An EDISO N INTERNATIONAL Company (U 338-E) 2015 General Rate Case APPLICATION. Workpapers. Generation Coal O&M SCE-02 Volume 06, Part 01

Transcription

1 An EDISO N INTERNATIONAL Company (U 338-E) 2015 General Rate Case APPLICATION Workpapers Generation Coal O&M SCE-02 Volume 06, Part 01 N ovem ber 2013

2 I. INTRODUCTION This volume of testimony contains our O&M expense and capital expenditure forecasts for the coal-fired Four Corners Generating Station (Four Corners) and Mohave Generating Station (Mohave). These plants are located in New Mexico and Nevada, respectively. Each of these plants is co-owned with other utilities. SCE is the operating agent of Mohave, and plant co-owner Arizona Public Service (APS) is the operating agent of Four Corners. In this testimony, we present the methodology we used to develop our Test Year 2015 O&M expense forecasts for the two plants and our Capital expenditure forecast and decommissioning cost forecast for Four Corners, and we explain the reasonableness of our estimates. For convenience, this volume of testimony is divided into two parts. Part 1 provides background information on both plants and provides details on each plant s O&M expense forecasts. Part 2 provides details on our Four Corners capital expenditure and decommissioning forecasts. SCE is working to conclude the sale of our Four Corners plant share to APS, as approved by the Commission in D T Meanwhile, SCE customers continue to receive SCE s share of the plant s generation, and the costs incurred by SCE for the plant s ongoing operations are being recorded to the Four Corners Memorandum Account approved in SCE s 2012 GRC (D ).2 SCE and APS originally targeted to conclude the sale in October 2012; however, as of October 2013, certain sale closing requirements have not yet been completed. A primary remaining buyer contingency is for APS and the co-owners (other than SCE) to successfully conclude negotiations for a new Coal Supply Agreement (CSA) that is needed so that the plant can continue to operate beyond July However, these CSA negotiations were delayed because on August 31, 2012 the existing coal mining company, BHP, announced their intent to divest their interests in the mine when the plant s current coal supply agreement ends in July BHP and the Navajo Nation (the plant and the mine are located on Navajo land) then entered into negotiations for the Navajo to purchase the mine operation from BHP. Those negotiations are continuing and are expected to close during Once the mine sale is completed, we expect that APS, the co-owners (other than SCE) and the Navajo will conclude negotiations on the CSA, which will allow SCE and APS to then close the plant sale.3 WP 250,251 1 See workpapers for a copy o f D , p.2. 2 See workpapers for a copy o f D , pp , On June 17, 2013 APS issued a Form 8-K Current Report with the US Securities & Exchange Commission indicating that APS currently expects that it will not be in a position to close the Four Corners purchase transaction with SCE until the (Continued)

3 While SCE therefore expects our Four Comers sale to successfully close during 2013, this cannot yet be assured. Because of this ongoing uncertainty, in this GRC SCE is including O&M expense and capital expenditure forecasts for SCE to continue to participate in the plant. Our Four Corners forecasts assume: (1) Four Corners will cease operations in July 2016, the termination date o f the existing coownership agreements and coal fuel supply contract, and (2) plant Decommissioning will be initiated once operations cease. As further explained in Chapter VII of this testimony, SCE s Four Corners Test Year O&M expense Forecast is $ million. As further explained in Part 2 of this volume, our capital expenditure forecast is $ million.4 As discussed in more detail in Part 2, Chapter VI, the forecast cost for Four Corners decommissioning is $ million, of which $ million is forecast to be incurred during and the remainder thereafter. SCE will remove these forecast Four Corners O&M expenses and capital expenditures from our 2015 GRC proceeding at the soonest opportunity should the sale close as expected. In D the Commission approved recovery of Four Corners forecast expenses up until the (then) expected sale close on October 1, 2012, and created the Four Corners Memorandum Account (the FCMA) to capture additional expenses and expenditures that would be incurred should SCE experience delays in closing the sale.5 SCE subsequently created the FCMA and has been recording expenses and expenditures there since October 1, Consistent with D , should the sale not close, SCE proposes to discontinue the FCMA and return Four Corners cost recovery to GRC base rates effective January 1, 2015 (i.e., the start of our 2015 GRC rate cycle). As noted above, these costs consist of our continued participation in Four Corners operations until July 2016 and the costs to initiate plant Continued from the previous page A rizona Corporations Com mission s (ACC) intentions with regard to pursuing retail access deregulation in Arizona become clearer. This was in response to the A C C s announcement in May 2013 o f their intent to re-examine possible deregulation o f the retail electric market in Arizona. However, in September 2013, the ACC closed this docket, effectively foreclosing the possibility o f retail access deregulation impeding sale closure. SCE and APS continue to work on the remaining issues that could delay or prevent final sale closure. 4 The Four Corners capital expenditure testimony contained in part 2 o f this volume also provides information concerning SCE's Four Corners 2012 recorded capital expenditures, as directed in D should the sale not occur. See Chapter IV o f part 2 for further details. 5 D , Ordering Paragraph 14, p. 882: Southern California Edison Company may establish a Four Corners Memorandum Account to track expenses incurred between October 1, 2012 and the delayed sale date and file an application for reasonableness review after the sale o f Four Corners is completed. 2

4 decommissioning at that time, including related expenses such as employee severance costs that result from the plant shutdown. Mohave ceased operations December 31, 2005 and decommissioning work is nearing completion. After decommissioning is complete, SCE will continue to incur O&M expense to manage the Mohave plant site. These plant site O&M activities are expected to continue for the foreseeable future. As explained in more detail in Chapter IX and X, these O&M activities include management of the plant s ash disposal landfill and related ongoing groundwater monitoring, and are forecast to cost $0.309 million per year (SCE Share).6 W P SCE also proposes to close the Mohave BalancingjAccount (MBA) approved in SCE s 2006 GRC (D )7 and continued in SCE s 2009 GRC (D ),8 as Mohave dispositioning and decommissioning activities are now concluding. SCE proposes to recover forecast Mohave site management O&M expenses in GRC Base Rates, including maintenance of the ash landfill, until the Mohave plant site is closed or divested. Further details concerning the proposed rate treatment of Four Corners and Mohave are provided in SCE-10, Volume 1, Part 2. W P All Mohave and Four Corners O&M expense and capital expenditure forecast and recorded cost information presented in this volume of testimony are given on an SCE Share basis, unless otherwise noted. 7 D , Ordering Paragraph 8, p. 382: SCE shall establish a two way balancing to record the ongoing expenses and capital related costs associated with the Mohave Generating Station (Mohave). See workpapers for a copy o f D , pp , See workpapers for a copy o f D , pp

5 II. FOUR CORNERS OVERVIEW A. Location and Major Assets Four Corners Generating Station is located in northwestern New Mexico, in San Juan County, on the Navajo Nation Indian Reservation. The Plant is situated six miles southwest of Fruitland, New Mexico and 20 miles west of Farmington, New Mexico. The plant is operated by the Arizona Public Service Company (APS) for the benefit of its several owners. SCE owns 48 percent of Units 4 and 5 of the Four Corners Generating Station. Power from the plant is delivered to the SCE El Dorado substation via the El Dorado-Moenkopi 500kv Transmission line. The plant has five coal-fired units rated from 170 MW to 770 MW. Construction on Units 1 and 2 began in 1959 and operation commenced in Unit 3 was constructed during 1962 and 1963 and began operation in Units 1, 2, and 3 are owned entirely by APS. In the late 1960s, SCE joined with five other electric utilities (including APS) to build Units 4 and 5. Units 4 and 5 were placed into commercial operation in 1969 and 1970, respectively. Units 4 and 5 each had an initial generating capacity o f 785 MW net. However, beginning in the mid-1980s, the plant installed baghouses to reduce smoke stack particulate emissions, sulfur dioxide (SO2) scrubbers to reduce sulfur emissions, and other new auxiliary equipment.9 This new auxiliary equipment increased the Unit 4 and 5 auxiliary loads, and thereby reduced these units' net output. Because o f these changes, Unit 4 and 5 currently each have a maximum dependable net rating o f 770 MW.10 Coal for each unit is supplied from the adjacent Navajo Mine, currently operated by BHP Navajo Coal Company (BHP). The plant is a major employer on the Navajo Nation Reservation and about two-thirds o f the employees o f Four Corners Generating Station are Navajo Indians. Units 4 and 5 are conventional dry coal-fired once-through supercritical units11 designed to take advantage of the low-cost strip-mined coal on the Navajo Indian Reservation. 9 The scrubber and baghouse project was initiated as the result o f a court decree after a lawsuit was filed by the N ew Mexico Citizens for Clear A ir and W ater. The decree was signed by the N ew Mexico Environmental Improvement Department, The N ew Mexico Citizens for Clean A ir and W ater and APS as operating agent for the project. The baghouses went in service in 1983 and the scrubbers followed a year later in During their history, in addition to the 785 MW and 770 MW ratings, Units 4 and 5 have had other dependable ratings reflective of equipment conditions that existed at those times. 11 The Four Corners steam generators operate at pressures above 3,500 PSIG (pounds per square inch, gauge) and do not utilize a steam drum during normal operation (a bypass system that incorporates a drum type separator is provided for (Continued) 4

6 Each unit includes a steam generator (boiler), turbines, generators, control systems, and associated auxiliary equipment necessary to generate electric power. A baghouse particulate collection system and wet SO2 scrubber for each unit reduces particulate and sulfur dioxide emissions. A railroad line from the adjacent Navajo Mine carries coal to the station. The coal is delivered to blending facilities adjacent to the plant where it is crushed and moved to on-site storage or to conveyor belts for transport to the units. Once at the generating units, the coal is crushed into finer particles in pulverizing mills, mixed with preheated air, and injected into the plant s boilers for combustion. Natural gas is used for ignition and flame stabilization of the coal fuel. In addition to its 48 percent share of Units 4 and 5, SCE owns percent of the common facilities at the site.12 Systems and equipment that are common to both units or that provide service to the entire plant include air compressors, bottom ash and fly ash storage and disposal systems, water purification and storage systems, equipment and bearing cooling water systems, and shop and office facilities. The plant s cooling water system uses an on-site reservoir that also provides water for various plant requirements. Water for this reservoir is pumped from the San Juan River located approximately five miles from the plant site. B. Ownership and Management As stated above, APS owns 100 percent of Units 1, 2, and 3. Units 4 and 5 are jointly owned, as tenants in common, by SCE, APS, Public Service Company of New Mexico (PNM), Salt River Project Agricultural Improvement and Power District (SRP), El Paso Electric Company (EPE), and Tucson Electric Company (TEP). The participants undivided interests in Units 4 and 5 are as follows: SCE 48 percent (739 MW) APS 15 percent (231 MW) PNM 13 percent (200 MW) 25 SRP 10 percent (154 MW) Continued from the previous page startup and low load operation). Units incorporating steam generators o f this design are referred to as supercritical (operating above the critical point for water) once through (operating without a steam drum) units. 12 SCE also owns a 32 percent interest in the plant s 500 kv switchyard and 12 percent interest in its 345 kv switchyard. SCE owns 48 percent o f the kv transform er and the connection to the reserve auxiliary power source, 3.46 percent o f the reserve auxiliary power source, and percent o f the connection to the 345 kv switchyard facilities, respectively. 5

7 EPE 7 percent (108 MW) WP 249a-e TEP 7 percent (108 MW) The participants ownership interests and rights are governed by the Four Corners Project Co-Tenancy Agreement, and all amendments thereto.13 The Co-Tenancy Agreement sets forth the relationship among the participants and the governance of the Four Corners Plant. This agreement terminates on July 19, Plant operational issues are further managed in accordance with the Four Corners Project Operating Agreement. Other agreements between the co-owners include Four Corners Engineering and Operating Agreement and Four Corners Units 4 and 5 Capital Improvements Design and Construction Agreement. As mentioned above, the plant is located on the Navajo Nation Indian Reservation. The property is leased from the Navajo Nation. The current land lease to which SCE is party expires in July The participants exercise oversight management of the plant principally through the Engineering and Operating Committee (E&O Committee). The E&O Committee is composed of representatives from each participant and meets approximately once every three months to examine plant operations, review budget performance, and make decisions affecting Four Corners that must be approved by the committee. Particular emphasis is given to controlling costs. Every year in August, the E&O Committee meets to closely scrutinize APS's plans for the next year and examine the merits of those plans. The committee has the power to accept or reject both capital and operating expense budgets. During the year, as circumstances change to warrant significant adjustments to the expenditure requirements, the E&O Committee meets to evaluate those adjustments. The principal responsibilities of the E&O Committee are as follows: Final review and approval of the annual O&M budget. Review and approval o f capital expenditures. 13 A copy o f this agreement, as well as copies o f all other agreements among the plant owners governing the plant, are available upon request. 14 In anticipation o f successful close o f the SCE-APS sale, and successful close o f CSA negotiations that would allow the other plant owners to continue plant operations beyond July 2016, the other plant owners entered into a land lease extension in 2011 that terminates in 2041, according to SCE s understanding. SCE is not a party to this extension because SCE does not intend to participate in plant operations beyond July The existing lease to which SCE is a party allows the owners 120 days to decommission the plant after the termination date o f the lease. Decommissioning is currently expected to take much longer than 120 days. Therefore, should the sale not close and in order for the plant to remain in operation to July 2016 with SCE as a participant, SCE may need to reach an arrangement with the other plant owners regarding termination o f SCE plant ownership in 2016 with SCE continued financial responsibility related to the decommissioning thereafter. 6

8 Review and approval of staffing levels. Review and approval o f maintenance schedules. An SCE Project Manager in SCE s Power Production s Operations Support and Performance Improvement Division (OS&PI) and the Manager of OS&PI represent SCE on the Four Corners E&O Committee. The Manager of OS&PI reports to the Vice President of Power Production, and also serves as SCE s alternate representative on the Four Corners Coordinating Committee. The Project Manager and the OS&PI manager have an extensive management and technical background in fossil-fired generation. As SCE s E&O Committee representatives, the two managers receive policy direction from SCE s Vice President of Power Production and provide regular communications on issues affecting Four Corners cost and performance. The Vice President of Power Production represents SCE on the Four Corners Coordinating Committee, which is composed of a responsible officer from each of the six participants. This committee meets as needed to discuss major issues that require substantial long-term monetary allocation or redirection of major plant objectives. This committee also provides a framework to further address issues that the E&O Committee is unable to resolve. The Vice President of Power Production has oversight of SCE activities related to Four Corners and Mohave, along with SCE s gas-fired and hydroelectric generating assets, SCE s Solar Photovoltaic power plants, and SCE s demonstration Fuel Cell power plant O&M activities. The Vice President of Power Production reports to the SCE Senior Vice President of Power Supply, who in turn reports to the President of SCE. The Senior Vice President of SCE has oversight of the SCE Power Production assets described above, as well as oversight of SCE's fuel and power purchase activities and the dispatch of the generating assets owned by and contracted by SCE. Each owner has a representative on the Four Corners Financial Audits Committee. This committee oversees an annual audit of Four Corners production costs. The audit team is led by a representative of one of the participants, normally assigned on a rotating basis. Typically, the audit includes examination of contractor billings, application of Administrative and General (A&G) charges to the participants, and similar financial concerns. When the audit is complete, the committee meets to work out any significant problems discovered. C. Units 4 and 5 History As described above, Four Corners Units 4 and 5 were designed in the late 1960s and have been in operation since The Four Corners facility has delivered substantial value to our customers. Units 4 and 5 generate on average approximately ten to eleven million MWh of energy each year, of which SCE 7

9 receives 48 percent. Producing this much energy involves processing extremely large amounts of raw materials and places heavy demands on plant assets. Each day, over seventeen thousand tons of coal are consumed by the plant s giant furnaces, which supply steam at a temperature of 1,000 degrees Fahrenheit to the turbine generators. Four Corners processes more coal and ash per MWh of electricity than most other coal power plants because of the higher ash content of the coal used there. The age and service experience o f these generating stations must be considered when planning for the future. Since construction, the owners have made numerous additional capital expenditures at Four Corners to maintain safety and reliability, and to sustain or improve environmental performance. Often this involves replacing individual equipment components with like equipment as they reach the end of their specific service lives. In some cases the installation of entirely new systems has been needed to perform, in a significantly different manner, the functions performed by a prior obsolete system. In other cases, the installation of entirely new systems has been needed to meet operational needs that did not exist when the plants were constructed (e.g., many of the pollution control systems now in operation). Performance at this generating station has benefited from these major expenditures. For example, in the 1980s APS added flue gas SO2 removal systems, low NOx burners and baghouse particulate collection systems15 to Four Corners Units 4 and 5, which have greatly reduced the environmental impact of plant operations. At approximately the same time, APS replaced all the coal pulverizers at the plant because of poor reliability. As a result of these and similar expenditures, and the continued diligence of plant leadership and personnel, Four Corners plant reliability and fuel efficiency has been relatively consistent for many years. To sustain plant safety, reliability, fuel efficiency, and regulatory compliance until Units 4 and 5 are shut down for decommissioning in July 2016 (if the sale does not close), we must continue to make expenditures to comply with regulatory changes, to effectively deal with the adverse impacts of obsolescence and age, and to address the normal equipment degradation associated with the severe service conditions under which the plant operates. 15 SO2 removal systems refers to environmental control systems designed to remove sulfur dioxide from the flue gas exiting a boiler. Low NOx burners refers to specially designed equipment that replaces the standard burners (equipment used to mix fuel and air in a boiler) with equipment that produces lower levels o f oxides o f nitrogen during the combustion o f fuel. Baghouse particulate collection systems are specially designed environmental m anagement systems that use filter material to very efficiently capture extremely fine particles o f ash that become entrained with the flue gas during coal combustion. 8

10 D. Cost Forecasts Are Consistent With Plant Performance Objectives and With Our Decommissioning Plan Even as we approach a planned shut-down and decommissioning in July 2016, we must continue to maintain plant safety. Likewise, the plant must sustain its environmental performance at acceptable levels and within the stringent limits and requirements o f operating permits and all other applicable regulations. We must continue to meet other regulatory requirements, including NERC Reliability Standards governing our national power grid. We must continue to sustain production reliability to avoid incurring excessive costs to replace Four Corners generation, which is particularly important as Four Corners continues to be one o f the lowest cost generating resources available to our customers. We must sustain our fuel economy as the cost o f coal is one o f the largest components incurred in operating Four Corners. In summary, in order for the plant to provide the maximum benefit to our customers, we must operate Four Corners in a fashion that minimizes total costs (i.e., capital expenditures, fuel, plant O&M, and replacement power during plant outages) until we cease operations in July All expenditures described in this volume address one or more of these objectives. These performance objectives are described in more detail below. Our historic performance levels are reviewed in Chapter III, and in Chapter IV we further discuss our conformance with the Commission's requirement that all o f our post expenditures are in service of Decommissioning. 1. Plant Safety Safety o f personnel is our paramount objective. Employees, contractors, and the general public all come into close proximity to potentially dangerous operating plant equipment. Inadequate maintenance or improper operations o f Four Corners could expose employees, visitors, and contractors to unacceptable safety consequences. Equipment that could pose a safety concern includes the following: Large rotating equipment is in everyday service at these plants and represents risk of catastrophic failure, with associated damage and risk of personnel injury. This equipment includes large rotating steam turbines operating at temperatures up to 1000 degrees, generator components weighing up to 100 tons, motors operating at thousands o f horsepower, and large, heavy centrifugal air compressors rotating at thousands o f revolutions per minute. Four Corners utilizes very large coal-fueled furnaces, well over 100 feet tall, that operate at over 2,000 degrees. The risks of operating this equipment include explosion, fire, and casing rupture. These unacceptable events pose substantial risk to employees, 9

11 visitors, and the public and require that SCE assure the equipment is adequately maintained and unreliable components are replaced. The large steam generators (commonly referred to as boilers) at Four Corners operate at pressures over 3,500 pounds per square inch (PSI) and produce steam that is distributed throughout the plants at temperatures up to 1000 degrees. The boilers, valves, and piping systems that produce, convey, and control this superheated steam represent risk of death and injury to employees and visitors if not adequately maintained. The electrical generation and distribution systems at these plants operate at voltages ranging from 60 volts DC to 500,000 volts AC. Numerous electrical switches, circuit breakers, power cables, motors, and oil-filled power transformers are in regular service and represent significant risk of fire and explosion if not adequately inspected, maintained, and replaced when required. These forms of failure represent a serious risk to employees and other personnel. SCE considers proper maintenance of electrical equipment to be a very important aspect of our management programs at Four Corners. The boiler and piping insulation systems for Four Corners contain asbestos that must be adequately maintained and replaced when necessary to avoid exposure to employees and other personnel. Much of the equipment at our coal-fired plants is physically large, requiring employees and contractors to work at elevated conditions. The structures that contain large equipment must therefore be properly maintained to avoid risk of collapse and associated employee injury. Other equipment that, when not effectively maintained, represents safety risks to personnel include sulfuric acid, caustic and ammonia storage and handling facilities, paved surfaces, plant lighting, and maintenance tooling. Our O&M forecast includes funding for sustaining the plant s current safety management and training processes, which include assuring the proper operation and maintenance of power generation equipment and maintenance of safety and fire protection systems and equipment. As described in more detail in Part 2 of this volume, our Capital forecast includes several projects needed to assure this level of safety into the future. 10

12 Regulatory Compliance and Environmental Responsibility Including Compliance With Current US EPA Air Emissions Requirements Operating in conformance with all applicable laws and permit requirements, including environmental responsibilities, are important performance objectives. Four Corners is a large industrial facility that processes millions of tons of coal fuel every year and assumes substantial risk of unacceptable environmental impact if not adequately maintained. Coal-fired generating stations are subject to substantial environmental regulation, which serves to protect native groundwater and air quality. Examples of this regulation include: (1) the Federal Clean Water Act (33 U.S.C et seq.), which requires that permit conditions that limit water discharge contamination be met; (2) the hazardous waste regulations of 40 C.F.R. Parts , which require safe handling and disposal of hazardous materials; and (3) the Federal Clean Air Act (42 U.S.C ), which regulates air emissions of generating stations and requires monitoring of emissions. In 2009 the EPA initiated a review of the plant s compliance with the Clean Air Act (CAA). The plant has provided the EPA extensive records on the plant s operations, maintenance, and capital expenditures from January 1, 1990 to the present, which the EPA is reviewing. Plant air emissions are also governed by a Federal Air Implementation Plan (FIP) promulgated by the US Environmental Protection Agency (EPA) effective in June This FIP includes limits on SOX (sulfur oxides) air pollution and smokestack opacity along with other monitoring and reporting requirements. A separate regional haze FIP was promulgated for Four Corners in August 2012 and requires expenditures of several hundred million dollars for NOX emissions abatement systems, including the addition of Selective Catalytic Reduction (SCR) should the other owners desire to continue operations beyond 2016 after the SCE-APS sale closes. Specifically, among other mandates, the FIP requires that SCR be installed either: (Option A) on the first unit of Units 4 and 5 (i.e., on at least 750 MW) by October 23, 2016 and on all five of the plant s generating units by October 23, 2017, or alternatively, (Option B) on both Unit 4 and Unit 5 by July 31, 2018 if Units 1, 2, and 3 are permanently shut down by January 1, Since we do not plan to participate in plant operations beyond July 2016, SCE would not be funding this work. However, because the other owners are pursuing Option B (i.e., Units 1, 2, and 3 shut down by 2014 and then SCR installation on Units 4 and 5) in anticipation of a successful SCE-APS sale closure, there may be a possibility of Units 1, 2, and 3 shutting down prior to permanent shut down of 11

