mesa Site surrender project discussed below. 7
(2) Mesa Site Surrender 8
(a) Description 9
During 2014, a significant amount of work was performed to 10
return the land and selected buildings at the Mesa site back to the Navy. Several meetings between SCE 11
and the Navy were conducted to negotiate the surrender plan of the Mesa site and to identify the 12
buildings and/or structures that would remain at the site, at the Navy’s request. In parallel, SCE 13
successfully demolished 30 buildings, structures, and containers, and removed appurtenant landscaping. 14
These activities and associated costs are reasonable as they will result in future savings. Specifically, by 15
terminating some of the Mesa leases and surrendering portions of the Mesa site to the Navy earlier than 16
estimated, SCE will avoid future lease payment and other site-maintenance costs. Figure V-3 and 17
Figure V-4 below provide a comparison of the Mesa facility in 2013 to November 2014: 18
88 See Attachment A, line 111.
89 Id.
90 Id.
35
Figure V-3 SONGS Mesa Site-2013
Figure V-4 SONGS Mesa Site – 2014
36
(b) Variance Explanation 1
The DCE estimated that the cost to perform the Mesa Site 2
Surrender during 2014 would be $0.3 million.91 SCE incurred $3.3 million92 in 2014, or $3.0 million 3
more than estimated.93 This variance occurred because work was performed earlier than estimated in the 4
DCE. The DCE included most of the Mesa Site Surrender expenses in 2016. 5
(3) Regulatory Compliance 6
(a) Description 7
Prior to the permanent retirement of SONGS 2&3, SCE had 8
executed several contracts for the purchase of uranium and the fabrication of new fuel assemblies for use 9
in future fuel cycles. Following the decision to permanently retire SONGS, SCE used, and continue to 10
use, its best efforts to sell the uranium and to avoid incurring fabrication expenses for fuel assemblies 11
that it would no longer need. These activities were reasonable to reduce unnecessary expenses. 12
(b) Variance Explanation 13
The DCE estimated $17.7 million94 for nuclear fuel contract 14
termination expenses during 2014. SCE incurred $5.1 million,95 or $12.6 million96 less than estimated. 15
However, because SCE expended $10.6 million for nuclear fuel contract termination expenses during 16
2013, relative to an estimate of $0 in 2013, SCE incurred approximately $2 million less than the 17
estimated expense for the June 7, 2013 through December 31, 2014 period. 18
b) Undistributed 19
Undistributed site restoration costs are non-labor expenses that are not assigned to 20
site restoration activities. In the DCE, the estimated undistributed expenses associated with SR Period 1 21
91 See Attachment A, line 115.
92 Id.
93 Id.
94 See Attachment A, line 118.
95 Id.
96 Id.
37
during 2014 were $12.5 million.97 SCE incurred $13.4 million98 for these types of costs, or $0.9 million 1
more than estimated.99 2
(1) Labor 3
No labor expenses were estimated or incurred for site restoration activities 4
during 2014. 5
(2) Non-Labor 6
(a) Description: 7
SCE incurred Site Restoration non-labor expenses in 2014 for 8
severance and results sharing and for a portion of the site lease and easement expenses. The remaining 9
portion of the site lease and easement expense was allocated to License Termination. Severance 10
expenses incurred were related to SONGS’ continuing workforce reductions. The site lease and 11
easement expenses are the contractual amounts that SCE is required to pay the Navy. 12
(b) Variance Explanation: 13
The estimated undistributed expenses associated with SR Period 1 14
during 2014 were $12.5 million.100 SCE incurred $13.4 million101 for this category, or $0.9 million 15
more than estimated.102 $12.1 million103 of the $13.4 million104 was for separation payments to severed 16
utility workers. The remaining $1.3 million105 was incurred because the easement expenses for the plant 17
site were underestimated by $0.8 million106 in the DCE. 18
97 See Attachment A, line 126.
98 Id.
99 Id.
100 See Attachment A, line 124.
101 Id.
102 Id.
103 See Attachment A, line 123.
104 See Attachment A, line 124.
105 See Attachment A, line 122.
106 Id.
Attachment A
Attachment A
Southern California Edison
SONGS Decommissioning
Preliminary Comparison Of 2014
Recorded And Forecasted Costs To The DCE By WBS
(2014 Dollars in Millions, 100% Level)
Category D/U Phase WBS
DCE
No. Description
2014
Decommissioning
Cost Estimate
2014
Actual/Forecast
Forecasted 2014
Variance
1 Cold and Dark D LT WD2-1.1.1.01.01 2.26 Install Spent Fuel Pool System Modifications - Unit 2 3.3$ 4.2$ (0.9)$
2 Cold and Dark D LT WD4-1.1.6.01.02.02 2.23 Design Spent Fuel Pool Support System Modifications 0.8 - 0.8
3 Cold and Dark D LT WD4-1.1.1.01.21.01 2.19 Implement Cold and Dark (Repower Site) 23.0 1.5 21.5
4 Cold and Dark D LT WD4-1.1.1.01.21.02 2.29 Implement Control Room Modifications (Command Center Relocation) 1.1 - 1.1
5 Cold and Dark D LT WD4-1.1.1.01.21.03 2.30 Implement Spent Fuel Pool Security Modifications 0.5 - 0.5
6 Cold and Dark D LT WD4-1.1.1.01.22.02 2.31 Transition Project Modifications 0.1 - 0.1
7 Cold and Dark D LT WD4-1.1.2.01.21.01 2.21 Drain and De-Energize Non-Essential Systems (DEC Process) 3.1 - 3.1
8 Cold and Dark D LT WD4-1.1.6.01.02.01 2.18 Planning and Design For Cold and Dark 12.3 13.2 (0.9)
9 Cold and Dark D LT WD4-1.1.6.01.02.03 2.24 Design Control Room Relocation 0.8 - 0.8
10 Cold and Dark D LT WD4-1.1.6.01.02.04 2.25 Design Spent Fuel Security System Modifications 0.6 - 0.6
11 Cold and Dark Total 45.6$ 18.9$ 26.7$
12
13 DGC Prep D LT WD4-1.1.5.01.21 2.22 Select Decommissioning General Contractor (DGC) 0.5 1.9 (1.4)
14 DGC Prep Total 0.5$ 1.9$ (1.4)$
15
16 H S A D LT WD4-1.1.6.01.01 2.17 Historical Site Assessment/Site Charac. 8.8 2.6 6.2
17 H S A Total 8.8$ 2.6$ 6.2$
18
19 REG Comp D LT WD4-1.1.7.01.01.01 2.01 Develop Certified Fuel Handler Program 0.1 - 0.1
20 REG Comp D LT WD4-1.1.7.01.01.02 2.02 Prepare Post-Shutdown QA Plan 0.4 - 0.4
21 REG Comp D LT WD4-1.1.7.01.01.03 2.03 Prepare Post-Shutdown Security Plan 0.4 - 0.4
22 REG Comp D LT WD4-1.1.7.01.01.04 2.04 Prepare Post-Shutdown Fire Protection Plan 0.4 - 0.4