13 Units 4 and 5 in July Such a shutdown of Units 1, 2, and 3 would impact the start-up ability of Units 4 and 5 during 2014 through There is the possibility, therefore, of this impacting SCE's costs of continued participation in the plant, through requiring SCE s participation in capital expenditures for a new auxiliary source of start-up steam. This is also discussed in Part 2 of this volume. In addition to environmental compliance, regulatory conformance is a factor in many other areas of plant operations. This includes maintaining the plant as required by NERC Reliability Standards. As these standards are relatively new, compliance has required the plant to increase expenditures over the past few years. These standards require a variety of actions such as routinely testing and calibrating electrical fault protection devices that are part of the plant s electrical system. Another area of regulatory compliance specific to SCE is that our Four Corners participation complies with the Commission s Greenhouse Gas Emissions Performance Standards (EPS), as contained in SB 1368 and in Commission decisions applying the statute to Four Corners, and including the related requirements contained in the Commission s decision in our 2012 GRC. This area of compliance is discussed in more detail in Chapter IV of Part 2. In summary, our O&M and capital expenditure forecasts appropriately include funding for sustaining current environmental and regulatory compliance processes, and for meeting various other regulatory requirements, to assure compliant operations of the plant up until July This funding is needed to assure full regulatory compliance, including the continued proper operation and maintenance of coal fuel combustions systems, stack gas pollution scrubbers, emissions monitoring systems, ash removal and land-filling systems, and waste treatment systems, as needed to conform with our environmental regulatory requirements and permits, and consistent with our past operation. 3. Reliability Our O&M expense and Capital expenditure forecasts assume that some small degradation of reliability and fuel efficiency performance is an acceptable trade-off in order to reduce O&M expense and capital expenditures during the plant s last few years of operation. However, given the potentially A t the conclusion o f outages affecting only either Unit 4 or U nit 5 (i.e., where one o f the two units is operating and the other is experiencing an outage), the operating unit can provide the steam that is needed to restart the other unit. A t the conclusion o f outages affecting both Unit 4 and Unit 5, the start-up steam has historically been provided by Unit 1, 2 or 3. If necessary, Unit 1, 2, or 3 can be started without a supply o f start-up steam. However, this is not the case for U nit 4 or Unit 5, as they both require substantial amounts o f startup steam to drive the auxiliary steam turbines, which in turn, drive the Units 4 and 5 boiler feed pumps. Units 1, 2, and 3 have electric motors that drive the boiler feed pumps rather than auxiliary steam turbines. Retirement o f Units 1, 2, and 3 requires that an auxiliary boiler be installed and operated to supply this Units 4 and 5 startup steam. 12

14 high economic consequences of extended outages of the low-cost Four Corners Units 4 and 5 generating resources, and the fact that fuel expense is a very significant percentage of total Four Corners costs, our forecasts provide sufficient funding to assure that Units 4 and 5 reliability and fuel efficiency do not significantly degrade. Four Corners is a large producer of low-cost coal-fired electrical energy. SCE s share of the Units 4 and 5 represents approximately 739 MW of capacity. In 2012 Units 4 and 5 produced 10,183,288 MWh of low-cost energy of which SCE customers received approximately 5,160,407 MWh. SCE recognizes the importance of reliable power to its customers and to the State of California, and plant reliability is a key performance objective. When the Four Corners units are operating at full load, the output available to SCE s customers meets the load requirements of approximately one million homes. When the California energy load is at 40,000 MW, Four Corners Units 4 and 5 serve approximately oneand-a-half percent of the total California power demand, and it is one of the lowest cost sources of electricity. The majority of forecast O&M and capital expenditures for Four Corners are driven by plant reliability needs. Our forecast includes funding needed to sustain appropriate and cost effective levels of reliability performance through July This includes sustaining our personnel training programs and assuring that we continue to take corrective action each time we have an event that hinders plant output. This further includes sustaining our preventative and corrective maintenance programs and promptly undertaking equipment repairs when failures occur. 4. Fuel Efficient Operation As discussed above, our total cost management goal includes taking into account the fuel (i.e., coal) cost o f our Four Corners operations. Fuel cost is by far the largest component of total production cost. Thus, although direct fuel costs are the subject of another CPUC filing, maintaining the plant s efficiency in converting fuel energy to electrical energy is a key management objective. Monitoring equipment performance, controlling operating parameters, and using effective maintenance practices are all part of achieving this objective. 5. Total Cost Management Management of the total cost of our Four Corners operations is a primary SCE objective. Total cost management involves taking into account the inter-relationship between O&M, capital, and coal fuel expenditures and the cost of purchasing market energy when Four Corners electrical production is constrained during forced and scheduled outages. Actions undertaken by SCE and the other owners include assuring that appropriate levels of qualified and trained staffing are maintained at the station. We 13

15 14 Workpaper - Southern California Edison / 2015 GRC - APPLICATION 1 also evaluate equipment performance and attempt to schedule equipment replacements before production 2 restrictions and forced outages become costly to our customers. Additionally, we utilize employee 3 incentives that help maintain the focus of Four Corners plant employees on objectives that support the 4 cost management needs of our customers. 14

16 III. FOUR CORNERS PERFORMANCE A. Safety Worker safety remains the top priority at Four Corners. Safety management at Four Corners includes monthly safety inspections and safety observations by station managers, front-line leaders, and safety analysts, as well as a minimum of quarterly site visits from APS headquarters safety professionals. Employee safety teams focus on Human Performance Improvement and specific project development.17 Tailboards are conducted at the beginning of every shift and anytime the task significantly changes. B. Environmental Responsibility The Four Corners major environmental permits are: 1. Title V Air Permit, Acid Rain Permit. 2. National Pollutant Discharge Elimination System (NPDES) Water Permit Stormwater Permit. 4. US EPA Federal Implementation Plan (Air Emissions). 5. US EPA Federal Implementation Plan FIP (BART). One measure of environmental performance is the amount and severity of violation citations a power plant receives from regulatory agencies. Four Corners has not received any major Notices of Violations (NOVs) for the past several years. Four Corners also tracks un-permitted wastewater discharges relative to their NPDES wastewater permit. There have been no un-permitted discharges for several years. C. Reliability Equivalent Availability Factor (EAF) is a measurement of reliability performance that is widely used in the electric industry.19 During 2008 through 2012, Four Corners Units 4 and 5 exhibited excellent 17 The Four Corners Human Performance Improvement program reduces human errors and unsafe behaviors by identifying the cause for performance gaps, providing appropriate interventions to improve and sustain performance, and evaluating the results against the requirements. 18 The EPA (Environmental Protection Agency) initiative known as The National Pollutant Discharge Elimination System (NPDES) permit program controls water pollution by regulating point sources that discharge pollutants into waters o f the United States. 19 Equivalent Availability Factor is defined as the num ber o f hours the plant is available to serve load, including the prorating o f those hours where the plant is only partially available (i.e., when the plant is on-line, but cannot produce full output because o f equipment problems), divided by the total hours in the period (i.e., 8,760 hours, when measured on an annual basis). 15

17 1 2 reliability performance as shown in Figure III-1. The low EAF recorded in 2008 on Unit 5 and 2010 on Unit 4 was due to the extended outages needed to perform major unit overhauls in those years. Figure III-1 Four Corners Equivalent Availability Factor Major overhauls have historically been conducted approximately every six years on each unit. This periodic major maintenance is needed to assure that the units operate safely, efficiently, and reliably during the remainder of each six-year cycle. As the last major overhaul on Unit 4 was conducted in 2010, the next regularly scheduled Unit 4 major overhaul would be However, either the sale will close well before 2016, or the sale will not close and the plant will cease operations in July Therefore, in either case, SCE will not be funding any more Unit 4 major overhauls. As the last major overhaul on Unit 5 was conducted in 2008, the next regularly scheduled Unit 5 major overhaul would be in However, since we are working to close our sale during 2013, SCE is not funding a 2014 major overhaul, or any further overhauls, on Unit 5. If the sale does not close, our forecast assumes that no further overhauls will be needed between now and the plant shut down in July We assume Unit 5 reliability can be sustained at acceptable levels for this final, unusually long eight-year operating cycle since its last overhaul in While we may incur an increased level of break 16

18 17 1 down repairs because o f this unusally long operating cycle since its last major overhaul, we believe we 2 can maintain the overall reliability of Unit 5 at a cost effective level until plant shut down in July Figure III-2 below depicts the capacity factor from Units 4 and 5 combined (i.e., MWh, percent Owner Share) for years 2008 through As shown, actual generation varies year to year, as 5 planned and unplanned outage durations vary year to year, and as a result o f power market conditions. Figure III-2 Four Corners Capacity Factors Year Average U nit U nit D. Fuel Efficient Operation 7 Heat rate is a measurement of operating efficiency used in the fossil generation industry. Heat 8 Rate is defined as the heat energy used to generate a unit o f power output, most commonly expressed as 9 Btu per kwh (i.e., a lower number represents better fuel economy than a higher number). From Capacity factor is the percentage figure which reflects a plant's actual MWH output divided by the plant s maximum theoretical M W H generation that would result from operating at rated output every hour o f the year. A s such, a plant with a higher MW rating will generate more MWH than a plant with a lower MW rating operating at the same capacity factor. In June 2011, Units 4 and 5 were each re-rated from 750 MW to 770 MW (net) commensurate with turbine repairs made during their respective 2010 and 2008 overhauls, which increased generator MW output for the same amount o f steam flow. 17

19 1 2 through 2012 Four Corners Units 4 and 5 exhibited consistently good heat rate performance, as shown in Figure III-3 below. Figure III-3 Four Corners Heat Rate ,100 10,050 10,000 9,950 9,900 9,850 9,800 9,750 9,700 9,650 9,600 9,550 Year A verage U nit U nit The lower heat rates observed during 2008 through 2010 reflect two principal factors. The first factor is that it is normal for efficiency to degrade in between major overhauls due to the normal wear and tear of equipment components over many hours of operation (e.g., turbine blades erode, air preheater baskets and seals wear out, etc.). As noted above, the last major overhauls were in 2008 and 2010 on Unit 5 and Unit 4, respectively. The second factor is that fuel economy is best when the units are operated near or at their normal rated load (i.e., 770 MW on each unit). Due to power market conditions over the past few years the units experienced more hours of operation well below 770 MW in 2011 and 2012 than in 2008, 2009, and Notwithstanding the consistently good heat performance over the past several years, it should be noted that larger fluctuations in heat rate can sometimes occur and, as such, future heat rate cannot be predicted with certainty. Market conditions are subject to change. Also, as the units get closer to a July 2016 retirement and continue to operate further beyond their last major overhauls in 2008 and 2010, it is expected that the heat rate will increase. For example, we could experience earlier-than-forecast problems 18

20 with a major equipment item (e.g., turbine blades), and then have to continue to operate with that efficiency-degraded equipment. E. Total Cost Management Figure III-4 below depicts Four Corners recorded non-fuel O&M costs from 2008 through 2012, along with our forecast O&M expenses for 2013 through The higher costs shown in years 2008 and 2010 reflect the costs for the major overhauls in those years. In addition to the clear impacts of the major overhauls, Figure III-4 also shows that even in non-overhaul years Four Corner's annual costs fluctuate as activities such as repair maintenance can vary from one year to the next. While these year to year fluctuations exists, total non-fuel O&M costs do not show a clear trend either up or down during this time period, which indicates that costs are being managed to relatively consistent levels. When combined with the fact that fuel efficiency (i.e., fuel costs) and plant reliability are also being appropriately maintained (as discussed above), this indicates that plant total costs are also being managed to relatively consistent levels. Figure III-4 Four Corners Recorded O&M /Forecast ,000 0llllllll 60, , Labor (std escl) Non-Labor (std escl) Other (not escl) Labor Non-Labor 49,788 42,593 50,234 44,914 40,660 43,118 43,118 43,118 Other Total 50,724 43,685 51,623 46,160 41,937 44,407 44,420 44,433 Forecast A significant cost of operating Four Corners is the labor costs associated with plant staffing. Figure III-5 below depicts station staffing levels from 1993 through 2012 and forecast for These station personnel are all employees of the plant operator, APS. Note that these staffing figures include 19

21 percent of the plant s staff, including APS personnel who spend all or a portion of their time on Units 1, 2, and 3.21 However, all cost data discussed herein is only for SCE s share of plant costs, unless otherwise noted. Figure III-5 Four Corners Staffing Units 4 and The large staffing reduction achieved during the 1990s (well over 100 employees) reflects investments made in control system automation at the power plant, which allowed reductions in operating personnel levels. The station also undertook the wide-scale deployment of desktop computers during this time period and, related to this deployment, made significant improvements in data systems management and communication. These initiatives greatly improved worker productivity and allowed for more detailed analysis of the plant's maintenance program, thereby improving its effectiveness. Staffing essentially remained relatively constant during the late 1990s through Staffing then increased over the next seven years, peaking in 2008 at 607 employees, to support the slow-but-steady increasing maintenance needs of an aging generating station. This increase also reflects added work, including new training requirements, the operation and maintenance of new equipment, and management of data collection and reporting systems needed to comply with increasingly stringent regulations 21 Certain APS employees work solely on Units 1, 2 and 3, and others work solely on Units 4 and 5. Many employees work on both Units 1, 2 and 3, and on Units 4 and 5, as well as on plant Common equipment. The work hours o f all o f these employees are appropriately recorded and tracked to assure that the Units 4 and 5 co-owners pay their appropriate ownership share for this work. 20

22 promulgated over the years. Most recently this includes compliance with the SOX Federal Air Implementation Plan that became effective on June 6, 2007, as well as with NERC Reliability Standards that also became effective in June 2007 and have increased since that time. Since 2010, the station has steadily decreased manning through attrition, and the total employee count at the start of 2013 was 480. The decrease is consistent with APS s plans to cease operations on Units 1, 2, and 3 in 2014 should the SCE-APS Units 4 and 5 sale close as expected. APS has stated they will replace their Units 1, 2, and 3 generation (as noted earlier, APS is the sole owner of Units 1, 2, and 3) with SCE s share of Units 4 and 5 generation once they obtain that share. Aternatively, should the sale not close, we expect to operate at approximately this reduced level of staffing until the entire plant ceases operations in July In this case, as the entire plant will continue to operate, the cost savings of reduced staff (i.e., compared to prior levels) will continue to be offset by the costs of higher levels of contractor support and higher overtime costs for APS staff. 21

23 WP IV. OUR FOUR CORNERS O&M EXPENSE FORECAST CONFORMS TO THE GREENHOUSE GAS EMISSIONS PERFORMANCE STANDARD, AND IS IN SERVICE OF DECOMMISSIONING SCE s current participation in the plant is compliant with the Commission s Greenhouse Gas (GHG) Emissions Performance Standard. If the sale does not close, SCE's continued participation in the plant must remain compliant with the Commission's Greenhouse Gas (GHG) Emissions Performance Standard (EPS) (D ). This requires that base-loaded power plants maintain greenhouse gas emissions levels at or below those of a of a gas-fired combined cycle gas turbine (CCGT) base-load power plant. The EPS prohibits capital expenditures that extend the life of existing base loaded power plants that do not meet the emissions limit. Since Four Corners emissions exceed this level and cannot be cost effectively reduced below this level, SCE entered into the agreement to sell our plant share to APS. This sale was approved by the Commission in D , which exempted planned 2012 capital expenditures from EPS review. Prior to that approval, in response to SCE s Four Corners GHG EPS Petition, in D the Commission granted SCE approval of past and planned capital expenditures at Four Corners through 2011 that were not previously approved by the Commission in SCE s 2009 GRC (D ) because of potential conflict with the EPS. However, the Commission s approval in D was subject to certain conditions where SCE was required to demonstrate compliance in our 2012 GRC proceeding.22 In the Commission s decision in our 2012 GRC, the Commission found we met these requirements, stating: WP WP 276 We find that SCE established the nature, purpose, and necessity of the expenditures as 278 required for its pre-2012 Four Corners capital projects. The fact that SCE s ownership until 2016 was an integral part of the Commission s decision to grant the partial exemption from EPS for expenditures, otherwise shown to be reasonable and necessary, indicates acceptance of 2016 as the measure of Four Corners plant life for SCE. To the extent that replacement equipment might last beyond 2016, it does not equate with plant life extension because the ownership agreements, fuel supply contract, and land lease expire that year. Without new agreements, the plant cannot continue to operate. (D pp. 53, 54.). iwp The Commission therefore recognized that SCE s continued participation and funding of Four Corners plant operations through the remaining term of the existing plant agreements is compliant with the EPS. Recognizing that the closure of the SCE-APS sale might not occur and the potential impact of the sale not closing relative to the Commission s EPS policy objectives, the Commission further directed: WP a 22 See workpapers for a copy o f D , pp WP

24 If SCE does not complete the sale of Four Corners as authorized, SCE shall include in its 2015 GRC a showing that each post-2011 expenditure is reasonable, necessary, and in service of Decommissioning. The showing of necessity shall include an analysis of expected failure and available less costly alternatives. Although we agree that the sale might not close in 2012, we find that the policy objectives of EPS require that, going forward, SCE only be eligible for rate recovery for O&M and capital expenditures identified in the Decommissioning Case that it reached in consultation with its co-owners. (D , p. 55). W P If the Four Corners sale does not occur, SCE should limit post-2011 funding to O&M and capital expenditures identified in the Decommissioning Case and include in the 2015 GRC a showing that each post-2011 expenditure is reasonable, necessary, and in service of Decommissioning. (D , Conclusion of Law 30, p. 823) W P Immediately below, we explain why our O&M expense forecast is consistent with the Commission s findings and directives contained in D and is consistent with the Decommissioning Case presented in our 2012 GRC. In Part 2 of this volume, we explain why our capital expenditure forecast is consistent with the Commission s findings and directives contained in D and is consistent with the Decommissioning Case presented in our 2012 GRC. In our 2012 GRC proceeding, SCE provided two O&M expense and capital expenditure forecasts: one for a Plant Sale Case and one for a Plant Decommission Case. As explained in SCE s testimony in our 2012 GRC, our 2012 Test Year O&M expense Forecast for the Decommissioning Case was identical to that for our Plant Sale Case except for removal of the forecast costs for the (then) planned Unit major overhaul. As previously explained in Chapter III, major overhauls have historically been performed on Unit 4 and Unit 5 approximately every six years and were last performed in 2008 (Unit 5) and 2010 (Unit 4). The costs for these overhauls causes O&M expense to be significantly higher in years where a major overhaul is performed, as compared to years in which no major overhaul is performed. In SCE s past GRCs, SCE included (and the Commission approved) the annual average of these incremental costs for major unit overhauls in our Test Year forecast. For example, in SCE s 2009 GRC (D ) for the three-year rate cycle of 2009 through 2011, the Commission approved inclusion of one-third of the forecast incremental cost for the 2010 Unit 5 major overhaul (i.e., the annual average of this incremental overhaul cost that would be incurred during 2009 through 2011). Consistent with this practice, in our 2012 GRC Sale Case Forecast, SCE included the forecast annual average (during 2012 through 2014) incremental costs for the (then) planned 2014 Unit 5 major overhaul. These costs were included in our Sale Case forecast because, among other reasons, the SCE-APS sale had not yet been approved and the remaining duration of SCE s participation had not been decided. 23

25 Conversely, our 2012 GRC Decommission Case forecast assumed that the 2014 major overhaul would be canceled, but that an abbreviated overhaul would be conducted in its place to help assure reliable operation until the plant ceased operations for Decommissioning. We then forecast that this abbreviated overhaul preventative maintenance work would be equal to one-third of the 2014 incremental annual major overhaul costs that we had included in our Sale Case. In our 2012 GRC, the Commission subsequently approved SCE to recover Four Corners O&M expense that equaled our Sale Case forecast, with two reductions: (1) the incremental cost for the planned Unit major overhaul; and (2) all forecast O&M expense for operation beyond September The second of these reductions was based on the assumption the sale would close by October 1, 2012, but also allowed SCE to track any costs incurred after October 2012 in the Four Corners Memorandum Account.24 Consistent with the 2012 GRC Decision, our 2015 GRC forecast includes no funding for major overhauls. Furthermore, our forecast includes no funding for additional repairs (or for additional preventative maintenance to avoid such repairs) that might result from cancelation of the 2014 overhaul. Managing costs within this forecast will therefore be challenging, because we expect that we will need to perform additional repairs or additional preventative maintenance as a result o f canceling the overhaul. We expect that as added work arises, it may require us to incur multiple shorter outages in lieu of a single, large extended major overhaul outage. Such additional work and the associated outages could reduce plant reliability slightly below recent historic levels, and could drive O&M expenses above our forecast. While we have endeavored to produce an accurate forecast for operation until July 2016, it is possible that costs will be incurred that are in excess of our O&M expense and capital expenditure forecasts. Whether or not certain major overhaul work items are conducted during shorter outage(s) during January 2015 through June 2016, it is assumed that the plant will not perform much of the preventative maintenance that is normally performed during major overhauls. This means that Unit 5, in particular, will be at increased risk of incurring higher-than-historic repair costs after In spite of this risk, SCE s 2015 Test Year forecast assumes that O&M Operation expenses can be maintained at 2012 levels and O&M Maintenance expenses can be maintained at the 2011 and 2012 average recorded levels during the last 18 months of plant operation (i.e., from January 2015 through June 2016). As no major overhauls 23 D , Conclusions of Law 29, p D , Conclusions of Law 31, p WP

26 were conducted during 2011 and 2012, the Test Year forecast therefore does not include funding for any of the work items that would normally be accomplished only during major overhauls. A comparison of our 2015 Test Year O&M expense forecast with our 2012 GRC Decommission Case forecast, and with the O&M expense forecast adopted by the Commission in our 2012 GRC, further demonstrates that our 2015 Test Year O&M expense forecast conforms to the Commission s mandate that going forward, SCE only be eligible for rate recovery for O&M and capital expenditures identified in the Decommissioning Case that it reached in consultation with its co-owners. 25 Our 2012 GRC Decommission Case forecast was $ million in 2009 dollars, which equates to $ million in 2012 dollars. Our 2015 Test Year forecast is $ million in 2012 dollars, which is $1.984 million lower than our 2012 GRC Decommission Case forecast. In our 2012 GRC the Commission adopted a Four Corners O&M expense of $ million in 2009 dollars for nine months of operation, which equates to $ in 2009 dollars for twelve months of operation. This equates to $ million in 2012 dollars. Our 2015 Test Year forecast is $ million in 2012 dollars, or $1.203 million lower than the equivalent 12-month authorized amount in our 2012 GRC. This comparison demonstrates that our forecast herein is consistent with past forecasts for the plant Decommission Case. This forecast is aggressively cost-conscious, particularly in light of actual recorded expenditures during 2011 and 2012, and the continuing risk that the plant will incur additional break down repair costs (or added preventative maintenance to avoid those breakdowns) in lieu of conducting a Unit major overhaul. 25 D , p. 55. W P

27 V. WE ESTIMATE JULY 2016 THROUGH DECEMBER 2017 O&M DECOMMISSIONING EXPENSE WILL BE EQUAL TO OUR FORECAST JANUARY 2015 THROUGH JUNE 2016 O&M EXPENSE, AND WE WILL UPDATE OUR FORECAST WHEN APPROPRIATE We forecast that plant decommissioning work will begin shortly after the plant shutdown in July Further details regarding the decommissioning scope of work and cost estimate are provided in Part 2 of this volume, where we discuss forecast capital expenditures. The decommissioning cost estimate discussed therein consists o f those expenditures that will be incurred to physically dismantle the plant and return the site to an acceptable condition. However, the decommissioning cost estimate does not include numerous O&M expenses that will be incurred by the plant owners after the plant ceases operation in July These costs include employee severance costs and potential related expenses, such as job placement assistance for severed employees. These post-july 2016 O&M expenses, which are in in addition to the cost to decommission the plant, are difficult to accurately forecast at this time. This is because detailed planning for a July 2016 plant shutdown has not yet been performed. For the past several years, SCE and the other plant owners have focused their limited budgetary and staffing resources on successfully concluding the SCE plant share sale to APS, rather than on detailed plant shutdown and decommissioning planning. For plant operating agent APS and the other plant owners, this work has included: (1) initiating and proceeding with the various federal and state reviews that the other plant owners must complete in order to continue to operate the plant after SCE departs; and (2) initiating and then concluding negotiations on a new coal contract for those continued operations. Should the SCE-APS sale not successfully close, SCE and the other plant owners will then fully undertake the detailed planning process to prepare for a plant shutdown in July 2016, and to prepare for follow-on plant decommissioning. This planning process will include formulating a more detailed estimate of the various costs that will be incurred by the owners after plant operations cease in July 2016, that are in addition to plant decommissioning expenses. As these detailed plans to exit the plant site proceed, we will update the Commission at appropriate points during this GRC proceeding and will revise our post-shutdown O&M expense forecast as appropriate. Meanwhile, based on experience gained from the Mohave plant shutdown and decommissioning, SCE expects that costs incurred during July 2016 * 26

28 27 1 through December 2017, which are in addition to decommissioning costs, will be approximately equal to 2 the plant s monthly O&M expense incurred during the time period of January 2015 through June 2016A6 26 See W orkpapers for more information on M ohave recorded O&M expense leading up to and following its shut down on December 31, W P

29 VI. IF THE SCE-APS SALE CLOSES IN 2013 AS EXPECTED, SCE WILL REMOVE FOUR CORNERS COSTS FROM OUR 2015 GRC FORECASTS Should the SCE-APS sale successfully close during 2013 as expected, SCE will remove all forecast Four Corners costs from our 2015 GRC forecasts, including the O&M expense and capital expenditure forecasts presented in this volume. SCE will instead recover our remaining unrecovered Four Corners costs through mechanisms already established by the Commission. In the Commission s approval of the SCE-APS plant share sale, the Commission found reasonable the SCE-APS Asset Sale and Purchase Agreement.27 The Agreement provides that APS will reimburse to SCE capital expenditures incurred by SCE for Four Corners since January 1, 2011, except for accumulated depreciation associated with those expenditures recorded between January 1, 2011 and the sale close date, and except for capital expenditures incurred for unbudgeted plant emergencies (e.g., unforeseen breakdowns of significant pieces of equipment requiring capital repairs such as replacement of the failed equipment item). In the 2012 GRC, the Commission ordered SCE to remove all forecast Four Corners costs from GRC base rates, effective October 1, Four Corners costs we have incurred since October 2012 are currently being tracked in the Four Corners Memorandum Account, as follows: Southern California Edison Company may establish a Four Corners Memorandum Account to track expenses incurred between October 1, 2012 and the delayed sale date and file an application for reasonableness review after the sale of Four Corners is completed. (D , Ordering Paragraph 14, p. 882) Upon the close of the Sale, and commensurate with the removal our forecast O&M expense and capital expenditure forecasts presented herein, we will file an Application for reasonableness review and to the extent applicable, recovery of the incurred costs, that have accumulated between October 1, 2012 and the date the sale closes, in our Four Corners Memorandum Account. 27 D Conclusion o f Law 1, p D , page 55. WP 262 WP a 28

30 VII. FOUR CORNERS O&M EXPENSE FORECAST OVERVIEW A. Test Year Forecast Summary Our Four Corners 2015 Test Year O&M forecast is $ millon. It is based on the analysis of the most recent five years of recorded O&M expense data (i.e., 2008 through 2012). Four Corners has three categories of costs: labor, other and non-labor. Labor is the cost of SCE personnel who provide oversight of SCE s ownership share of the plant. Other costs consists of only one item, which is SCE s share of the lease payment to the Navajo Nation for the plant site lease. It is an other cost because it is analyzed in nominal years dollars, rather than in 2012 dollars, given that the lease has specific provisions that govern annual escalation of the lease cost.29 Non-labor comprises the large majority of Four Corners costs, which includes the costs for APS staff who operate and maintain the plant, as well as all of the costs of contractors, repair parts, consumables, and all other items needed to run the plant. In turn, these three cost components (labor, other and non-labor) fall into two sets of FERC accounts; one set for plant operations functions and another set for plant maintenance functions. The operations functions include a portion of the non-labor costs, as well as all of SCE s oversight labor and plant lease costs. The maintenance functions are comprised entirely of non-labor costs. As explained in more detail in Chapter VIII, we forecast that 2015 maintenance expenses will match the annual average of maintenance expenses (i.e., maintenance accounts ) recorded during the last two years (i.e., 2011 and 2012). We forcast that the labor and non-labor components of 2015 operating expenses will match last recorded year (2012) operations expenses (i.e., operations accounts ). We forecast the site lease expense component (i.e., the other cost category) of the operations accounts based on the terms of the Lease. As shown in Figure VII-6, our 2015 Test Year forecast is consistent with recorded expenses in 2008 through 2012, and is significantly less than recorded expenese in 2008 and This is because of costs associated with the major overhauls conducted in 2008 and As discussed above, our Test Year forecast does not include any funding for major overhauls. 29 Labor and non-labor costs are forecast and analyzed using constant 2012 dollars. 29

31 Figure VII-6 Recorded and Adjusted /Forecast ($000 C onstant 2012$) 60,000 60, , Labor (std escl) Non-Labor (std escl) Other (not escl) Labor Non-Labor Other , , ,166 50, , , , , , Total 50,724 43,685 51,623 46,160 41,937 44,407 < ,433 Forecast > B. Collection, Grouping, Adjustments, and Analysis of Recorded Data We used the following general process to analyze the recorded data and generate candidates for estimate: First, we collected five years of recorded data from 2008 through 2012, grouped by FERC accounts. Then, we escalated the recorded/adjusted expense to year 2012 constant dollars using rates supplied by SCE s Treasurers Department.30 We then grouped the Operations (FERC ) and Maintenance (FERC ) accounts. We analyzed the Operations and Maintenance FERC accounts recorded data and determined the causes of significant year-to-year changes. 30 See Exhibit SCE-10, Vol. 1, Chapter VII. Cost Escalation. 30

32 31 1 Using the adjusted recorded base, we forecast our Test Year expense levels for the Operations 2 (FERC ) and Maintenance (FERC ) accounts combinations o f the recorded 3 data were representative of all or part o f future requirements. 4 In the following chapter we provide additional details concerning our analysis and forecasting for 5 the operations accounts and maintenance accounts that comprise the total Test Year forecast for Four 6 Corners. 31

33 VIII. FOUR CORNERS GENERATING STATION O&M FERC ACCOUNTS A. FERC Operations Accounts Operations Accounts capture costs related to starting, stopping, and running the numerous equipment items required to produced power from the Four Corners generating units. This includes labor for operations personnel, water, chemicals, and other consumables, waste disposal, and a wide variety of other functions. Specifically, these accounts consist of: FERC Expenses incurred in the general supervision, direction, and support of station W P W P / I W P operation at Four Corners Generating Station. Since Four Corners is operated by APS and not SCE, this account is the only Four Corners account that records labor charges incurred by SCE. This includes oversight of its ownership share of the plant, including regular review of APS budget performance and operating and maintenance practices and similar activities. FERC Fuel-Related Expenses, including non-labor expense for the receiving, storage, and handling of fuel and removal/disposal of combustion residual (ash). FERC Steam Expenses, including expenses incurred to operate the furnace and boiler systems used for the production o f steam for electric generation. FERC Electric Expense, including expenses incurred in operating prime movers, generators, and auxiliary electrical systems to the points where electricity leaves for conversion to transmission W P FERC Miscellaneous Steam Expenses, including operations expenses that are not applicable to other specific Operation accounts. The significant activities with costs recorded to this account include salaries and expenses for the management, administrative, and support staffs and the payout for the Employee Incentive Plan W P FERC Rents, including the expense of real property rentals used, occupied, or V operated. in connection with the plants. For Four Corners, this consists solely of the annual payment made to the Navajo Nation for lease of the plant site. As noted above, to facilitate our review of past recorded operating costs, and for purposes of forecasting future operating costs, we first grouped all of the above operations accounts into a single account; specifically, we grouped them into account Figure VIII-7 below summarizes the total 2008 through 2012 recorded costs captured by the operations accounts, and our Test Year forecast for these accounts. 32

34 33 Figure VIII-7 FERC Operations Accounts Recorded and Adjusted /Forecast ($000 C onstant 2012$) II Labor (std escl) Non-Labor {std escl) Other (not escl) Labor , Non-Labor 19,889 20,875 20,048 19,037 19,700 19,700 19,700 19,700 Other Total 20,825 21,967 21,437 20,283 20,977 20,989 21,002 21, As shown, operations account recorded expense has been largely stable during 2008 through Lime purchases are a significant operating cost that can vary year to year depending on how much generation is produced. Four Corners uses wet scrubbers to sequester SOX emissions from the exhaust gases exiting the furnace. The wet scrubbers inject lime slurry into the exhaust gases to remove the SOX. In 2008 and 2010 we had lower lime costs compared to years 2009, 2011, and This is because less lime was required due to less generation because of the long overhaul outages in 2008 and However, offsetting these reduced lime costs were higher costs recorded to FERC during those two major overhaul years. During major overhauls, this account records the extra cost for site security, consumable material and supplies, tool repair and replacement, safety equipment, and all other operating expenses not specifically identified in the other operations accounts. In summary, O&M operations expenses shift to different activities between overhaul years (2008 and 2010) and non-overhaul years (2009, 2011, and 2012). In D and D , the CPUC stated that if recorded expenses in an account have been relatively stable for three or more years, the last recorded year is an appropriate base estimate. Non-labor has been relatively stable, therefore last recorded year is an appropriate estimate. Additionally, in D and D , the CPUC stated that if 33

35 costs have shown a trend in a certain direction over three or more years, the last recorded year is an appropriate base estimate. Labor expense demonstrate a slight decreasing trend from 2010 through 2012, therefore use of the last recorded year is an appropriate estimate. The 2015 Test Year estimate for labor is $0.710 million and for non-labor is $ million. The Rents other recorded category expense experienced an increase in 2011 and 2012, and will continue to increase during 2013 through 2016 pursuant to the plant site lease s specific escalation rates. Because past recorded expense is not consistent with the current cost of the lease, none of the recorded cost forecasting analysis methods were appropriate. Instead, an itemized forecast was utilized that is based on the terms of the lease resulting in a forecast of $0.605 million for the 2015 Test Year. B. FERC Maintenance Accounts Maintenance Accounts capture costs related to preventative maintenance and break down repairs on the numerous equipment systems required to produced power from the Four Corners generating units. This includes labor for maintenance personnel, repair parts, repair contractors (including repair shop services), and similar costs. Specifically, these accounts consist of: W P W P FERC Maintenance Supervision and Engineering, including APS salaries and related expenses for Managers overseeing the plant maintenance programs carried out by over 320 full time employees. FERC Maintenance of Structure, including labor and non-labor expenses incurred for routine maintenance and unforeseen storm damage on Administrative buildings, garage, and shop facilities W P W P FERC Maintenance of Boiler Plant, including non-labor expenses for the maintenance of the Four Corners station boiler and boiler-related systems. Account 512 is the plant s largest account, and typically records nearly one-third of total annual O&M expense. The plant s maintenance work force spend much o f their time working on the boiler systems. FERC Maintenance of Electric Plant, including expenses for the maintenance of the turbine, generator, cooling systems, and auxiliary electrical systems such as transformers and battery systems W P!/ FERC Maintenance of Miscellaneous Steam Plant, including expenses for maintenance of various systems such as compressed air, refrigeration, fire control, and also expenses for the wheeled vehicles used in and around the plants. Additionally, APS charges indirect maintenance activities to this account. These indirect activities cover such items as 34

36 rental of cranes, lifts and miscellaneous equipment, erection and rental of scaffolding, and other support facilities or services required to facilitate the maintenance of the plant. As noted above, to facilitate our review of past recorded maintenance costs, and for purposes of forecasting future maintenance costs, we first grouped all of the above maintenance accounts into a single account; specifically, we grouped them into account Figure VIII-8 below summarizes the total 2008 through 2012 recorded costs captured by the operations accounts, and our Test Year forecast for these accounts. Figure VIII-8 i Forecast > As shown in Figure VIII-8, maintenance costs vary significantly vary from year to year. In particular, as noted earlier, costs for major overhauls resulted in total maintenance costs being higher in 2008 and 2010, compared to 2009, 2011 and The higher maintenance cost is 2011, compared to 2009 and 2012, is primarily due to extensive routine boiler repairs that were needed in In our forecasting analysis, we concluded that using a two-year average of recorded expense to forecast the 2015 Test Year maintenance expense is reasonable. We excluded in this average the recorded costs in 2010 and prior years because of the major overhauls performed during that time period, including the relatively low costs recorded in The 2009 costs reflects the extensive 35

37 maintenance work just completed on Unit 5 in 2008, and the deferral of certain Unit 4 work during 2009 in anticipation that such work could be more efficiently accomplished during the (then) upcoming 2010 overhaul. Since no further overhauls are planned between now and the plant shut down in July 2016, we conclude that the maintenance work performed during 2011 and 2012 best represent maintenance costs forecast for In D and D , the CPUC stated that for those accounts which have significant fluctuations in recorded expenses from year to year, an average of recorded expenses is appropriate. From 2008 through 2012, the recorded costs in this account have fluctuated significantly from year to year, so an average is an appropriate forecast. The five-year average from 2008 through 2012 is $ million. However, due to the reasons above for excluding years prior to 2011 because of overhaul expenses, we selected a two-year average of 2011 and This provides a 2015 Test Year forecast of $ million for maintenance functions. While this forecast is reasonable based on recorded cost history, we also conclude that maintaining future maintenance costs within 2011 and 2012 recorded levels will be challenging, because as discussed above in Chapter IV, we could experience an increasing level of breakdown repairs (or preventative maintenance to avoid such equipment breakdowns) as we continue to operate further beyond the last major overhauls in 2008 and

38 IX. MOHAVE GENERATING O&M EXPENSE FORECAST OVERVIEW This chapter outlines the basis of our O&M forecast to manage the Mohave Generating Station power plant site for the 2015 Test Year, which we forecast at $0.3 million per year (SCE Share). SCE and the other owners ceased commercial operation of the Mohave Generating Station on December 31, The owners subsequently undertook a series of efforts to disposition the plant and provided the Commission regular updates on these efforts as required by D Ultimately, a variety of issues prevented SCE and the other owners from re-starting the plant or, alternatively, selling the plant. Therefore, in June 2009 the decision was made by the co-owners to decommission the facility. As of April 2013, SCE and the other Mohave co-owners have completed all major components associated with decommissioning the site with the exception of closure of all non-landfill associated monitoring wells. The closure of these wells is awaiting regulatory approval by the Nevada Department of Environmental Protection. It is expected that the regulatory approval and the actual closure of the wells will be completed by the end of After completion of the decommissioning process, SCE will continue to incur O&M expenses. These expenses will primarily relate to site security, minor maintenance activities, and landfill regulatory obligations (such as monitoring well testing & analysis and landfill inspections). These charges will continue into the foreseeable future until final site closure can be achieved. We describe these forecast Mohave O&M expenditures in more detail below and then by FERC Account in the following Chapter X. We present our capital expenditure forecast to complete the decommissioning of Mohave in Volume 6, Part 2, Chapter VII. A. Ownership and Management of Mohave Mohave Generating Station is jointly owned as tenants in common by SCE, Salt River Project Agricultural Improvement and Power District (SRP), Los Angeles Department of Water and Power (LADWP), and NV Energy, Inc. (NVE), collectively referred to as the co-owners or Participants. SCE is the Operating Agent on behalf of the co-owners. The co-owners interests in Mohave are as follows: SCE: 56 percent SRP: 20 percent LADWP: 10 percent W P W P See workpapers for a copy o f D , pp

39 NVE: 14 percent Mohave Generating Station formally included two 790 MW coal-fired generating units along with supporting systems associated with coal handling, water and wastewater treatment, and various administrative buildings and maintenance shops. Through decommissioning all plant systems and support buildings have been removed and the disturbed land has been modified to restore normal stormwater flow across the entire property. The decommissoned site contains a closed landfill, two switchyards, and two switchyard support buildings. The site should be considered as being in a brownfield condition. The plant is physically located at the southern tip of Nevada in the Township of Laughlin, on a 2,490-acre site adjacent to the Colorado River and the State of Arizona. The co-owners ownership interests and rights are governed by the Mohave Project Co-Tenancy Agreement, and all amendments.32 The Co-Tenancy Agreement and the Mohave Project Operating Agreement set forth the relationship among the co-owners and the governance of the Mohave Plant. The co-owners exercise oversight management of the plant principally through the Engineering and Operating Committee (E&O Committee). The E&O Committee includes representatives from each co-owner and meets approximately once every three months to discuss the status of the site, review budget performance, and make decisions affecting Mohave. During the year, as circumstances change to warrant significant adjustments to the expenditure requirements, the E&O Committee meets to evaluate those adjustments. The principal responsibilities of the E&O Committee are as follows: Review and approval of the annual O&M budget every August. Review and approval o f capital expenditures. Review and approval of staffing levels. The Vice President of SCE Power Production Division (PPD) represents SCE on the Mohave E&O Committee. The Vice President of PPD also represents SCE on the Mohave Coordinating Committee, which includes senior managers and officers from each of the co-owners. This committee meets as needed to discuss major issues that require substantial long-term monetary allocation or redirection of major plant objectives. Each owner has a representative on the Mohave Audit Committee that performs an annual audit of Mohave costs. The audit team is led by a representative of one of the co 32 The term o f the Mohave Co-Tenancy A greem ent and Operating A greem ent ceased in Plant owners continue to manage the plant in accordance with these governance documents pending final disposition o f the facility, or the replacement o f these agreements with a new site governance agreement. 38

40 owners, normally assigned on a rotating basis. Typically, the audit includes examination of contractor billings, application of Administrative and General (A&G) charges to the co-owners, and similar financial matters. The Committee is additionally responsible for addressing any issues revealed during the audit. B. Status of Plant Decommissioning and Site Disposition Consistent with the decision to decommission Mohave, SCE selected a demolition contractor on July 1, 2009, mobilized a team at the site on July 27, 2009, and began the work. SCE planned the work in two phases. The initial phase focused on: (1) achieving full separation of the facility from the 500KV switchyard; (2) dismantling equipment and facilities that were not associated with the 500KV switchyard; and (3) securing the environmental Emission Reduction Credits consistent with the permanent shutdown of the facility and formally releasing the station s Title V air permit.33 This phase was completed on May 10, The second phase involved: (1) removal of the balance of the plant equipment and facilities; (2) removal of wastewater pond material and formal closure of the evaporation ponds; and (3) restoring the natural stormwater flow through the site and complete final closure activities associated with the site landfill. As of April 2013, all physical site demolition activities have been completed with the exception of final closure of the remaining monitoring wells. Nine wells will remain through a five-year landfill monitoring program initiated at the start of It is expected that the plant's other 53 groundwater monitoring and treatment wells will be closed by the end of 2013 pending approval by Nevada Department of Environmental Protection. See Part 2, Chapter VII of this volume for further discussion of Mohave decommissioning. In addition to decommissioning, SCE and the other owners are currently assessing how to utilize the site following plant decommissioning. This utilization could include maintaining ownership of part or all of the property for some future utility use, including the construction of a new power plant. Alternatively, or in combination with other development efforts by the owners, this utilization could entail sale of the decommissioned Mohave power plant property. 33 The total amount o f ERCs are 7,216 tons o f N O x ERCs and 137 tons o f VOC ERCs (SCE s share is 56 percent o f these totals). These ERCs are usable only in the Clark Co, NV, air district and are required only by facilities there (new or existing) increasing emissions by certain threshold amounts; thus the market for the ERCs is very illiquid and changeable over time, and prices are very difficult or impossible to predict. Also, some or all o f the RCs m ight be required for any new generation that m ight ultimately be built at the Mohave site, and it m ight be optimal to retain the ERCs for that purpose. Besides the need to secure the M ohave ERCs, there was an additional reason that the plant s Title V permit was kept in effect for a time beyond the final shutdown decision. Certain ancillary equipment such as the emergency generators is needed through duration o f the decommissioning process and was permitted under the plant s overall Title V permit, and thus had to be re-permitted under new separate permits before the plant permit could be terminated. 39

41 X. MOHAVE STEAM POWER GENERATION O&M FERC ACCOUNTS A. Mohave Site Management O&M Plan and 2015 Expense Forecast At the Mohave site there will be $0.308 million 2015 Test Year O&M espense associated with site security and maintenance, including landfill monitoring well sampling and analysis. The following Figure X-9 illustrates the recorded expense from 2008 to 2012 and the forecasted expense from 2013 to 2015, on an SCE share basis. SCE s share of Mohave costs is 56 percent communsurate with our ownership percentage. Figure X-9 Recorded and Adjusted /Forecast SCE Share Expense ($000 C onstant 2012$) Labor (std escl) Non-Labor (std esc!) Other (not escl) Labor , Non-Labor 9,356 1, Other Total 13, , i Forecast > Our forecast assumes the current site ownership governance processes will not extensively change prior to the 2015 Test Year. We assume SCE will continue to provide, on behalf of all the remaining site owners, the lead in assuring all needed site management activities are properly funded, performed, reported, and documented. We assume these activities will continue to be co-funded by the other owners, in relation to their ownership share (i.e., we assume SCE will continue to own 56 percent of the site and will continue to fund 56 percent of site management O&M activities). 40

42 Future maintenance and any needed replacements of remaining equipment and structures (e.g., wells, well pumps, and fencing) will no longer be performed by SCE plant personnel as the facilities, staffing, tooling, and equipment needed to do so were removed as part of decommissioning. Therefore, our 2015 Test Year O&M forecast is primarily non-labor for contract workers. However, the PPD Home Office support groups will continue to record labor costs to Mohave commensurate with the site management activities described above. In summary, our forecast work scope for site O&M during and after decommissioning includes: Regular patrols of the plant perimeter. Performing biannual monitoring well testing and analysis associated with the landfill post closure plan. Required maintenance of plant landfill, perimeter fence, dams, and structures. Required maintenance of soil conditions at the site, including prevention of ambient dust and maintenance of soil erosion. Coordinate and interface with Nevada State and Clark County regulatory agencies, which will include site inspections and various reports Securing contractor services, and oversee and document the work these contractors will perform. Adminstrative functions associated with managing the site as it relates to the other co-owners, including financial audits as defined in the ownership agreements and the general tracking and documenting of the ongoing O&M costs. B. Accounts for Mohave Have Been Reduced To Two Accounts, ^ W P In SCE's 2009 GRC, we reduced the number of FERC Accounts shown for Mohave s forecast due to limited activity since the station shut down at the end of We continued that process for the 2012 GRC forecast, and again for this 2015 GRC. Specifically, we have consolidated Mohave recorded and forecasted expenditures that usually record to the operations series of FERC Account through into the Miscellaneous Operation account For maintenance activities, we consolidated expenditures that usually record to the maintenance series of FERC Accounts through into the Maintenance of Miscellaneous Steam Plant account ^ W P C. Account Operations Miscellaneous Steam Expenses - Mohave The following operation activities are included in this one FERC Account: Operation Supervision and Engineering. Fuel Related Expense. Operation o f Boiler Plant. 41

43 Operation of Turbine/Generator Plant. Miscellaneous Steam Power Expenses. Rents. For site management, these operations tasks specifically include site patrols, landfill and other ongoing environmental monitoring, ground water testing, and coordination of co-ownership processess. Our 2015 Test Year estimate of Mohave Operations activities is $0.322 million consisting of $0.201 labor (100 percent share) and $0.121 million non-labor (100 percent share). Figure X-10 below shows the recorded expense for the years 2008 through 2012, and our 2013 through 2015 forecast expense (100 percent share). SCE s share of Mohave costs is 56 percent commensurate with our ownership percentage. Figure X-10 Mohave (Miscellaneous Steam Power Expenses) 100% Share Expense FERC Account Mohave Generating Station WP The high cost recorded in 2008 reflects an accounting entry to capture the costs of repair parts and materials remaining in the plant s storeroom inventory. This inventory was salvaged as part of plant decommissioning, and revenues generated from salvage partially offset the cost of the decommissioning. The Test Year forecast of $0.322 million for this account is not based on recorded cost history. Rather it is based on a budgetary estimate to perform the activities discussed above. 42

44 43 W P D. Account Maintenance of Miscellaneous Steam Plant - Mohave The following maintenance activities are included in this one FERC Account: Maintenance Supervision and Engineering Maintenance of Structures Maintenance of Boiler Plant Maintenance of Turbine/Generator Plant Maintenance of Miscellaneous Steam Plant For site management, these maintenance tasks specifically include maintainig water treatment and sampling systems, making repairs to site perimeter fencing, and similar incidental maintenance as it arises. Figure X-11 below shows the recorded expense for the years 2008 through 2012, and our 2013 through 2015 forecast expense (100 percent share). Our 2015 Test Year estimate of Mohave Maintenance activities is $0.229 million, all in non-labor (100 percent Share). SCE's share of Mohave costs is 56 percent commensurate with our ownership percentage. Figure X-11 Mohave (Maintenance of Miscellaneous Steam Plant) 100% Share Expense FERC Account Mohave Generating Station W P The test-year forecast of $0.229 million for this account is not based on recorded cost history. Rather it is based on a budgetary estimate to perform the activities discussed above. 43

45 2015 General Rate Case - APPLICATION INDEX OF WORKPAPERS EXHIBIT SCE-02, Vol 6 Part 1/Generation - Coal O&M DOCUMENT PAGE(S) COAL ACCOUNTS FOUR CORNERS: Account Miscellaneous Steam Power Expenses 1-16 Account Maintenance of Miscellaneous Steam Plant Decommissioning O&M Expenses Accounts , , , , , , , MOHAVE: Account Miscellaneous Steam Power Expenses Account Maintenance of Miscellaneous Steam Plant Accounts , , , , , , Four Corners Project Operating Agreement (relevant pages) 249 a-e CPUC Decisions (relevant pages): Decision No regarding A a Decision No regarding A Decision No regarding A Decision No regarding A Decision No regarding R Decision No regarding A Decision No regarding R Decision No regarding A

46 1 Beginning of Workpapers for: FERC A ccount: W itness: 506 Miscellaneous Steam Power Expenses FOUR CORNERS Thomas G Ware Labor Non-Labor Other Total Forecast Method Chosen Last Recorded Year Last Recorded Year Itemized Forecast Recorded $ (000) , Forecast , ,977 21,015 Description of Activity: This activity shall include the cost of labor, materials used and expenses incurred which are not specifically provided for or are not readily assignable to other steam generation operation expense accounts. Final Cost Centers included in this activity (See Appendix A for additiona l detail): F F F F F F F F F F F900506

47 2 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A ccoun t: A c tivity : W itn e ss: 506 Miscellaneous Steam Power Expense s FOUR CORNERS Thom as G Ware DETERMINATION OF RECORDED/ADJUSTED Recorded Period $ (000) FERC Form 1 Recorded (Nominal $) Labor Non-Labor 6,005 4,156 4,317 3,615 4,258 Other Total 6,011 4,156 4,317 3,615 4,258 Adjustments- (Nominal $) - see Appendix B for additional detail Labor Non-Labor Other , , ,090 14, , , Total 12,396 15,522 15,499 16,104 16,719 Recorded/Adjusted (Nominal $) Labor Non-Labor Other , , ,090 18, , , Total 18,407 19,678 19,816 19,719 20,977 Escalation: Labor Non-Labor Other Recorded/Adjusted (Constant 2012$) Labor , Non-Labor 19,889 20,875 20,048 19,037 19,700 Other Total 20, ,967 21,437 20,283 20,977 Recorded Adjusted (2012$) ,000 12,000 8,000 4, Labor (std escl) Non-Labor (std escl) Other (not escl)

48 3 FERC A ccoun t: A ctivity : W itness: 506 Miscellaneous Steam Power Expenses FOUR CORNERS Thomas G Ware F o re ca stin g M e thod s - S um m ary o f Res u lts o f all M ethods S tu d ie d $ (000) 2 R ecorded Years ( ): o CM CO o CM Results of Averaging (A2) ^ r 2015 sd** Chosen Labor no Non-Labor 19,369 19,369 19, no Other no Total 20,631 20,631 20,631 n/a n/a 3 R ecorded Years ( ): o CM CO Results of Linear Trending (T3) o CM ^ r Results of Averaging (A3) 2015 r2 * Chosen sd** Chosen Labor (2) 0.96 no no Non-Labor 19,247 19,073 18, no 19,595 19,595 19, no Other , no no Total 20,439 20,209 19,979 n/a n/a 20,899 20,899 20,899 n/a n/a 4 R ecorded Years ( ): Labor Non-Labor Other Total CO o CM Results of Linear Trending (T4) ^r o CM 2015 r2 * Chosen CO o CM Results of Averaging (A4) ^r o CM 2015 sd** Chosen no no 18,781 18,328 17, no 19,915 19,915 19, no no no 20,135 19,723 19,311 n/a n/a 21,167 21,167 21,167 n/a n/a 5 R ecorded Years ( ): Labor Non-Labor Other Total O th e r M ethods: CO o CM Results of Linear Trending (T5) ^r o CM 2015 r2 * Chosen CO o CM Results of Averaging (A5) ^r o CM 2015 sd** Chosen no no 19,245 19,024 18, no 19,910 19,910 19, no no no 20,684 20,547 20,408 n/a n/a 21,098 21,098 21,098 n/a n/a Labor Non-Labor Other Total CO o CM Last Recorded Year (LRY) ^r o CM 2015 Chosen CO o CM ^r o CM Itemized Forecast (IF) 2015 Chosen yes no 19,700 19,700 19,700 yes no no yes 20,977 20,977 20,977 n/a n/a Forecast A djustm ents : Labor Non-Labor Other Total Method CO o CM Base Forecast Method ^r o CM 2015 CO o CM ^r o CM Adjustments* LRY LRY 19,700 19,700 19, IF ,989 21,002 21, * r2 = R Squared (Based on recorded years data) ** sd = standard deviation (Based on recorded years data) *** See Appendix B For Additional Detail

49 4 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A ccoun t: A ctiv ity : W itness: 506 Miscellaneous Steam Power Expenses FOUR CORNERS Thomas G Ware R esults: F orecasting Results Method Selected Labor Last Recorded Year Non-Labor Last Recorded Year 19,700 19,700 19,700 Other Itemized Forecast Total 20,989 21,002 21,015 A nalysis o f Forecasting M ethods Analysis of Linear Trending Method: In D and D , the CPUC stated that if costs have sh own a trend in a certain direction over three or more years, the last year recorded is an appropriate base estimate. The years indicate a decreasing trend for labor; therefore, the last year recorded provides the best forecast for estimating labor for test year Other expense also shows a trend for , however, the resulting forecast is higher than our itemized forecast. See discussion under itemized forecast below. Analysis of Averaging Method: In D and D , the CPUC stated that for those accou nts which have significant fluctuations in recorded expenses from year to year, an average of recorded expenses is appropriate. The recorded costs in this account have not fluctuated significantly from , so the averaging methodology is not an appropriate forecast. Analysis of Last Recorded Year (2012): In D and D , the CPUC stated that if recorded expenses in an account have been relatively stable for three or more years, the last recorded year is an appropriate base estimate. Non-labor expenses for have been stable, therefore the use of the last year recorded provides our base for estimating test year As noted above, we chose last recorded year for labor expense. Analysis of Itemized Forecast Method: Itemized forecast is the appropriate forecast method for 'Other' costs determination because it is a calculated annual land lease payment tied to the Consumer Price Index "CPI", published by the U.S. Bureau of Labor Statistics.

50 5 FERC A ccoun t: A c tivity : W itness: 506 Miscellaneous Steam Power Expenses FOUR CORNERS Thomas G Ware Recorded / Forecast $ (000) 24, Labor (std escl) Non-Labor (std escl) Other (not escl) 1 R ecorded Period $ (000) Forecast Expenses (constant 2012$) Labor (standard escalation) , Non-Labor (standard escalation) 19,889 20,875 20,048 19,037 19,700 19,700 19,700 19,700 Other (not escalatable) Total 20,825 21,967 21,437 20,283 20,977 20,989 21,002 21,015 Labor Prior year Total Change Total Non-Labor Prior year Total 19,700 19,700 19,700 Change Total 19,700 19,700 19,700 19,700 Other Prior year Total Change Total Total Change Labor Non-Labor Other Total N/A

51 6 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A ccoun t: A c tivity : W itn e ss: 506 Miscellaneous Steam Power Expenses FOUR CORNERS Thom as G W are This page shows the changes in Labor, Non-Labor, and Other expenditures forecast during 2013 through 2015, including reasons for the addition of personnel (labor), increased office supplies required due to an increase in activity (non-labor) Labor: 0 Not applicable. Non-Labor: 0 Not applicable. Other: 12 Annual land lease payment is tied to the "CPI" that is published in April every year by the U.S. Bureau of Labor Statisics.

52 7 FERC A ccount: A ctiv ity : W itness: 506 Miscellaneous Steam Power Expenses FOUR CORNERS Thomas G Ware This page shows the changes in Labor, Non-Labor, and Oth er expenditures forecast during 2013 through 2015, including reasons for the addition of personne l (labor), increased office supplies required due to an increase in activity (non-labor) Labor: 0 Not applicable. Non-Labor: 0 Not applicable. Other: 13 Annual land lease payment is tied to the "CPI" that is published in April every year by the U.S. Bureau of Labor Statisics.

53 8 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A ccoun t: A ctivity : W itness: 506 Miscellaneous Steam Power Expenses FOUR CORNERS Thomas G Ware This page shows the changes in Labor, Non-Labor, and Oth er expenditures forecast during 2013 through 2015, including reasons for the addition of personnel (labor), increased office supplies required due to an increase in activity (non-labor) Labor: 0 Not applicable. Non-Labor: 0 Not applicable. Other: 13 Annual land lease payment is tied to the "CPI" that is published in April every year by the U.S. Bureau of Labor Statisics.

54 9 FERC A ccount W itn e ss: 506 Miscellaneous Steam Power Expenses FOUR CORNERS Thomas G Ware APPENDIX A D e t a i l D e s c r i p t i o n o f F i n a l C o s t C e n t e r s I n c l u d e d i n T h i s A c t i v i t y

55 10 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A ccoun t: Activity: W itness: 506 Miscellaneous Steam Power Expenses f o u r c o r n e r s Thomas G Ware Description o f Final Cost Centers included in this activity: F FOUR CORNERS 500 OPERATIONS SUPP ORT AND ENGINEERING Includes labor, material, contract, and other costs o f shift supervisors and operating forem an incurred in connection w ith supervision o f station operation not specifically applicable to other operation function activities. F FOUR CORNERS 501 FUEL Includes labor and non-labor expense for the receiving, storage, and handling o f fuel and rem oval/disposal o f com bustion residual ash. Includes expenses for operations and the m aintenance of the fuel handling equipm ent. The expense o f coal and gas fuel consum ed at the plants is not included in this application. F FOUR CORNERS 502 STEAM EXPENSE Includes expenses incurred to operate the furnace and boiler system s used for the production o f steam for electric generation. It includes the salary expense for operators and technicians and part o f the salary of the ir supervisors. Som e of these operators w ork in control room s where they monitor, control, schedule and docum ent the operation o f the boiler plant. O ther operator classifications w ork throughout the plant and physically operate valves and controls o f equipm ent associated with the boiler system s. Also includes part o f the salary and other expense for technicians w ho control the w ater chemistry aspects related to the production of steam. F FOUR CORNERS 505 ELECTRICAL EXPENSE Includes labor, material, contract, and other costs involved in system operation coordination, equipm ent operation/m onitoring, and operating procedures developm ent in relation to the prime mover, generator, and auxiliary electrical system s. The related prim e m over and generator equipm ent includes turbine/engine, generator and exciter, steam stop and throttle valves/piping, condenser and cooling w ater system s, condensate system, genera tor-cooling system s, lubricating and control oil system s, and associated m otor drives, starters/breakers, perform ance, and control system s. The related auxiliary electrical equipm ent includes statio n electric busses, main generator connections, auxiliary and reserve transformers, battery systems, and indicating and supervisory systems. F FOUR CORNERS 506 MISCELLANEOUS STEAM EXPENSE Includes m aterial cost o f all m iscellaneous m aterials that otherwise cannot be identified, planned, and recorded to specific activities. M aterials falling in this category include lubricants, cooling and insulating gases, gaskets/ packing, gauge g lasses, indicating lamps, paint, bar steel, brass rods, cast iron, copper tubing, elbows, nipples, tees, unions, cylinder dem urrage, etc. Also includes miscellaneous labor cost such as the Employee Incentive Plan. F FOUR CORNERS 507 RENTS Includes costs for the rental o f real property used, occupied, or operated in connection with Steam facilities including the rental o f stationary trailers used for conference rooms, office facilities, etc. This activity does not include labor and m aterials, cylinder dem urrage, and rental o f office equipm ent, post-office boxes, w ater coolers, etc. F FINANCIAL SERVICES FOUR CORNERS 500 OPERATION SUPPORT & ENGINEERING Includes labor, material, contract, and other costs incurred in connection with operation, supervision, and adm inistration not specifically applicable to other operation function activities. Tasks include annual budget developm ent, budget m onito ring/control/forecasting, payroll reporting, personnel/benefits administration and staff administrative support services.

56 11 FERC A ccoun t: Activity: W itn e ss: 506 Miscellaneous Steam Power Expenses f o u r c o r n e r s Thom as G W are Description o f Final Cost Centers included in this activity: F OPERATIONS SUPPORT & PERFORM ANCE IMPROVEM ENT - FOUR CORNERS 500 OPERATION SUPERVISION & ENGINEERING Includes labor, material, contract, and other costs incurred in connection with operation, supervision and engineering not specifically applicable to other operation function activities. O ther tasks include, annual budget developm ent, coordinate departm ent goal setting and perform ance tracking, prepare departm ent business plan and long-range m aintenance plan, coordinate departm ental workforce attrition planning, m anage departm ent participation in regulatory proceedings, coordinate departm ental regulatory and safety com pliance activities, evaluate im pacts o f potential changes to SCE power generating, m aintain departm ent policies, and coordinate departm ental participation in com pany - workers union activities (e.g., contract negotiations). F FOUR CORNERS LABO R 501 FUEL Includes salaries and expenses o f Power Procurem ent B usiness U nit (PPBU) personnel or the Coal Contract Administration Group. F BUSINESS PLANNING & D EVELO PM ENT - FOUR CORNERS 500 OPERATION SUPERVISION & ENGINEERING Includes labor, material, contract, and other costs incurred in connection with operation, supervision and engineering not specifically applicable t o other operation function activities. O ther tasks include, annual budget developm ent, coordinate departm ent goal setting and perform ance tracking, prepare departm ent business plan and long-range m aintenance plan, coordinate departm ental workforce attrition planning, m anage departm ent participation in regulatory proceedings, coordinate departm ental regulatory and safety com pliance activities, evaluate im pacts o f potential changes to SCE power generating, m aintain departm ent policies, and coordinate departm ental participation in com pany - workers union activities (e.g., contract negotiations). F FOUR CORNERS CORPORATE ADJUSTMENT MISCELLANEOUS STEAM EXPENSE Miscellaneous steam power expenses accrual for accounts payable.

57 12 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t W itness: 506 M iscellaneous Steam Power Expenses FOUR CORNERS Thomas G Ware Recorded/Adjusted (Cons tant 2012$) By Final Cost Center $ (000) F F FOUR CORNERS 500 OPERATIONS SUPPORT AND ENGINEERING FOUR CORNERS 501 FUEL 700 1,029 1,450 1,729 1,021 3,775 4,234 3,574 3,114 3,192 F FOUR CORNERS 502 STEAM EXPENSE 8,745 9,762 9,073 9,608 9,939 F F F FOUR CORNERS 505 ELECTRICAL EXPENSE FOUR CORNERS 506 MISCELLANEOUS STEAM EXPENSE FOUR CORNERS 507 RENTS ,315 4,647 4,659 3,709 4, F F F FINANCIAL SERVICES FOUR CORNERS 500 OPERATION SUPPORT & ENGINEERING OPERATIONS SUPPORT & PERFORMANCE IMPROVEMENT - FOUR CORNERS 500 OPERATION SUPERVISION & ENGINEERING FOUR CORNERS LABOR 501 FUEL 1, F BUSINESS PLANNING & DEVELOPMENT - FOUR CORNERS 500 OPERATION SUPERVISION & ENGINEERING , F FOUR CORNERS CORPORATE ADJUSTMENT MISCELLANEOUS STEAM EXPENSE Total 20,824 21,966 21,437 20,284 20,977 ** Due to rounding, totals m ay not tie to other workpaper pages.

58 13 FERC A ccount: W itness: 506 Miscellaneous Steam Power Expenses FOUR CORNERS Thomas G Ware APPENDIX B D e t a i l o f T o t a l C o m p a n y A d j u s t m e n t s t o R e c o r d e d

59 14 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A ccoun t: W itness: 506 Miscellaneous Steam Power Expenses FOUR CORNERS Thomas G Ware D etail o f Total C om p any A d j u stm e n ts to R ecorded Expenses A d js - (N om inal $) $ (000) Labor , Non-Labor 11,554 14,514 14, ,885 15, O ther Total 12,396 15,522 15,499 16,104 16, Organizational Unit Adjustm ent 1 GBU-CPT-OU-4C ROLL UP TO 506 This adjustment transfers expenses from FERC 500, 501, 502, 505, and 507 to FERC 506 Operations. Labor , Non-Labor 12,867 14,514 14,409 15,274 16, O ther Total 13,715 15,522 15,499 16,104 16, Organizational Unit Adjustm ent 2 GBU-CPT-OU-4C ADJUSTMENT TO OTHER To reflect the normal expected paym ent p a tte rn, adjustm ent to move the expenses from the non-labor to the other category as these am ounts are not subject to escalation. Labor N on-labor 0 0 (223) (389) (567) O ther Total Organizational Unit Adjustm ent 3 GBU-CPT.LM M -OUX-GP&S 557 For historical consistency, this adjustment transfers integrated planning expenses from Generation FERC 500, 501, 506, 535 and 546 to FERC 557 where they are being forecast. Labor (6 ) Non-Labor O ther Total (6 ) Organizational Unit Adjustm ent 4 GBU-CPT-OU-4C REMAP FCC A credit was recorded to FERC 506 that should have been recorded to FERC 507. This adjustment corrects the error. Labor Non-Labor (263) O ther Total (263)

60 15 FERC A ccoun t: W itness: 506 Miscellaneous Steam Power Expenses FOUR CORNERS Thomas G Ware D etail o f Total C om p any A d ju s tm e n ts to R ecorded Expenses A d js - (N om inal $) $ (000) Organizational Unit Adjustm ent 5 GBU-CPT-OU-4C REMAP TO A Corporate Regulatory Accounting adjustm ent w as recorded to FERC Four C orners that should have been recorded to FERC Mohave. This adjustment corrects the error. Labor Non-Labor O ther 0 (391) Total (391) Organizational Unit Adjustm ent 6 GBU-CPT-OU-4C ADJ 506 TO 501 Expenses were recorded to FERC Four Corners in 2008 that should have been recorded in FERC Mohave. This adjustment corrects the error. Labor Non-Labor (659) O ther Total (659)

61 16 Workpaper - Southern California Edison / 2015 GRC - APPLICATION End of Workpapers for: FERC A ccoun t: W itness: 506 Miscellaneous Steam Power Expenses FOUR CORNERS Thomas G Ware

62 17 Beginning o f Workpapers for: FERC A ccount: W itness: 514 Maintenance of Miscellaneous Steam Plant FOUR CORNERS Thomas G Ware Forecast Method Chosen Recorded $ (000) Forecast 2015 Labor Non-Labor Other Total N/A Two Year Average N/A 0 20, , , ,418 Description o f Activity: This activity shall include the cost of labor, materials used and expenses incurred in maintenance of miscellaneous steam generation plant. The book cost is included in account 316, Miscellaneous Power Plant Equipment. Final Cost Centers included in this activity (See Appendix A for additiona I detail): F F F F F F527010

63 18 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A ccount: A c tivity : W itness: 514 Maintenance of Miscellaneous Steam Plant FOUR CORNERS Thomas G Ware DETERMINATION OF RECORDED/ADJUSTED \ Recorded Period $ (000) FERC Form 1 Recorded (Nominal $) Labor Non-Labor 5,105 3,987 4,038 5,068 4,696 Other Total 5,105 3,987 4,038 5,068 4,696 Adjustments- (Nominal $) - see Appendix B for additional detail Labor Non-Labor Other 0 21, , , , ,264 Total 21,292 15,437 23,822 20,078 16,264 0 Recorded/Adjusted (Nominal $) Labor Non-Labor Other 0 26, , , , ,960 Total 26,397 19,424 27,860 25,146 20,960 0 Escalation: Labor Non-Labor Other Recorded/Adjusted (Constant 2012$) Labor Non-Labor 29,900 21,718 30,186 25,876 20,960 Other Total 29,900 21,718 30,186 25,876 20, Recorded Adjusted (2012$) ,000 12,000 8,000 4, Labor (std escl) Non-Labor (std escl) Other (not escl)

64 19 FERC A ccoun t: A c tivity : W itness: 514 Maintenance of Miscellaneous Steam P lant FOUR CORNERS Thomas G Ware F o re ca stin g M e thod s - S um m ary o f Res u lts o f all M ethods S tudie d $ (000) 2 R ecorded Years ( ): CO o CM Results of Averaging (A2) ^r o CM 2015 sd** Chosen Labor no Non-Labor 23,418 23,418 23,418 2,458 yes Other no Total 23,418 23,418 23,418 n/a n/a 3 R ecorded Years ( ): CO o CM Results of Linear Trending (T3) ^r o CM 2015 r2* Chosen CO o CM Results of Averaging (A3) ^r o CM 2015 sd** Chosen Labor no no Non-Labor 16,448 11,835 7, no 25,674 25,674 25,674 3,769 no Other no no Total 16,448 11,835 7,222 n/a n/a 25,674 25,674 25,674 n/a n/a 4 R ecorded Years ( ): CO o CM Results of Linear Trending (T4) ^r o CM 2015 r2* Chosen CO o CM Results of Averaging (A4) ^r o CM 2015 sd** Chosen Labor no no Non-Labor 23,039 22,381 21, no 24,685 24,685 24,685 3,686 no Other no no Total 23,039 22,381 21,723 n/a n/a 24,685 24,685 24,685 n/a n/a 5 R ecorded Years ( ): o CM CO Results of Linear Trending (T5) o CM ^ r 2015 r2* Chosen o CM CO o CM Results of Averaging (A5) ^ r 2015 sd** Chosen Labor no no Non-Labor 21,612 20,240 18, no 25,728 25,728 25,728 3,902 no Other no no Total 21,612 20,240 18,868 n/a n/a 25,728 25,728 25,728 n/a n/a O th er M ethods: Labor Non-Labor Other Total o CM CO o CM Last Recorded Year (LRY) ^ r 2015 I Chosen o CM CO o CM Itemized Forecast (IF) ^ r 2015 Chosen no no 20,960 20,960 20,960 no no no no 20,960 20,960 20,960 n/a n/a Forecast A djustm ents : Labor Non-Labor Other Total Method CO o CM Base Forecast Method ^r o CM 2015 CO o CM ^r o CM Adjustments* N/A A2 23,418 23,418 23, N/A ,418 23,418 23, * r2 = R Squared (Based on recorded years data) ** sd = standard deviation (Based on recorded years data) *** See Appendix B For Additional Detail

65 20 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A ccoun t: A c tivity : W itn e ss: 514 Maintenance of Miscellaneous Steam Plant FOUR CORNERS Thom as G W are R esults: F o re ca stin g R esults Method Selected Labor N/A Non-Labor Two Year Average 23,418 23,418 23,418 Other N/A Total 23,418 23,418 23,418 A nalysis o f Forecasting M ethods Analysis of Linear Trending Method: In D and D , the CPUC stated that if costs have sh own a trend in a certain direction over three or more years, the last year recorded is an appropriate base estimate. The years show a strong trend, however, 2010 expenses are not a good representation of historical costs for this account because of a maintenance outage. Please see discussion in averaging section below Analysis o f Averaging Method: In D and D , the CPUC stated that for those accounts which have significant fluctuations in recorded expenses from year to year, an average of recorded expenses is appropriate. The years demonstrate significant fluctuations, indicating averaging as an appropriate method. We exclude the 2010 maintenance outage year and prior years to arrive at a lower, more reasonable basis for averaging forecast costs using a two-year forecast of Analysis of Last Recorded Year (2012): In D and D , the CPUC stated that if recorded expenses in an account have been relatively stable for three or more years, the last recorded year is an appropriate base estimate. The non-labor expenses have not been stable, eliminating the use of this forecasting method. Analysis of Itemized Forecast Method: Not applicable.

66 21 FERC A ccoun t: A c tivity : W itn e ss: 514 Maintenance of Miscellaneous Steam Plant FOUR CORNERS Thom as G W are Recorded / Forecast $ (000) ,000 12,000 8,000 4, Labor (std escl) Non-Labor (std escl) Other (not escl) Reco rded Period $ (000) Forecast Expenses (constant 2012$) Labor (standard escalation) Non-Labor (standard escalation) 29,900 21,718 30,186 25,876 20,960 23,418 23,418 23,418 Other (not escalatable) Total 29,900 21,718 30,186 25,876 20,960 23,418 23,418 23,418 Labor Prior year Total Change Total Non-Labor Prior year Total 20,960 23,418 23,418 Change 2, Total 20,960 23,418 23,418 23,418 Other Prior year Total Change Total Total Change Labor Non-Labor 2, Other Total N/A 2,

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68 23 FERC A ccount W itness: 514 Maintenance of Miscellaneous Steam Plant FOUR CORNERS Thomas G Ware APPENDIX A D e t a i l D e s c r i p t i o n o f F i n a l C o s t C e n t e r s I n c l u d e d i n T h i s A c t i v i t y

69 24 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A ccoun t: Activity: W itness: 514 Maintenance of Miscellaneous Steam Plant f o u r c o r n e r s Thomas G Ware Description o f Final Cost Centers included in this activity: F FOUR CORNERS 510 MAINTENANCE SUPPORT AND ENGINEERING Includes labor, material, contract, and other costs o f forem en, planners, and m aintenance engineers in the direct supervision o f routine m aintenanc e o f structures, turbines, boilers, and auxiliary equipm ent not specifically applicable to other maintena nce function activities. F FOUR CORNERS 511 MAINTENANCE STRUCTURE Includes labor, material, contract, and other costs for m ajor m aintenance, repairs, and im provem ents of structures, facilities, and grounds. Relates to costs associated with the heating system s and auxiliary (non-pow er producing) boilers, general lighting and ventilation, sum p pumps, yard lighting/drainage, w ater supply, hydrants, wells, w harves, docks, w aterfront im provem ents, coal bins and bunkers, elevators, and pest control. F FOUR CORNERS 512 MAINTENANCE BOI LER Includes labor, material, contract, and other costs for m aintenance on the boiler system s. Relates to costs associated with boiler and auxiliaries, steam system s, fire-side/fuel- burning equipm ent, ash-handling equipm ent, and associated m otor drives, starters/breakers, and perform ance and control system s. F FOUR CORNERS 513 MAINTENANCE ELECTRICAL Includes labor, material, contract, and other costs for m aintenance on the prim e m over and generator system s. Relates to costs associated with the engine, generator and exciter, steam stop and throttle valves/piping, condenser and cooling-w ater system s, generator cooling system s, lubricating and control oil system s, and associated m otor drives, starters/breakers, and perform ance and control system s. F FOUR CORNERS 514 MAINTENANCE MISCELLANEOUS STEAM Includes labor, material, contract, and other costs for corrective m aintenance on the balance o f plant system s. Relates to costs associated with com pressed air system s, fire protection system s, com m unication system s, refrigeration system s, marine equipm ent, and associated m otor drives, starters/breakers, and control systems. F FOUR CORNERS 556 SYSTEM LOAD DISPATCH This account includes the cost o f labor and expenses incurred in load dispatching activities for system control for Utilities having an interconnected electric system w hich controls the production and dispatching.

70 25 FERC A ccoun t: A ctivity : W itness: 514 Maintenance of Miscellaneous Steam Plant FOUR CORNERS Thomas G Ware Recorded/Adjusted (Constant 2012$) By Final Cost Center $ (000) F F F F F F FOUR CORNERS 510 MAINTENANCE SUPPORT AND ENGINEERING FOUR CORNERS 511 MAINTENANCE STRUCTURE FOUR CORNERS 512 MAINTENANCE BOILER FOUR CORNERS 513 MAINTENANCE ELECTRICAL FOUR CORNERS 514 MAINTENANCE MISCELLANEOUS STEAM FOUR CORNERS 556 SYSTEM LOAD DISPATCH ,353 1,430 1, ,736 13,482 15,722 14,805 11,588 4,923 1,909 7,439 3,043 2,318 5,782 4,458 4,375 5,215 4, Total 29,900 21,719 30,185 25,876 20,960 * Due to rounding, totals m ay not tie to other workpaper pages.

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72 27 FERC A ccount: W itness: 514 Maintenance of Miscellaneous Steam Plant FOUR CORNERS Thomas G Ware APPENDIX B D e t a i l o f T o t a l C o m p a n y A d j u s t m e n t s t o R e c o r d e d

73 28 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A ccoun t: A ctivity : W itness: 514 Maintenance of Miscellaneous Steam Plant FOUR CORNERS Thomas G Ware D etail o f Total C om p any A d j u stm e n ts to R ecorded E xpenses A d js - (N om inal $) $ (000) Labor Non-Labor 21,292 15,437 23,822 20,078 16, O ther Total 21,292 15,437 23,822 20,078 16, Organizational Unit Adjustm ent 1 GBU-CPT-OU-4C ROLL UP TO 514 This adjustment transfers expenses from FERC 510, 511, 512, and 513 and to FERC 514 Maintenance. Labor Non-Labor 21,292 15,437 23,205 19,436 15, O ther Total 21,292 15,437 23,205 19,436 15, O rganizational Unit Adjustm ent 2 GBU NUC-K LB.C PT-O U X -PV TRANSFER TO FC This adjustment transfers expenses incorrectly recorded as Palo Verde expense from FERC account 556 to FERC account 514. Labor o o o Non-Labor O ther Total

74 29 End of Workpapers for: FERC A ccoun t: W itness: 514 Maintenance of Miscellaneous Steam Plant FOUR CORNERS Thomas G Ware

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76 31 Decommissioning O&M Expenses

77 32 Workpaper - Southern California Edison / 2015 GRC - APPLICATION Mohave Recorded O&M Expense Constant 2006 $ GRC Testimony Year % OWNER SHARE Operations 24,839 12,428 Maintenance 29,401 11,480 Total 54,240 23,908 SCE 56% SHARE Total 30,374 13,388 Mohave Worker Protection Expenses Nominal $000 (SCE Share) ERRA Review Phase Proceeding 2010 Record Period Year Worker Protection 0 15,562 GRAND TOTAL 30,374 28,950

78 33 Application N o.: Exhibit No.: Witnesses: SCE-02, Vol. 7 Ch. I-IX G. Butts P. Phelan T. Ware SOUTHERN CALIFORNIA EDISON An EDISON INTERNATIONAL Company (U 338-E) 2009 General Rate Case Generation Volume 7 - Coal Operation And Maintenance Expenses (O&M) Chapters I-IX Before the Public Utilities Commission of the State of California Rosemead, California November 2007

79 Figure IX-22 Mohave (Miscellaneous Steam Power Expenses) FERC Account MohaveGenerating Station) R e c o rd e d a n d A d ju s te d /F o re c a s t J O M O H A V E - M IS C E L L A N E O U S S T E A M P O W E R E X P E N S E S (C onstant 2000 SOOO) $ 3 2,0 0 0 $ 2 8,0 0 0 $ 2 4,0 0 0 $20,000 $ 1 6,0 0 0 $12,000 $8,000 $ 4,0 0 0 SO III L a b o r ( s td e s c l) N o n -L a b o r ( s t d e s c l) a O th e r ( n o t e s c l) L a b o r 1 3, , , , , N o n.l a b o r , ,720 4,000 1,700 1,700 O th e r T o ta l , ,428 10,000 2,000 2,000 i -Forecast a) Analysis of Recorded and Forecast Expenses The years 2002 through 2004 reflect normal operations for Mohave. Recorded expense in 2005 reflects reduced expenditures in anticipation of the pending shut down in Finally, 2006 reflects the first year of shut down. During 2006, the plant went through a transition from full 5 6 operation to lay-up status. Systems were deactivated and put into a preserved status. Staffing was reduced from 365 employees to 65 by year end. The test-year forecast of $2.0 million reflects one half 7 o f the expenditures listed in the previous section II C. Maintenance of Miscellaneous Steam Plant - Mohave Account For this showing the following maintenance activities are shown in this one FERC Account: Maintenance Supervision and Engineering Maintenance o f Structures 79

80 Maintenance o f Boiler Plant Maintenance o f Turbine/Generator Plant Maintenance o f Miscellaneous Steam Plant 4 Our test year estimate of Mohave Maintenance activities is $2,000 million consisting of 5 $300,000 labor and $1,700 million non-labor (100% share). Figure IX-23 below shows the recorded expense for the years 2002 through 2006 and our forecast for 2007 through 2009 (100% Basis): Figure IX-23 Mohave (Maintenance o f Miscellaneous Steam Plant) FERC Account Mohave Generating Station R e c o rd e d a n d A d ju s te d T o re c a s t M O H A V E - M A IN T E N A N C E O F M IS C E LLA N E O U S STEAM PLA N T (C onstant 2006 $000) $ 5 0,0 0 0 $ 4 5,0 0 0 $ 4 0,0 0 0 $ $ 3 0,0 0 0 $ 2 5,0 0 0 $20,000 $ 1 5,0 0 0 $ 10,000 $ 5,0 0 0 $ Labor ( std e sc!) N on-labor ( std s s c l) O ther ( not e scl) Lab cm N o n L a b o r O ther T otal ,000 2,000 2, i forecasta) Analysis of Recorded and Forecast Expenses Labor for 2002 through 2004 was within normal variation but declined in 2005 as vacancies were left open and some employees sought work at other locations in anticipation of the pending shut down in Recorded labor in 2006 reflects the reduction in forces from 365 employees 11 to 65 by year end. Non-Labor over the same period shows a steady decline as only maintenance 12 required to keep the units running through the end of 2005 was accomplished. Finally, 2006 reflects the 80

81 36 Workpaper - Southern California Edison / 2015 GRC - APPLICATION Application N o.: Exhibit No.: SCE-2 Witnesses: D. Cox V. Myers-Voumakis B. Gilman G. Stern S. Willis G. Huckaby T. Watson J. Cherrie D. Snow T. W alker M. Bennett S. Kiner P. McGregor P. Campbell A. Sudbury L. Vellanoweth G. Henry K. Pickrahn T. Frontino P. Phelan M. Nelson D. Adams SOUTHERN CALIFORNIA EDISON' An EDISON INTERNATIONAL Company (U 338-E) Before the Energy Resource Recovery Account (ERRA) Review of Operations, 2010 Chapters IX-XVI PUBLIC VERSION Public Utilities Commission of the State of California Rosemead, California April 1, 2011

82 37 Table XVI-54 Mohave Balancing Account ($000) Line No Description Total 1. Beginning Balance,,,, Capital-Related Expenses 3. - Depreciation Property Taxes Income Taxes Return Total-Capital Related Expenses Operating Expenses 9. - MERMA Transfer O&M Costs A&G Expenses & Payroll Taxes A&G Participant Credit (5.365) (1.948) (1.049) (952) (758) (10.072) Worker Protection Expenses Total Operating Expenses 1/ Total Revenue Requirement (Line 7 + Line 14) Authorized Revenue Requirement 2/ (55.384) (41.867) (43.162) (17.876) (18.636) ( ) 17. (Over) ( nder Collection (Line 15 + Line 16) (5.632) (11.883) (11.835) (1.595) (29.269) 18. Interest (116) (242) (68) 1 6 (420) 19. Ending Balance (Line 17 + Line 18) (5.749) (12.124) (11.902) (1.594) (29.688) 20. Transfer to BRRBA (1.681) Ending Balance / Represents SCE's share 2 / Not including FF& U 1 D. Mohave Capital-Related Revenue Requirement 2 During the Mohave Record Period, SCE recorded on a monthly basis the capital-related expenses 3 associated with the recorded net plant investment as of December 31, 2005 and recorded 4 deconunissioning-related expenses, as incurred. As shown on Line 7 o f Table XVI-54, the amount of 5 capital-related revenue requirement totaled $91,294 million. The capital-related revenue requirement 6 includes: (1) depreciation expense based on the adopted depreciation rates; (2) return based on the 7 authorized rate of return on rate base; and (3) associated income taxes, income tax-related amounts, and 8 ad valorem taxes. 173

83 38 Workpaper - Southern California Edison / 2015 GRC - APPLICATION Beginning o f Workpapers for: FERC A cc o u n t: W itn e s s : 500 O peration Supervision and Engineering FOUR CORNERS Thom as G W are Forecast Method Chosen Recorded $ (000) Forecast 2015 Labor N/A 0 0 Non-Labor N/A 0 0 Other N /A 0 0 Total 0 0 Description o f A ctivity: This activity shall include the cost of labor and expenses incurred in the general supervision and direction of the operation of steam power generating stations. Direct supervision of specific activities, such as fuel handling, boiler room operations, generator operations, etc., shall be charged to the appropriate account. This activity package has zero dollars; all costs have been transferred to other activities. Final Cost Centers included in this activity (See Appendix A for additional detail): F F F F526234

84 39 FERC A ccoun t: W itn e s s : 500 O peration Supervision and Engineering FOUR CORNERS T hom as G W are I DETERMINATION OF RECORDED/ADJUSTED Recorded Period $ (0 0 0 ) FERC Form 1 Recorded (Nom inal $) Labor , N on-labor 1,054 1,276 1,731 1,920 1,174 O ther Total 1,700 2,105 2,863 2,781 1,884 Adjustments- (Nominal $) - see Appendix B for additional detail Labor (646) (829) (1,132) (861) (710) N on-labor (1,054) (1,276) (1,731) (1,920) (1,174) O ther Total (1,700) (2,105) (2,863) (2,781) (1,884) Recorded/Adjusted (Nominal $) Labor N on-labor O ther Total E s c a la tio n : Labor N on-labor O ther Recorded/Adjusted (Constant 2012$) L ab or N on-labor O ther Total Recorded Adjusted (2012$) ,, Labor (std escl) Non-Labor (std escl) Other (not escl)

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86 41 FERC A c c o u n t W itn e s s : 500 O peration S upervision and Engineering FO UR CORNERS Thom as G W are APPENDIX A Detail Description of Final Cost Centers Included in This Activity

87 42 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 500 Operation Supervision and Engineering FOUR CORNERS Thom as G W are Recorded/Adjusted (Constant 2012$) By Final Cost Center $ (0 0 0 ) F F F FOUR CORNERS 500 OPERATIONS SUPPORT AND ENGINEERING FINANCIAL SERVICES FOUR CORNERS 500 OPERATION SUPPORT & ENGINEERING OPERATIONS SUPPORT & PERFORMANCE IMPROVEMENT - FOUR CORNERS 500 OPERATION SUPERVISION & ENGINEERING F BUSINESS PLANNING & DEVELOPMENT - FOUR CORNERS 500 OPERATION SUPERVISION & ENGINEERING Total ** Due to rounding, totals m ay not tie to other workpaper pages.

88 43 FERC A c c o u n t: W itn e s s : 500 O peration Supervision and Engineering FO UR CORNERS Thom as G W are APPENDIX B Detail of Total Company Adjustments to Recorded

89 44 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 500 O peration Supervision and Engineering FOUR CORNERS Thom as G W are D etail o f Total C o m p a n y A d ju s tm e n ts to R eco rd e d E xp e n se s A d js - (N o m in a l $) $ (0 0 0 ) Labor (646) (829) (1,132) (861) (710) N on-labor (1,054) (1,276) (1,731) (1,920) (1,174) O ther Total (1,700) (2,105) (2,863) (2,781) (1,884) Organizational Unit Adjustm ent 1 A&G FINC-RSL.CPT-OUX-CNTRLS -XFER TO GBU This adjustm ent transfers labor recorded in Financial Services Miscellaneous Expenses 930 to FERC accounts 500, 535 and 546. Labor N on-labor O ther Total Organizational Unit Adjustm ent 2 GBU -CPT.LM M -OUX-GP& S 557 This adjustm ent transfers integrated planning expenses from Generation FERC 500, 501, 506, 535 and 546 to FERC 557 for historical consistency and w here they are being forecast. Labor (39) (44) (42) (31) N on-labor (11) (15) (24) (14) O ther Total (50) (59) (6 6 ) (45) Organizational Unit Adjustm ent 3 GBU-C PT-O U -4C ROLL UP TO 506 This adjustm ent transfers expenses from FERC 500, 501, 502, 505, and 507 to FERC 506 Operations. Labor (625) (785) (1,090) (830) (710) N on-labor (1,043) (1,261) (1,706) (1,907) (1,174) O ther Total (1,668) (2,046) (2,796) (2,737) (1,884) 0 0 0

90 45 End o f Workpapers for: FERC A c c o u n t: W itn e s s : 500 Operation Supervision and Engineering FOUR CORNERS Thom as G W are

91 46 Workpaper - Southern California Edison / 2015 GRC - APPLICATION Beginning o f Workpapers for: FERC A c c o u n t: W itn e s s : 501 Fuel FOUR CORNERS Thom as G W are Forecast Method Chosen Recorded $ (000) Forecast 2015 Labor N/A 0 0 Non-Labor N/A 0 0 Other N /A 0 0 Total 0 0 Description o f A ctivity: For SCE's General Rate Case application this activity does not include the cost of fuel used in the production of steam for the generation of electricity. However, it does include expenses in unloading fuel from the shipping media and handling thereof up to the point where the fuel enters the first boiler plant bunker, hopper, bucket, tank or holder of the boiler-house structure. Additionally, it includes the handling and disposal expense for residual ash and proceeds from the sale of fly ash. This activity package has zero dollars; all costs have been transferred to other activities. Final Cost Centers included in this activity (See Appendix A for additional detail): F F F900501

92 47 FERC A ccoun t: W itn e s s : 501 Fuel FOUR CORNERS T hom as G W are I DETERMINATION OF RECORDED/ADJUSTED Recorded Period $ (0 0 0 ) FERC Form 1 Recorded (Nominal $) L ab or N o n-labor 2,645 3,787 3,388 3,028 3,192 O th e r Total 2,653 3,805 3,483 3,089 3,192 Adjustments- (Nominal $) - see Appendix B for additional detail Labor (8) (18) (95) (61) 0 N on-labor (2,645) (3,787) (3,388) (3,028) (3,192) O ther Total (2,653) (3,805) (3,483) (3,089) (3,192) Recorded/Adjusted (Nominal $) Labor Non-Labor O ther Total E s c a la tio n : Labor Non-Labor O ther Recorded/Adjusted (Constant 2012$) L ab or Non-Labor O ther Total Recorded Adjusted (2012$) ,, Labor (std escl) Non-Labor (std escl) Other (not escl)

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94 49 FERC A c c o u n t W itn e s s : 501 Fuel FOUR CORNERS Thom as G W are APPENDIX A Detail Description of Final Cost Centers Included in This Activity

95 50 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e ss: 501 Fuel FOUR CORNERS Thom as G W are Recorded/Adjusted (Constant 2012$) By Final Cost Center $ (0 0 0) F FOUR CORNERS 501 FUEL F FOUR CORNERS LABOR 501 FUEL F FOUR CORNERS CORPORATE ADJUSTMENT-501 FUEL Total ** Due to rounding, totals m ay not tie to other workpaper pages.

96 51 FERC A c c o u n t W itness: 501 Fuel FOUR CORNERS Thom as G W are APPENDIX B Detail of Total Company Adjustments to Recorded

97 52 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e ss: 501 Fuel FOUR CORNERS Thom as G W are D etail o f Total C om p any A d ju s tm e n ts to R ecorded E xpenses A d js - (N om inal $) $ (0 0 0) Labor (8) (18) (95) (61) N on-labor (2,645) (3,787) (3,388) (3,028) (3,192) Other Total (2,653) (3,805) (3,483) (3,089) (3,192) Com pany W ide Adjustm ent 1 G R C -K B S-C W -FC FU E LA C C R U A L This adjustm ent removes the accrual/reversal of the accrual of fuel expenses. Labor Non-Labor Other Total O rganizational Unit Adjustm ent 1 G B U -C P T-O U -4C ADJ 506 TO 501 Expenses w ere recorded to FERC Four C orners in 2008 that should have been recorded in FER C Mohave. This adjustm ent corrects the error. Labor N on-labor O ther Total O rganizational Unit Adjustm ent 2 GBU -CPT.LM M -OUX-GP& S 557 This adjustm ent transfers integrated planning expenses from Generation FERC 500, 501, 506, 535 and 546 to FERC 557 for historical consistency and w here they are being forecast. Labor (8) (18) (95) (61) N on-labor 0 0 (89) (2) O ther Total (8) (18) (184) (63) Organizational Unit Adjustm ent 3 GBU-C PT-O U -4C ROLL UP TO 506 This adjustm ent transfers expenses from FERC 500, 501, 502, 505, and 507 to FERC 506 Operations. Labor N on-labor (3,333) (3,787) (3,299) (3,026) (3,192) O ther Total (3,333) (3,787) (3,299) (3,026) (3,192) 0 0 0

98 53 End o f Workpapers for: FERC A c c o u n t: W itn e s s : 501 Fuel FOUR CORNERS T hom as G W are

99 54 Workpaper - Southern California Edison / 2015 GRC - APPLICATION Beginning o f Workpapers for: FERC A c c o u n t: W itn e s s : 502 S team Expenses FOUR CORNERS Thom as G W are Forecast Method Chosen Recorded $ (000) Forecast 2015 Labor N/A 0 0 Non-Labor N/A 0 0 Other N /A 0 0 Total 0 0 Description o f A ctivity: This activity shall include the cost of labor, materials used and expenses incurred in production of steam for electric generation. This includes all expenses of handling and preparing fuel beginning at the point where the fuel enters the first boiler plant bunker, hopper, tank or holder of the boiler-house structure. This activity package has zero dollars; all costs have been transferred to other activities. Final Cost Centers included in this activity (See Appendix A for additional detail): F201209

100 55 FERC A ccoun t: 502 Steam Expenses FOUR CORNERS W itn e s s : T hom as G W are DETERMINATION OF RECORDED/ADJUSTED I Recorded Period $ (0 0 0 ) FERC Form 1 Recorded (Nominal $) L ab or N o n-labor 7,721 8,731 8,374 9,337 9,939 O th e r Total 7,721 8,731 8,374 9,337 9,939 A d justm ents- (Nom inal $) - see A ppendix B fo r additional detail Labor Non-Labor (7,721) (8,731) (8,374) (9,337) (9,939) O ther Total (7,721) (8,731) (8,374) (9,337) (9,939) Recorded/Adjusted (Nominal $) Labor Non-Labor O ther Total Escalation: Labor Non-Labor O ther Recorded/Adjusted (Constant 2012$) L ab or Non-Labor O ther Total Recorded Adjusted (2012$) ,, Labor (std escl) Non-Labor (std escl) Other (not escl)

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102 57 FERC A c c o u n t W itn e s s : 502 Steam E xpenses FOUR CORNERS Thom as G W are APPENDIX A Detail Description of Final Cost Centers Included in This Activity

103 58 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 502 Steam Expenses FOUR CORNERS Thom as G W are R e c o r d e d /A d ju s te d ( C o n s ta n t $ ) B y F in a l C o s t C e n te r $ (0 0 0 ) F FOUR CORNERS 502 STEAM EXPENSE Total ** Due to rounding, totals m ay not tie to other workpaper pages.

104 59 FERC A c c o u n t W itn e s s : 502 S team Expenses FOUR CORNERS Thom as G W are APPENDIX B Detail of Total Company Adjustments to Recorded

105 60 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 502 S team Expenses FOUR CORNERS Thom as G W are D etail o f Total C o m p a n y A d ju s tm e n ts to R eco rd e d E xp e n se s A d js - (N o m in a l $) $ (0 0 0 ) Labor N on-labor (7,721) (8,731) (8,374) (9,337) (9,939) O ther Total (7,721) (8,731) (8,374) (9,337) (9,939) Organizational Unit Adjustm ent 1 GBU-C PT-O U -4C ROLL UP TO 506 This adjustm ent transfers expenses from FERC 500, 501, 502, 505, and 507 to FERC 506 Operations. Labor N on-labor (7,721) (8,731) (8,374) (9,337) (9,939) O ther Total (7,721) (8,731) (8,374) (9,337) (9,939) 0 0 0

106 61 End o f Workpapers for: FERC A c c o u n t: W itn e s s : 502 S team Expenses FOUR CORNERS T hom as G W are

107 62 Workpaper - Southern California Edison / 2015 GRC - APPLICATION Beginning o f Workpapers for: FERC A cc o u n t: W itn e s s : 505 Electric Expenses FOUR CORNERS Thom as G W are Forecast Method Chosen Recorded $ (000) Forecast 2015 Labor N/A 0 0 Non-Labor N/A 0 0 Other N /A 0 0 Total 0 0 Description o f A ctivity: This activity shall include the cost of labor, materials used and expenses incurred in operating prime movers, generators, and their auxiliary apparatus, switch gear and other electric equipment to the points where electricity leaves for conversion for transmission or distribution. This activity package has zero dollars; all costs have been transferred to other activities. Final Cost Centers included in this activity (See Appendix A for additional detail): F201210

108 63 FERC A ccoun t: 505 Electric Expenses FOUR CORNERS W itn e s s : T hom as G W are DETERMINATION OF RECORDED/ADJUSTED R ecorded Period $ (000) FERC Form 1 Recorded (Nominal $) L ab or N on-labor O ther Total A djustm ents- (Nominal $) see A ppendix B fo r additional detail L abor N on-labor (770) (735) (807) (718) (768) O ther Total (770) (735) (807) (718) (768) Recorded/Adjusted (Nominal $) L abor N on-labor O ther Total Escalation: L abor N on-labor O ther R ecorded/adjusted (Constant 2012$) L ab or N on-labor O ther Total Recorded A djusted (2012$) _g Labor (std escl) Non-Labor (std escl) Other (not escl)

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110 65 FERC A c c o u n t W itness: 505 Electric Expenses FOUR CORNERS Thom as G W are APPENDIX A Detail Description of Final Cost Centers Included in This Activity

111 66 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e ss: 505 Electric Expenses FOUR CORNERS Thom as G W are Recorded/Adjusted (Constant 2012$) By Final Cost Center $ (000) F FOUR CORNERS 505 ELECTRICAL EXPENSE Total ** Due to rounding, totals m ay not tie to other workpaper pages.

112 67 FERC A c c o u n t W itn e s s : 505 Electric E xpenses FOUR CORNERS Thom as G W are APPENDIX B Detail of Total Company Adjustments to Recorded

113 68 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e ss: 505 Electric Expenses FOUR CORNERS Thom as G W are D etail o f Total C om p any A d ju s tm e n ts to R ecorded E xpenses A d js - (N om inal $) $ (0 0 0) Labor N on-labor (770) (735) (807) (718) (768) O ther Total (770) (735) (807) (718) (768) O rganizational Unit Adjustm ent 1 GBU-C PT-O U -4C ROLL UP TO 506 This adjustm ent transfers expenses from FERC 500, 501, 502, 505, and 507 to FERC 506 Operations. Labor N on-labor (770) (735) (807) (718) (768) O ther Total (770) (735) (807) (718) (768) 0 0 0

114 69 End o f Workpapers for: FERC A c c o u n t: W itn e s s : 505 Electric Expenses FOUR CORNERS T hom as G W are

115 70 Workpaper - Southern California Edison / 2015 GRC - APPLICATION Beginning o f Workpapers for: FERC A c c o u n t: W itn e s s : 507 Rents FOUR CORNERS Thom as G W are Forecast Method Chosen $ (0 0 0 ) Recorded Forecast Labor N/A 0 0 Non-Labor N/A 0 0 O ther N /A 0 0 Total 0 0 Description o f A ctivity: This activity shall include all rents of property of others used, occupied or operated in connection with steam pow er generation. This activity package has zero dollars; all costs have been transferred to other activities. Final Cost Centers included in this activity (See Appendix A for additional detail): F201212

116 71 FERC A ccoun t: 507 Rents FOUR CORNERS W itn e s s : T hom as G W are DETERMINATION OF RECORDED/ADJUSTED R ecorded Period $ (0 0 0 ) FERC Form 1 Recorded (Nominal $) L ab or N on-labor (40) O ther Total (40) A djustm ents- (Nominal $) see A ppendix B fo r additional detail L abor N on-labor 40 (223) (223) (286) (936) O ther Total 40 (223) (223) (286) (936) Recorded/Adjusted (Nominal $) L abor N on-labor O ther Total Escalation: L abor N on-labor O ther R ecorded/adjusted (Constant 2012$) L ab or N on-labor O ther Total Recorded A djusted (2012$) _g Labor (std escl) Non-Labor (std escl) Other (not escl)

117 72 Workpaper - Southern California Edison / 2015 GRC - APPLICATION THIS PAGE INTENTIONALLY LEFT BLANK

118 73 FERC A c c o u n t W itn e s s : 507 Rents FOUR CORNERS Thom as G W are APPENDIX A Detail Description of Final Cost Centers Included in This Activity

119 74 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 507 Rents FOUR CORNERS Thom as G W are R e c o r d e d /A d ju s te d ( C o n s ta n t $ ) B y F in a l C o s t C e n te r $ (0 0 0 ) F FOUR CORNERS 507 RENTS Total ** Due to rounding, totals m ay not tie to other workpaper pages.

120 75 FERC A c c o u n t W itn e s s : 507 Rents FOUR CORNERS Thom as G W are APPENDIX B Detail of Total Company Adjustments to Recorded

121 76 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 507 Rents FOUR CORNERS Thom as G W are D etail o f Total C o m p a n y A d ju s tm e n ts to R eco rd e d E xp e n se s A d js - (N o m in a l $) $ (0 0 0 ) Labor N on-labor 40 (223) (223) (286) (936) O ther Total 40 (223) (223) (286) (936) O rganizational Unit Adjustm ent 1 G BU-CPT-O U -4C REMAP FCC A credit was recorded to FERC 506 that should have been recorded to FERC 507. This adjustm ent corrects the error. Labor N on-labor O ther Total Organizational Unit Adjustm ent 2 G BU-C PT-O U -4C ADJUSTM ENT TO OTHER To reflect the normal expected payment pa ttern, adjustm ent to move the expenses from the non-labor to the other category as these am ounts are not subject to escalation. Labor N on-labor 40 (223) O ther (40) Total Organizational Unit Adjustm ent 3 GBU-C PT-O U -4C ROLL UP TO 506 This adjustm ent transfers expenses from FERC 500, 501, 502, 505, and 507 to FERC 506 Operations. Labor N on-labor 0 0 (223) (286) (936) O ther (223) (223) Total (223) (223) (223) (286) (936) 0 0 0

122 77 End o f Workpapers for: FERC A c c o u n t: W itn e s s : 507 Rents FOUR CORNERS T hom as G W are

123 78 Workpaper - Southern California Edison / 2015 GRC - APPLICATION Beginning o f Workpapers for: FERC A cc o u n t: W itn e s s : 510 Maintenance Supervision and Engineering FOUR CORNERS Thom as G W are Forecast Method Chosen $ (0 0 0 ) Recorded Forecast Labor N/A 0 0 Non-Labor N/A 0 0 O ther N /A 0 0 Total 0 0 Description o f A ctivity: This activity shall include the cost of labor and expenses incurred in the general supervision and direction of maintenance of steam generation facilities. Direct field supervision of specific jobs shall be charged to the appropriate maintenance account. This activity package has zero dollars; all costs have been transferred to other activities. Final Cost Centers included in this activity (See Appendix A for additional detail): F201213

124 79 FERC A ccoun t: 510 M aintenance Supervision and Engineering FOUR CORNERS W itn e s s : T hom as G W are DETERMINATION OF RECORDED/ADJUSTED I Recorded Period $ (0 0 0 ) FERC Form 1 Recorded (Nominal $) Labor N on-labor ,249 1,390 1,246 O ther Total ,249 1,390 1,246 A d justm ents- (Nom inal $) - see A ppendix B fo r additional detail Labor N on-labor (649) (845) (1,249) (1,390) (1,246) O ther Total (649) (845) (1,249) (1,390) (1,246) Recorded/Adjusted (Nominal $) Labor N on-labor O ther Total Escalation: Labor N on-labor O ther R ecorded/adjusted (Constant 2012$) L ab or N on-labor O ther Total Recorded Adjusted (2012$) ,, Labor (std escl) Non-Labor (std escl) Other (not escl)

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126 81 FERC A c c o u n t W itn e s s : 510 M aintenance Supervision and Engineering FO UR CORNERS Thom as G W are APPENDIX A Detail Description of Final Cost Centers Included in This Activity

127 82 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 510 Maintenance Supervision and Engineering FOUR CORNERS Thom as G W are Recorded/Adjusted (Constant 2012$) By Final Cost Center $ (0 0 0 ) F FOUR CORNERS 510 MAINTENANCE SUPPORT AND ENGINEERING Total ** Due to rounding, totals m ay not tie to other workpaper pages.

128 83 FERC A c c o u n t: W itn e s s : 510 M aintenance Supervision and Engineering FO UR CORNERS Thom as G W are APPENDIX B Detail of Total Company Adjustments to Recorded

129 84 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 510 M aintenance Supervision and Engineering FOUR CORNERS Thom as G W are D etail o f Total C o m p a n y A d ju s tm e n ts to R eco rd e d E xp e n se s A d js - (N o m in a l $)~ $ (000) Labor N on-labor (649) (845) (1,249) (1,390) (1,246) O ther Total (649) (845) (1,249) (1,390) (1,246) Organizational Unit Adjustm ent 1 GBU-C PT-O U -4C ROLL UP TO 514 This adjustm ent transfers expenses from FERC 510, 511, 512, and 513 and to FERC 514 M aintenance. Labor N on-labor (649) (845) (1,249) (1,390) (1,246) O ther Total (649) (845) (1,249) (1,390) (1,246)

130 85 End o f Workpapers for: FERC A c c o u n t: W itn e s s : 510 Maintenance Supervision and Engineering FOUR CORNERS Thom as G W are

131 86 Workpaper - Southern California Edison / 2015 GRC - APPLICATION Beginning o f Workpapers for: FERC A c c o u n t: W itn e ss: 511 M aintenance of Structures FOUR CORNERS Thom as G W are Forecast Method Chosen $ (0 0 0 ) Recorded Forecast Labor N/A 0 0 N on-labor N/A 0 0 O ther N /A 0 0 Total 0 0 Description o f A ctivity: This activity shall include the cost of labor, m aterials used and expenses incurred in the m aintenance o f steam structures, the book cost o f which is includible in account 311, Structures and Im provem ents. This activity package has zero dollars; all costs have been transferred to other activities. Final Cost Centers included in this activity (See Appendix A for additional detail): F201214

132 87 FERC A ccoun t: 511 M aintenance of Structures FOUR CORNERS W itn e s s : T hom as G W are DETERMINATION OF RECORDED/ADJUSTED R ecorded Period $ (000) FERC Form 1 Recorded (Nominal $) L ab or N on-labor O ther Total A djustm ents- (Nominal $) see A ppendix B fo r additional detail L abor N on-labor (639) (827) (579) (702) (575) O ther Total (639) (827) (579) (702) (575) Recorded/Adjusted (Nominal $) L abor N on-labor O ther Total Escalation: L abor N on-labor O ther R ecorded/adjusted (Constant 2012$) L ab or N on-labor O ther Total Recorded A djusted (2012$) _g Labor (std escl) Non-Labor (std escl) Other (not escl)

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134 89 FERC A c c o u n t W itn e s s : 511 Maintenance of Structures FOUR CORNERS Thom as G W are APPENDIX A Detail Description of Final Cost Centers Included in This Activity

135 90 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 511 M aintenance o f Structures FOUR CORNERS Thom as G W are Recorded/Adjusted (Constant 2012$) By Final Cost Center $ (0 0 0 ) F FOUR CORNERS 511 MAINTENANCE STRUCTURE Total ** Due to rounding, totals m ay not tie to other workpaper pages.

136 91 FERC A c c o u n t W itn e s s : 511 Maintenance of Structures FOUR CORNERS Thom as G W are APPENDIX B Detail of Total Company Adjustments to Recorded

137 92 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 511 M aintenance o f S tructures FO UR CORNERS Thom as G W are D etail o f Total C o m p a n y A d ju s tm e n ts to R eco rd e d E xp e n se s A d js - (N o m in a l $) $ (0 0 0 ) Labor N on-labor (639) (827) (579) (702) (575) O ther Total (639) (827) (579) (702) (575) O rganizational Unit Adjustm ent 1 GBU-C PT-O U -4C ROLL UP TO 514 This adjustm ent transfers expenses from FERC 510, 511, 512, and 513 and to FERC 514 M aintenance. Labor N on-labor (639) (827) (579) (702) (575) O ther Total (639) (827) (579) (702) (575) 0 0 0

138 93 End o f Workpapers for: FERC A c c o u n t: W itn e s s : 511 Maintenance of Structures FOUR CORNERS T hom as G W are

139 94 Workpaper - Southern California Edison / 2015 GRC - APPLICATION Beginning o f Workpapers for: FERC A c c o u n t: W itn e s s : 512 M aintenance o f B oiler Plant FOUR CORNERS Thom as G W are Forecast Method Chosen $ (0 0 0 ) Recorded Forecast Labor N/A 0 0 Non-Labor N/A 0 0 O ther N/A 0 0 Total 0 0 Description o f A ctivity: This activity shall include the cost of labor, materials used and expenses incurred in the maintenance of steam plant. The book cost is included in Plant account 312, Boiler Plant Equipm ent. For the purpose of making charges hereto and to FERC account 513, Maintenance of Electric Plant, the point at which steam plant is distinguished from electric plant is defined as follows: 1. Inlet flange of throttle valve on prime mover; 2. Flange of all steam extraction lines on prime mover; 3. Howell pump outlet on condensate lines; 4. Inlet flange of all turbine-room auxiliaries; and, 5. Connection to line side of m otor starter fo r all boiler-plant equipment. This activity package has zero dollars; all costs have been transferred to other activities. Final Cost Centers included in this activity (See Appendix A for additional detail): F201215

140 95 FERC A ccoun t: W itn e s s : 512 M aintenance of Boiler Plant FOUR CORNERS T hom as G W are DETERMINATION OF RECORDED/ADJUSTED R ecorded Period $ (0 0 0 ) FERC Form 1 Recorded (Nominal $) Labor Non-Labor 15,658 12,058 14,511 14,387 11,588 O ther Total 15,658 12,058 14,511 14,387 11,588 A d ju stm e n ts- (N om inal $) - see A ppendix B fo r additional detail L ab or Non-Labor (15,658) (12,058) (14,511) (14,387) (11,588) O ther Total (15,658) (12,058) (14,511) (14,387) (11,588) Recorded/Adjusted (Nominal $) Labor Non-Labor O ther Total Escalation: Lab or N o n-labor O ther Recorded/Adjusted (Constant 2012$) L abor N o n-labor O ther Total 6 Recorded Adjusted (2012$) Labor (std escl) Non-Labor (std escl) Other (not escl)

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142 97 FERC A c c o u n t W itn e s s : 512 Maintenance of Boiler Plant FOUR CORNERS Thom as G W are APPENDIX A Detail Description of Final Cost Centers Included in This Activity

143 98 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 512 M aintenance o f Boiler Plant FOUR CORNERS Thom as G W are Recorded/Adjusted (Constant 2012$) By Final Cost Center $ (0 0 0 ) F FOUR CORNERS 512 MAINTENANCE BOILER Total ** Due to rounding, totals m ay not tie to other workpaper pages.

144 99 FERC A c c o u n t W itn e s s : 512 Maintenance of Boiler Plant FOUR CORNERS Thom as G W are APPENDIX B Detail of Total Company Adjustments to Recorded

145 100 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e ss: 512 M aintenance of Boiler Plant FOUR CORNERS Thom as G W are D etail o f Total C om p any A d ju s tm e n ts to R ecorded E xpenses A d js - (N om inal $) $ (0 0 0) Labor N on-labor (15,658) (12,058) (14,511) (14,387) (11,588) O ther Total (15,658) (12,058) (14,511) (14,387) (11,588) O rganizational Unit Adjustm ent 1 G B U -C P T-O U -4C ROLL UP TO 514 This adjustm ent transfers expenses from FERC 510, 511, 512, and 513 and to FERC 514 M aintenance. Labor Non-Labor (15,658) (12,058) (14,511) (14,387) (11,588) Other Total (15,658) (12,058) (14,511) (14,387) (11,588) 0 0 0

146 101 End of Workpapers for: FERC A c c o u n t: W itness: 512 Maintenance of Boiler Plant FOUR CORNERS Thom as G W are

147 102 Workpaper - Southern California Edison / 2015 GRC - APPLICATION Beginning o f Workpapers for: FERC A c c o u n t: W itn e ss: 513 M aintenance o f Electric Plant FOUR CORNERS Thom as G W are Forecast Method Chosen $ (0 0 0 ) Recorded Forecast Labor N/A 0 0 Non-Labor N/A 0 0 O ther N /A 0 0 Total 0 0 Description o f A ctivity: This activity shall include the cost of labor, materials used and expenses incurred in the maintenance of electric plant. The book cost is included in account 313, Engines and Engine-Driven Generators, account 314, Turbo G enerator Units, and account 315, Accessory Electric Equipment. This activity package has zero dollars; all costs have been transferred to other activities. Final Cost Centers included in this activity (See Appendix A for additional detail): F201216

148 103 FERC A ccoun t: 513 M aintenance of Electric Plant FOUR CORNERS W itn e s s : T hom as G W are I DETERMINATION OF RECORDED/ADJUSTED Recorded Period $ (000) FERC Form 1 Recorded (Nominal $) L ab or N o n-labor 4,346 1,707 6,866 2,957 2,318 O th e r Total 4,346 1,707 6,866 2,957 2,318 A d justm ents- (Nom inal $) - see A ppendix B fo r additional detail Labor Non-Labor (4,346) (1,707) (6,866) (2,957) (2,318) O ther Total (4,346) (1,707) (6,866) (2,957) (2,318) Recorded/Adjusted (Nominal $) Labor Non-Labor O ther Total Escalation: Labor Non-Labor O ther Recorded/Adjusted (Constant 2012$) L ab or Non-Labor O ther Total Recorded Adjusted (2012$) ,, Labor (std escl) Non-Labor (std escl) Other (not escl)

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150 105 FERC A c c o u n t: W itness: 513 Maintenance of Electric Plant FOUR CORNERS Thom as G W are APPENDIX A Detail Description of Final Cost Centers Included in This Activity

151 106 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e ss: 513 M aintenance of Electric Plant FOUR CORNERS Thom as G W are Recorded/Adjusted (Constant 2012$) By Final Cost Center $ (0 0 0) F FOUR CORNERS 513 MAINTENANCE ELECTRICAL Total ** Due to rounding, totals m ay not tie to other workpaper pages.

152 107 FERC A c c o u n t: W itn e s s : 513 Maintenance of Electric Plant FOUR CORNERS Thom as G W are APPENDIX B Detail of Total Company Adjustments to Recorded

153 108 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 513 M aintenance of Electric Plant FOUR CORNERS Thom as G W are D etail o f Total C o m p a n y A d ju s tm e n ts to R eco rd e d E xp e n se s A d js - (N o m in a l $) $ (0 0 0 ) Labor N on-labor (4,346) (1,707) (6,866) (2,957) (2,318) O ther Total (4,346) (1,707) (6,866) (2,957) (2,318) Organizational Unit Adjustm ent 1 GBU-C PT-O U -4C ROLL UP TO 514 This adjustm ent transfers expenses from FERC 510, 511, 512, and 513 and to FERC 514 M aintenance. Labor N on-labor (4,346) (1,707) (6,866) (2,957) (2,318) O ther Total (4,346) (1,707) (6,866) (2,957) (2,318) 0 0 0

154 109 End o f Workpapers for: FERC A c c o u n t: W itn e s s : 513 Maintenance of Electric Plant FOUR CORNERS Thom as G W are

155 110 Workpaper - Southern California Edison / 2015 GRC - APPLICATION Beginning o f Workpapers for: FERC A cc o u n t: W itn e ss: 506 Miscellaneous Steam Power Expenses MOHAVE - PART BILLIN G TRANS Thom as G W are Forecast Method Chosen Recorded $ (000) Forecast 2015 Labor N/A 0 0 Non-Labor Calculated (73) (142) Other N/A 0 0 Total (73) (142) Description o f A ctivity: Participant credit billing activities related to activity Final Cost Centers included in this activity (See Appendix A for additional detail): F201198

156 111 FERC A ccoun t: W itn e ss: 506 M iscellaneous Steam Pow er Expenses MOHAVE - PART BILLING TRANS T hom as G W are DETERMINATION OF RECORDED/ADJUSTED I Recorded Period $ (000) FERC Form 1 Recorded (Nominal $) L a b o r N o n -L a b o r (7,164) (1,296) (1,138) (792) (73) O th e r Total (7,164) (1,296) (1,138) (792) (73) Adjustments- (Nominal $) - see Appendix B for additional detail Labor N on-labor O ther Total Recorded/Adjusted (Nominal $) Escalation: Labor N on-labor (7,164) (1,296) (1,138) (792) (73) O ther Total (7,164) (1,296) (1,138) (792) (73) Labor N on-labor O ther Recorded/Adjusted (Constant 2012$) L a b o r N o n -L a b o r (8,014) (1,448) (1,236) (812) (73) O th e r Total (8,014) (1,448) (1,236) (812) (73) o -1,000-2,000-3,000 4,000-5,000-6,000-7,000-8,000-9,000 Recorded Adjusted (2012$) Labor (std escl) Non-Labor (std escl) Other (not escl)

157 112 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e ss: 506 M iscellaneous S team P ow er Expenses MOHAVE - PART BILLING TRANS Thom as G W are F o re ca stin g M ethods - S um m ary o f R esults o f all M ethods S tudie d $ (000) 2 R ecorded Years ( ): Results of Averaging (A2) sd** Chosen Labor no Non-Labor (443) (443) (443) 370 no Other no Total (443) (443) (443) n/a n/a 3 R ecorded Years ( ): Results of Linear Trending (T3) Results of Averaging (A3) r2* Chosen sd** Chosen Labor no no Non-Labor 456 1,037 1, no (707) (707) (707) 481 no Other no no Total 456 1,037 1,619 n/a n/a (707) (707) (707) n/a n/a 4 R ecorded Years ( ): Results of Linear Trending (T4) Results of Averaging (A4) r2* Chosen sd** Chosen Labor no no Non-Labor , no (892) (892) (892) 525 no Other no no Total ,155 n/a n/a (892) (892) (892) n/a n/a 5 R ecorded Years ( ): Results of Linear Trending (T5) Results of Averaging (A5) r2* Chosen sd** Chosen Labor no no Non-Labor 2,639 4,290 5, no (2,317) (2,317) (2,317) 2,887 no Other no no Total 2,639 4,290 5,942 n/a n/a (2,317) (2,317) (2,317) n/a n/a O th er M e thod s: Labor Non-Labor Other Total Last Recorded Year (LRY) Itemized Forecast (IF) Chosen Chosen no (73) (73) (73) no no no no no (73) (73) (73) n/a n/a F o reca st A d ju s tm e n ts : Labor Non-Labor Other Total Base Forecast Method Adjustments* Method N/A CALC (142) (142) (142) N/A (142) (142) (142) * r2 = R Squared (Based on recorded years data) ** sd = standard deviation (Based on recorded years data) *** See Appendix B For Additional Detail

158 113 FERC A c c o u n t: W itn e s s : 506 Miscellaneous Steam Power Expenses MOHAVE - PART BILLING TRANS T h om a s G W are R e su lts: Forecasting R esults Method Selected Labor N/A Non-Labor Calculated (142) (142) (142) Other N/A Total (142) (142) (142) A n a ly s is o f F o re c a s tin g M e thods Analysis of Linear Trending Method: The participant share credit represents the Mohave participants ownership share of the 100% O&M expenses. It is a "calculated" amount which is derived by applying the participants ownership share of 44% to the 100% level O&M expenses. Using trends to derive this forecast is not appropriate. A n alysis of Averaging Method: The participant share credit represents the Mohave participants ownership share of the 100% O&M expenses. It is a "calculated" amount which is derived by applying the participants ownership share of 44% to the 100% level O&M expenses. Using 2, 3, 4, or 5 year averages to derive this forecast is not appropriate. Analysis of Last Recorded Year (2012): The participant share credit represents the Mohave participants ownership share of the 100% O&M expenses. It is a "calculated" amount which is derived by applying the participants ownership share of 44% to the 100% level O&M expenses. Using last recorded year to derive this forecast is not appropriate. Analysis of Itemized Forecast Method: The participant share credit represents the Mohave participants ownership share of the 100% O&M expenses. It is a "calculated" amount which is derived by applying the participants ownership share of 44% to the 100% level O&M expenses.

159 114 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 506 Miscellaneous Steam Power Expenses MOHAVE - PART BILLING TRANS T h om a s G W are Recorded / Forecast $ (000) Labor (std escl) Non-Labor (std escl) Cither (not escl) R eco rd e d P eriod $ (000) Forecast Expenses (constant 2012$) Labor (standard escalation) Non-Labor (standard escalation) (8,014) (1,448) (1,236) (812) (73) (142) (142) (142) Other (not escalatable) Total (8,014) (1,448) (1,236) (812) (73) (142) (142) (142) Labor Prior year Total Change Total Non-Labor Prior year Total (73) (142) (142) Change (69) 0 0 Total (73) (142) (142) (142) Other Prior year Total Change Total Total Change Labor Non-Labor (69) 0 0 Other Total N/A (69) 0 0

160 115 FERC A c c o u n t: W itness: 506 Miscellaneous Steam Power Expenses MOHAVE - PART BILLING TRANS Thom as G W are APPENDIX A Detail Description of Final Cost Centers Included in This Activity

161 116 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: Activity: W itn e ss: 506 Miscellaneous Steam Power Expenses m o h a v e - p a r t b i l l i n g t r a n s Thom as G W are Description o f Final Cost Centers included in this activity: F MOHAVE 506 M ISCELLANEOUS STEAM EXPENSE PRODUCTION CONTROL ROOM Includes expense offset related to O perations Miscellaneous Steam Power.

162 117 FERC A c c o u n t: W itn e s s : 506 M iscellaneous Steam Power Expenses MOHAVE - PART BILLING TRANS Thom as G W are Recorded/Adjusted (Constant 2012$) By Final Cost Center $ (000) F MOHAVE 506 MISCELLANEOUS STEAM EXPENSE PRODUCTION CONTROL ROOM (8,014) (1,448) (1,236) (812) (73) Total (8,014) (1,448) (1,236) (812) (73) " D u e to rounding, totals may not tie to other workpaper pages.

163 118 Workpaper - Southern California Edison / 2015 GRC - APPLICATION THIS PAGE INTENTIONALLY LEFT BLANK

164 119 FERC A c c o u n t: W itn e s s : 506 Miscellaneous Steam Power Expenses MOHAVE - PART BILLING TRANS Thom as G W are APPENDIX B Detail of Total Company Adjustments to Recorded

165 120 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e ss: 506 M iscellaneous Steam P ow er Expenses MOHAVE - PART BILLING TRANS Thom as G W are D etail o f Total C om p any A d ju s tm e n ts to R ecorded E xpenses A d js - (N om inal $) $ (000) Labor N on-labor O ther Total

166 121 End of Workpapers for: FERC A c c o u n t: W itn e ss: 506 Miscellaneous Steam Power Expenses MOHAVE - PART BILLING TRANS Thom as G W are

167 122 Workpaper - Southern California Edison / 2015 GRC - APPLICATION Beginning o f Workpapers for: FERC A c c o u n t: W itn e ss: 506 Miscellaneous Steam Power Expenses MOHAVE Thom as G W are Forecast Method Chosen 2012$ (000) Recorded Forecast Labor Last Recorded Year Adj Non-Labor Last Recorded Year Adj Other N/A 0 0 Total Description o f A ctivity: This activity shall include the cost of labor, materials used and expenses incurred which are not specifically provided for or are not readily assignable to other steam generation operation expense accounts. Final Cost Centers included in this activity (See Appendix A for additional detail): F F F F F F F F F F F F F F F F F F F F F F F F F F F F F F526389

168 123 FERC A cco u n t: 506 Miscellaneous Steam Power Expenses MOHAVE W itness: Thom as G Ware DETERMINATION OF RECORDED/ADJUSTED I R ecorded Period $ (000) FERC Form 1 Recorded (N om inal $) Lab or N o n-labor 15,721 2,477 2,118 1, O ther Total 16,286 2,940 2,633 1, A d justm ents- (N om inal $) - see A ppendix B fo r additional detail Labor 1, N on-labor (118) (408) 759 (253) (45) O ther Total 1, , R ecorded/adjusted (Nominal $) Labor 1,611 1,237 1,120 1, N on-labor 15,603 2,069 2, O ther Total 18,036 3,306 3,997 1, Escalation: Labor N on-labor O ther Recorded/Adjusted (Constant 2012$) Labor 1,839 1,369 1,198 1, N on-labor 17,454 2,312 3, O ther Total 20,115 3,681 4,323 2, Recorded Adjusted (2012$) ,000 12,000 8,000 4, Labor (std escl) Non-Labor (std escl) Cither (not escl)

169 124 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 506 Miscellaneous Steam Power Expenses MOHAVE Thom as G W are F o re c a s tin g M e th o d s - S u m m a ry o f R e su lts o f a ll M e th o d s S tu d ie d $ (000) 2 R ecorded Years ( ): R esults of Averaging (A2) sd** Chosen Labor no Non-Labor no Other no Total 1,130 1,130 1,130 n/a n/a 3 R ecorded Years ( ): Results of Linear Trending (T3) Results of A veraging (A3) r2* I Chosen sd** Chosen Labor (199) (711) (1,222) 0.82 no no Non-Labor (1,723) (3,269) (4,815) 0.95 no 1,370 1,370 1,370 1,297 no Other no no Total (1,922) (3,980) (6,037) n/a n/a 2,194 2,194 2,194 n/a n/a 4 R ecorded Years ( ): Results of Linear Trending (T4) Results of A veraging (A4) r2* Chosen sd** Chosen Labor 40 (328) (696) 0.79 no no Non-Labor (647) (1,548) (2,449) 0.71 no 1,605 1,605 1,605 1,195 no Other no no Total (607) (1,876) (3,145) n/a n/a 2,566 2,566 2,566 n/a n/a 5 R ecorded Years ( ): Results of Linear Trending (T5) Results of Averaging (A5) r2* Chosen sd** Chosen Labor 57 (303) (662) 0.88 no 1,136 1,136 1, no Non-Labor (6,085) (9,706) (13,326) 0.63 no 4,775 4,775 4,775 6,429 no Other (329) (493) (658) 0.50 no no Total (6,357) (10,502) (14,646) n/a n/a 6,075 6,075 6,075 n/a n/a O th e r M e th o d s: Labor Non-Labor Other Total Last Recorded Year (LRY) Itemized Forecast (IF) Chosen Chosen yes no yes no no no n/a n/a F o re c a s t A d ju s tm e n ts : Labor Non-Labor Other Total Base Forecast Method Adjustments* Method LRY LRY N/A * r2 = R Squared (Based on recorded years data) ** sd = standard deviation (Based on recorded years data) *** See Appendix BFor Additional Detail

170 125 FERC A c c o u n t: W itn e ss: 506 Miscellaneous Steam Power Expenses MOHAVE Thom as G W are R esults: Forecasting R esults Method Selected Labor Last Recorded Year Adj Non-Labor Last Recorded Year Adj Other N/A Total A n a ly s is o f F o re ca stin g M ethods Analysis of Linear Trending Method: In D and D , the CPUC stated that if costs have shown a trend in a certain direction over three or more years, the last recorded year is an appropriate base estimate. The years indicate a decreasing trend for labor and non-labor, therefore the last recorded year provides the best base for estimating labor and non-labor for Test Year A n a ly sis of A veraging Method: In D and D , the CPUC stated that for those accounts which have significant fluctuations in recorded expenses from year to year, an average of recorded expenses is appropriate. The labor and non-labor recorded costs in this account have a reducing trend from , so an average is not an appropriate forecast. Analysis of Last Recorded Year (2012): The last recorded year provides our base for estimating Test Year 2015 as supported by the linear trending analysis above. Analysis of Itemized Forecast Method: Not applicable.

171 126 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 506 M iscellaneous S team P ow er Expenses MOHAVE Thom as G W are Recorded / Forecast $ (000) ,000 12,000 8,000 4,000 0 I I I I Labor (std escl) Non-Labor (std escl) Other (not escl) R eco rd e d P eriod $ (000) Forecast Expenses (constant 2012$) Labor (standard escalation) 1,839 1,369 1,198 1, Non-Labor (standard escalation) 17,454 2,312 3, Other (not escalatable) Total 20,115 3,681 4,323 2, Labor Prior year Total Change Total Non-Labor Prior year Total Change Total Other Prior year Total Change Total Total Change Labor Non-Labor Other Total N/A

172 127 FERC A c c o u n t: W itn e s s : 506 Miscellaneous Steam Power Expenses MOHAVE T h om a s G W are This page shows the changes in Labor, Non-Labor, and Other expenditures forecast during 2013 through 2015, including reasons for the addition of personnel (labor), increased office supplies required due to an increase in activity (non-labor) Labor: 26 This labor increase is due to the increase in caretaking maintenance expenses over 2012 recorded. See Appendix B. Non-Labor: 89 This non-labor increase is due to the increase in caretaking maintenance expenses over 2012 recorded. See Appendix B. Other: 0 Not applicable.

173 128 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A cco u n t: W itn e s s : 506 Miscellaneous Steam Power Expenses MOHAVE T hom as G W are This page shows the changes in Labor, Non-Labor, and Other expenditures forecast during 2013 through 2015, including reasons for the addition of personnel (labor), increased office supplies required due to an increase in activity (non-labor) Labor: 0 Not applicable. Non-Labor: 0 Not applicable. Other: 0 Not applicable.

174 129 FERC A c c o u n t: W itn e s s : 506 M iscellaneous S team P ow er Expenses MOHAVE Thom as G W are This page shows the changes in Labor, Non-Labor, and Other expenditures forecast during 2013 through 2015, including reasons for the addition of personnel (labor), increased office supplies required due to an increase in activity (non-labor) Labor: 0 Not applicable. Non-Labor: 0 Not applicable. Other: 0 Not applicable.

175 130 Workpaper - Southern California Edison / 2015 GRC - APPLICATION THIS PAGE INTENTIONALLY LEFT BLANK

176 131 FERC A c c o u n t W itn e s s : 506 Miscellaneous Steam Power Expenses MOHAVE T hom as G W are APPENDIX A Detail Description of Final Cost Centers Included in This Activity

177 132 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: A ctivity: W itn e s s : 506 Miscellaneous Steam Power Expenses MOHAVE T hom as G W are Description o f Final Cost Centers included in this activity: F MOHAVE ADMINISTRATION 500 Includes expense offset related to Operation Supervision & Engineering. F MOHAVE 501 FUEL ADMINISTRATION EXPENSE Includes labor, m aterial, contract, oth er costs fo r general supervision and adm inistration for fuel-related activities. C ategory relates to day-to-day activities of the M anager o f Steam G eneration, Division S taff M anagers, Division S taff Engineering, S tation/s ervice O rganization M anagers, and the section supervisors w ho report directly to them. In addition, includes costs o f annual budget developm ent, payroll and labor reporting, budget m onitoring/control/forecasting, personnel/benefits adm inistration, and adm inistrative support services such as stationery, telephone bills, copier m achine rentals, etc. F MOHAVE 502 STEAM EXPENSES ADMINISTRATION Includes labor, m aterial, contract, and other costs in relation to w ate r/chem istry m anagem ent and control and analysis fo r steam generating and oth er production units. A ctivities include w ater chem istry standards developm ent, routine testing and analysis, shutdow n chem ical m aintenance, startup/outage protection analysis, w ate r treatm ent activities reporting, chem istry instrum ents perform ance testing, check sam pling/analysis, and w ate r chem istry quality assurance. Includes the cost o f acquiring the actual w a te r and chem icals as well as the associated cost o f requirem ents planning, handling, and control. F MOHAVE 506 M ISCELLANEOUS STEAM EXPENSE ADMINISTRATION Includes labor, m aterial, contract, oth er costs fo r general supervision and adm inistration for fuel-related activities. C ategory relates to day-to-day activities of the M anager o f Steam G eneration, Division S taff M anagers, Division S taff Engineering, S tation/s ervice O rganization M anagers, and the section supervisors w ho report directly to them. In addition, includes costs o f annual budget developm ent, payroll and labor reporting, budget m onitoring/control/forecasting, personnel/benefits adm inistration, and adm inistrative support services such as stationery, telephone bills, copier m achine rentals, etc. F MOHAVE 506 M ISCELLANEOUS STEAM EXPENSE W AREHOUSE Includes labor, m aterial, contract, and other costs for m aterial-requirem ents planning and m anagem ent. M aterial-requirem ents planning involves establishing inventory levels based on operations and m aintenance requirem ents. M aterial m anagem ent involves storing, receiving, shipping, transporting, inventory expense, supervision, accounting, and docum ent preparation for m aterials and spare parts. Also includes costs to rent, operate, and m aintain warehouse vehicles. F MOHAVE 502 STEAM EXPENSES ENVIRONMENTAL Includes labor, m aterial, contract, and other costs for air-quality m onitoring and reporting. A ctivities include m aintaining records of visits by air quality-control representatives, continuous em issions data, air-quality files, w eather files, eve nt inform ation, opacity docum entation/data, and training. Also includes permits. F MOHAVE 506 M ISCELLANEOUS STEAM EXPENSE ENVIRONMENTAL Includes labor, m aterial, contract, and other costs for industrial insurance, certifications, regulatory and general rate-case support. A ctivities also include ongoing litigation support; e.g., data provision and report preparation. Also includes labor, m aterial, contract, and oth er costs fo r effluent w a te r quality control and reporting. A ctivities include m aintaining records o f effluent test d a ta, turbidity test data, and event inform ation and im plem entation o f regulatory requirem ents regarding w aste disposal, discharge monitoring, periodic reporting, and training. Also includes permits/fees.

178 133 FERC A c c o u n t: A ctivity: W itn e s s : 506 Miscellaneous Steam Power Expenses MOHAVE T hom as G W are Description o f Final Cost Centers included in this activity: F MOHAVE 506 M ISCELLANEOUS STEAM EXPENSE HEALTH & SECURITY Includes labor, m aterial, contract, and other costs for safety program de velopm ent and adm inistration, safety m eetings, on-the-job training, industrial hygiene program adm inistration, chem ical safety, and accident investigation and reporting. A lso includes labor, m aterial, contract, and oth er costs for facility security. This includes activities for security requirem ents analysis, incident investigation, and security reporting. F MOHAVE 506 MISCELLANEOUS STEAM EXPENSE CONTRACT Includes labor, m aterial, contract, and other costs for facility security and janitorial services. S ecurity activities include security requirem ents analysis, S C E /contract security guards, incident investigation, and security reporting. Janitorial and facility m anagem ent activities include the general upkeep of buildings and grounds performed by SCE personnel or contractors. F MOHAVE 502 STEAM EXPENSE W ATER & CHEMISTRY MANAGEM ENT Includes labor, m aterial, contract, and other costs in relation to w ate r/chem istry m anagem ent and control and analysis fo r steam generating and oth er production units. A ctivities include w ater chem istry standards developm ent, routine testing and analysis, shutdow n chem ical m aintenance, startup/outage protection analysis, w ate r treatm ent activities reporting, chem istry instrum ents perform ance testing, check sam pling/analysis, and w ate r chem istry quality assurance. Includes the cost o f acquiring the actual w a te r and chem icals as well as the associated cost o f requirem ents planning, handling, and control. F MOHAVE 505 ELECTRICAL EXPENSE W ATER & C HEM ICAL M ANAGEM ENT Includes m aterial, contract, and oth er costs in relation to w ater/chem istry m anagem ent fo r control and analysis o f steam generating and oth er production units relating to electric expense (circulating w ate r system s including cooling w a te r purchases, operating condensers, generator cooling system s, etc.). A ctivities include w a te r chem istry standards developm ent, routine testing and analysis; shutdow n chem ical m aintenance: startup/outage protection analysis; w ate r treatm ent activities reporting; chem istry instrum ents perform ance testing; check sam pling/analysis and w a te r chem istry quality assurance. Includes the cost o f acquiring the actual w a te r and chem icals as w ell as the associated cost of requirem ents planning, handling, and control. No labor will be charged to this account. F MOHAVE 506 MISCELLANEOUS STEAM EXPENSE CONSUM ABLES Includes m aterial cost o f all m iscellaneous m aterials that otherw ise cannot be identified, planned, and recorded to specific activities. M aterials falling in this category include lubricants, cooling and insulating gases, gaskets/ packing, gauge glasses, indicating lam ps, paint, bar steel, brass rods, cast iron, copper tubing, elbows, nipples, tees, unions, cylinder dem urrage, etc. F MOHAVE 500 OPERATION SUPERVISION AND ENGINEERING Includes labor, m aterial, contract, and other costs o f shift supervisors and operating forem an incurred in connection w ith supervision o f station operation not specifically applicable to oth er operation functional activities. F MOHAVE 501 FUEL Includes labor, material, contract, and other costs for repair and m aintenance of fuel handling systems.

179 134 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: A ctivity: W itn e s s : 506 Miscellaneous Steam Power Expenses MOHAVE T hom as G W are Description o f Final Cost Centers included in this activity: F MOHAVE 502 STEAM EXPENSE BOILER SYSTEMS Includes labor, m aterial, contract, and other costs involved in system operation coordination, equipm ent operation/m onitoring, and operating procedures developm ent in relation to the boiler system s. The related plant equipm e nt includes boiler and auxiliaries, feed-w ater system, steam system s, air-side/draft equipm ent, fire-side/fuel burning equipm ent, ash-handling equipm ent, and associated m otor drives, starters/breakers, and perform ance and control system s. A lso includes labor, m aterial, contract, and oth er expenses in relation to fuel-requirem ents planning, delivery coordination, fuel oil, gas, and coal quality verification (routine sam pling), and fuel-usage m easurem ent and reporting. Includes handling and preparing fuel beginning at the point w here the fuel enters the first plant bunker, hopper, bucket, tank, or holder. Includes operating costs associated w ith coal-handling and storage equipm ent, pulverized fuel equipm ent, oil-handling and storage equipm ent, and associated motor drives, starters/breakers, and control systems. F MOHAVE 506 M ISCELLANEOUS STEAM EXPENSE PERFORMANCE MONITORING Includes labor, m aterial, contract, and other costs for engineering activities associated w ith perform ance m onitoring/reporting and operation m onitoring/reporting. P erform ance m onitoring/reporting involves activities related to developing/revising unit/equip m ent efficiency standards, ongoing unit/equipm ent efficiency m onitoring/reporting, perform ance testing, station perform ance audits, com bustion control testing, isolation/analysis of efficiency problem s, and m aintenance project identification. O peration m onitoring/reporting involves activities related to periodic fuel usage m onitoring/m easurem ent, load requirem ent analysis, generation m easurem ent, North A m erican Electric R eliability C ouncil - G enerating A vailability Data System (N ER C -G AD S), and associated internal/external reporting. F MOHAVE 506 MISCELLANEOUS STEAM EXPENSE SUPPORT GROUPS Includes all costs fo r plant utilities such as phone bills, electrical utilities, m iscellaneous office supplies and expenses, printing and stationery at M ohave G enerating Station. Also includes labor, m aterial, contract, and oth er costs in relation to the form al training o f station personnel. A ctivities include training requirem ents analysis, corporate /training, professional/contract training, and training adm inistration. A lso includes labor, m aterial, contract, and other costs fo r m iscellaneous m eetings not specifically provided for in o th e r functions at M ohave G enerating S tation. These m eetings include crew m eetings, offsite m eetings, and team m eetings. Also includes appraising, coaching, and interviewing em ployees for job promotions. F MOHAVE CREDITS 500 OPERATION SUPERVISION & ENGINEERING Includes expense offset related to Operation Supervision & Engineering. F MOHAVE 501 FUEL PRODUCTION CONTROL ROOM Includes expense offset related to fuel expense. F MOHAVE 502 STEAM EXPENSE PRODUCTION CONTROL ROOM Includes expense offset related to O perations Steam Expense. F MOHAVE 505 ELECTRICAL EXPENSE PRODUCTION CREDIT Includes expense offset related to O perations Electrical Expenses.

180 135 FERC A c c o u n t: A ctivity: W itn e ss: 506 Miscellaneous Steam Power Expenses MOHAVE Thom as G W are Description o f Final Cost Centers included in this activity: F FINANCIAL SERVICES MOHAVE 500 OPERATION SUPPORT AND ENGINEERING Includes labor, m aterial, contract, and other costs incurred in connection w ith operation, supervision, and adm inistration not specifically applicable to other operation function activities. Tasks include annual budget developm ent, budget m onitoring/control/forecasting, payroll and labor reporting, personnel/benefits adm inistration and staff adm inistrative support services. F OPERATIONS SUPPORT & PERFORMANCE IM PROVEM ENT - MOHAVE 500 OPERATION SUPERVISION & ENGINEERING Includes labor, m aterial, contract, and other costs incurred in connection w ith operation, supervision and engineering not specifically applicable to other operation function activities. O ther tasks include, annual budget developm ent, coordinate departm ent goal setting and perform ance tracking, prepare departm ent business plan and long-range m aintenance plan, coordinate departm ental w orkforce attrition planning, manage departm ent participation in regulatory proceedings, coordinate departm ental regulatory and safety com pliance activities, evaluate im pacts o f potential changes to SCE power generating, m aintain departm ent policies, and coordinate departm ental participation in com pany - workers union activities (e.g., contract negotiations). F MOHAVE 501 FUEL C O A L LA B O R Includes labor and other expenses incurred by the Power Procurem ent Business Unit (PPBU ) or the Coal Contracts Adm inistration group. F MISCELLANEOUS GENERAL EXPENSES Includes the cost o f m iscellaneous expenses connected w ith the general m anagem ent o f the C ompany. F MOHAVE 501 C O AL EXPENSE - CORPORATE REGULATORY ACCOUNTING Includes cost of gas used for the generation o f steam. F MOHAVE 502 STEAM EXPENSES CHEM ICALS Includes labor, m aterial, contract, and other costs in relation to w ater/chem istry m anagem ent and control and analysis for steam generating and other production units. A ctivities include w ater chem istry standards developm ent, routine testing and analysis, shutdow n chem ical maintenance, startup/outage protection analysis, w ater treatm ent activities reporting, chem istry instrum ents perform ance testing, check sam pling/analysis, and w ater chem istry quality assurance. Includes the cost o f acquiring the actual w ate r and chem icals as well as the associated cost o f requirem ents planning, handling, and control. F W ESTMINSTER 553 MAINTENANCE GENERATION & ELECTRICAL PLAN T This account includes the cost o f labor, m aterials used and expenses incurred in m aintenance o f Gas Turbine Peaker plant and the book cost o f w hich is includible in Prime M overs, Generators, and A ccessory Electric Equipm ent. This includes costs such as corrective m aintenance on auxiliary electrical system s, fuel-conveying/processing system s, C ontinuous Em issions Monitoring System s (CEMS) calibration, w ater treatm ent system s and air quality maintenance. F MOHAVE 501 FUEL CONTROL ROOM ACCO UNT Includes am ounts billed by outside consulting firm s for w ork perform ed in support o f Power Procurem ent Business Unit (PPBU). W hen used in FERC account , this final cost center reflects a credit for the Mohave participant share of Coal Contract Adm inistration expense.

181 136 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: A ctivity: W itn e ss: 506 Miscellaneous Steam Power Expenses MOHAVE Thom as G W are Description o f Final Cost Centers included in this activity: F MOHAVE 506 MISCELLANEOUS STEAM POW ER EXPENSES - LABO R CORRECTION C osts associated with the M ohave A lternative/c om plim ent Study ordered by the CPUC. These costs are not billable to the participants (it is an SCE responsibility item only) and w ill be transferred out to Base Revenue Requirem ent Balancing Account (BRRBA) on a monthly basis. F MOHAVE 506 MISCELLANEOUS STEAM POW ER EXPENSES C osts associated with the M ohave A lternative/c om plim ent Study ordered by the CPUC. These costs are not billable to the participants (it is an SCE responsibility item only) and w ill be transferred out to Base Revenue Requirem ent Balancing Account (BRRBA) on a monthly basis. F BUSINESS PLANNING 8. DEVELOPMENT - MOHAVE 500 OPERATION SUPERVISION & ENGINEERING Includes labor, m aterial, contract, and other costs incurred in connection w ith operation, supervision and engineering not specifically applicable to other operation function activities. O ther tasks include, annual budget developm ent, coordinate departm ent goal setting and perform ance tracking, prepare departm ent business plan and long-range m aintenance plan, coordinate departm ental w orkforce attrition planning, manage departm ent participation in regulatory proceedings, coordinate departm ental regulatory and safety com pliance activities, evaluate impacts of potential changes to Southern California Edison (SCE) power generating, m aintain departm ent policies, and coordinate departmental participation in com pany - w orkers union activities (e.g., contract negotiations). F W ATER TREATMENT Includes material, contract, and other costs in relation to w ater/chem istry m anagem ent for control and analysis o f steam generating and other production units relating to electric expense (circulating w ater system s including cooling w ate r purchases, operating condensers, generator cooling system s, etc.). Activities include w ater chem istry standards developm ent, routine testing and analysis; shutdown chem ical m aintenance: startup/outage protection analysis; w ater treatm ent activities reporting; chem istry instrum ents perform ance testing; check sam pling/analysis and w ate r chem istry quality assurance. Includes the cost o f acquiring the actual w ater and chem icals as w ell as the associated cost of requirem ents planning, handling, and control. No labor will be charged to this account.

182 137 FERC A c c o u n t: W itn e s s : 506 Miscellaneous Steam Power Expenses MOHAVE T hom as G W are Recorded/Adjusted (Constant 2012$) By Final Cost Center $ (000) F MOHAVE ADMINISTRATION F F F F F F F F F F F F MOHAVE 501 FUEL ADMINISTRATION EXPENSE MOHAVE 502 STEAM EXPENSES ADMINISTRATION MOHAVE 506 MISCELLANEOUS STEAM EXPENSE ADMINISTRATION MOHAVE 506 MISCELLANEOUS STEAM EXPENSE WAREHOUSE MOHAVE 502 STEAM EXPENSES ENVIRONMENTAL MOHAVE 506 MISCELLANEOUS STEAM EXPENSE ENVIRONMENTAL MOHAVE 506 MISCELLANEOUS STEAM EXPENSE HEALTH & SECURITY MOHAVE 506 MISCELLANEOUS STEAM EXPENSE CONTRACT MOHAVE 502 STEAM EXPENSE WATER & CHEMISTRY MANAGEMENT MOHAVE 505 ELECTRICAL EXPENSE WATER & CHEMICAL MANAGEMENT MOHAVE 506 MISCELLANEOUS STEAM EXPENSE CONSUMABLES MOHAVE 500 OPERATION SUPERVISION AND ENGINEERING , , (139) 1 1,187 1,332 1, F MOHAVE 501 FUEL 18 (3) F F F F F F F MOHAVE 502 STEAM EXPENSE BOILER SYSTEMS MOHAVE 506 MISCELLANEOUS STEAM EXPENSE PERFORMANCE MONITORING MOHAVE 506 MISCELLANEOUS STEAM EXPENSE SUPPORT GROUPS MOHAVE CREDITS 500 OPERATION SUPERVISION & ENGINEERING MOHAVE 501 FUEL PRODUCTION CONTROL ROOM MOHAVE 502 STEAM EXPENSE PRODUCTION CONTROL ROOM MOHAVE 505 ELECTRICAL EXPENSE PRODUCTION CREDIT (540) (924) (562) (254) (81) (12) 2 1, (368) (219) (66) 9 (1) (69) (127) F FINANCIAL SERVICES MOHAVE 500 OPERATION SUPPORT AND ENGINEERING

183 138 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 506 Miscellaneous Steam Power Expenses MOHAVE T hom as G W are Recorded/Adjusted (Constant 2012$) By Final Cost Center $ (000) F OPERATIONS SUPPORT & PERFORMANCE IMPROVEMENT- MOHAVE 500 OPERATION SUPERVISION & ENGINEERING F MOHAVE 501 FUEL COAL LABOR F MISCELLANEOUS GENERAL EXPENSES F MOHAVE 501 COAL EXPENSE - CORPORATE REGULATORY ACCOUNTING F F F F F MOHAVE 502 STEAM EXPENSES CHEMICALS WESTMINSTER 553 MAINTENANCE GENERATION & ELECTRICAL PLANT MOHAVE 501 FUEL CONTROL ROOM ACCOUNT MOHAVE 506 MISCELLANEOUS STEAM POWER EXPENSES - LABOR CORRECTION MOHAVE 506 MISCELLANEOUS STEAM POWER EXPENSES (2) (47) (39) (74) (297) F BUSINESS PLANNING & DEVELOPMENT - MOHAVE 500 OPERATION SUPERVISION & ENGINEERING F WATER TREATMENT (5) 0 Total 20,117 3,684 4,323 2, ** Due to rounding, totals may not tie to other workpaper pages.

184 139 FERC A c c o u n t: W itn e s s : 506 Miscellaneous Steam Power Expenses MOHAVE Thom as G W are APPENDIX B Detail of Total Company Adjustments to Recorded

185 140 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 506 M iscellaneous Steam Power Expenses MOHAVE Thom as G W are D etail o f Total C o m p a n y A d ju s tm e n ts to R eco rd e d E xpenses A d js - (N o m in a l $) $ (000) Labor 1, N on-labor (118) (408) 759 (253) (45) O ther Total 1, , O rganizational Unit Adjustm ent 1 GBU -CPT-OU-M OHAVE - ADJ 506 AND 514 This adjustm ent removes dollars from M ohave-related FERC and 507 and transfers them to FERC 506 O perations and removes dollars from M ohave-related FERC Accounts and transfers them to FERC Account 514 M aintenance. Labor 1, N on-labor (116) (418) 763 (261) (45) O ther Total , O rganizational Unit A djustm ent 2 G B U -C P T-O U -4C 506 TO C O R R E C T A C C R U A L TO PSID E A D JU S T M E N T S This adjustm ent maps a Corporate Regulatory Accounting accrual to the proper FERC account and expense category. Labor N on-labor O ther Total O rganizational Unit Adjustm ent 3 GBU-C PT-O U -4C REMAP TO A C orporate Regulatory Accounting adjustm ent was recorded to FERC Four Corners that should have been recorded to FERC Mohave. This adjustm ent corrects the error. Labor N on-labor O ther Total O rganizational Unit Adjustm ent 4 GBU -CPT-OU-FYA MOHAVE - 506ADJ - CARETAKING This future year adjustm ent increases costs in FERC 506 for caretaking operations. Labor N on-labor O ther Total

186 141 FERC A c c o u n t: W itn e s s : 506 M iscellaneous Steam Power Expenses MOHAVE Thom as G W are D etail o f Total C o m p a n y A d ju s tm e n ts to R eco rd e d E xpenses A d js - (N o m in a l $) $ (000) O rganizational Unit Adjustm ent 5 G RC-M JP.CPT-O UX-A & G TO MOHAVE This adjustm ent transfers expenses related to M ohave G eneration from A & G FERC accounts 920/921, 923 and 930 to M ohave FERC account 506. Labor 30 (30) N on-labor O ther Total 32 (20) O rganizational Unit Adjustm ent 6 GBU -CPT.LM M -OUX-GP& S 557 This adjustm ent transfers integrated planning expenses from G eneration FERC 500, 501, 506, 53 5 and 546 to FERC 557 for historical consistency and where they are being forecast. Labor (39) 0 (190) (4) N on-labor (4) 0 (14) (3) O ther Total (43) 0 (204) (7)

187 142 Workpaper - Southern California Edison / 2015 GRC - APPLICATION End o f Workpapers for: FERC A c c o u n t: W itn e s s : 506 Miscellaneous Steam Power Expenses MOHAVE Thom as G W are

188 143 Beginning o f Workpapers for: FERC A cc o u n t: W itn e s s : 514 Maintenance of M iscellaneous Steam Plant MOHAVE - PART BILLING TRANS Thom as G W are Forecast Method Chosen 2012$ (000) Recorded Forecast Labor N/A 0 0 Non-Labor Calculated (14) (101) Other N/A 0 0 Total (14) (101) Description o f A ctivity: Participant credit billing activities related to activity Final Cost Centers included in this activity (See Appendix A for additional detail): F201204

189 144 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A ccoun t: W itness: 514 Maintenance of Miscellaneous Steam Plant MOHAVE - PART BILLING TRANS Thom as G Ware DETERMINATION OF RECORDED/ADJUSTED R ecorded Period $ (0 0 0 ) FERC Form 1 Recorded (Nominal $) Labor N on-labor O ther 0 (82) 0 0 (45) 0 0 (80) 0 0 (49) 0 0 (14) 0 Total (82) (45) (80) (49) (14) A d ju stm e n ts- (N om inal $) - see A ppendix B fo r additional detail Labor N on-labor O ther Total Recorded/Adjusted (Nominal $) Labor N on-labor (82) (45) (80) (49) (14) O ther Total (82) (45) (80) (49) (14) E s c a la tio n : Labor N on-labor O ther R ecorded/adjusted (C onstant 2012$) L ab or N on-labor (92) (50) (87) (50) (14) O ther Total (92) (50) (87) (50) (14) 0 Recorded A djusted (2012$) I I Labor (std escl) I Non-Labor (std escl) Other (not escl)

190 145 F E R C A c c o u n t : W itn e s s : M ain te n an c e o f M isc e lla n e o u s S te a m Plant M O H A V E - P A R T B IL L IN G T R A N S T h o m a s G W a re F o r e c a s t in g M e t h o d s - S u m m a r y o f R e s u lt s o f all M e t h o d s S tu d ie d $ (000) 2 R e c o r d e d Y e a r s ( ): Results of Averaging (A2) sd** Chosen Labor no Non-Labor (32) (32) (32) 18 no Other no Total (32) (32) (32) n/a n/a 3 R e c o r d e d Y e a r s ( ): Results of Linear Trending (T3) Results of Averaging (A3) r2* Chosen sd** Chosen Labor no no Non-Labor no (50) (50) (50) 30 no O ther no no Total n/a n/a (50) (50) (50) n/a n/a 4 R e c o r d e d Y e a r s ( ): Results of Linear Trending (T4) Results of Averaging (A4) r2* Chosen sd** Chosen Labor no no Non-Labor (14) no (50) (50) (50) 26 no O ther no no Total (14) 1 15 n/a n/a (50) (50) (50) n/a n/a 5 R e c o r d e d Y e a r s ( ): Results of Linear Trending (T5) Results of Averaging (A5) r2* Chosen sd** Chosen Labor no no Non-Labor (12) no (59) (59) (59) 28 no O ther no no Total (12) 4 19 n/a n/a (59) (59) (59) n/a n/a O th e r M e th o d s: Labor Non-Labor O ther Total Last Recorded Year (LRY) Itemized Forecast (IF) Chosen Chosen no no (14) (14) (14) no no no no (14) (14) (14) n/a n/a F o r e c a s t A d ju stm e n ts : Labor Non-Labor O ther Total Base Forecast Method Adjustments* Method N/A CALC (101) (101) (101) N/A * r2 =R Squared (Based on recorded years data) ** sd = standard deviation (Based on recorded years data) *** See Appendix BFor Additional Detail o o o

191 146 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e ss: 514 Maintenance of M iscellaneous Steam Plant MOHAVE - PART BILLIN G TRANS Thom as G W are R esults: Forecasting R esults Method Selected Labor N/A Non-Labor Calculated (101) (101) (101) Other N/A Total (101) (101) (101) A n a ly s is o f F o re ca stin g M ethods Analysis of Linear Trending Method: The participant share credit represents the Mohave participants ownership share of the 100% O&M expenses. It is a "calculated" amount which is derived by applying the participants ownership share of 44% to the 100% level O&M expenses. Using trends to derive this forecast is not appropriate. A n alysis of Averaging Method: The participant share credit represents the Mohave participants ownership share of the 100% O&M expenses. It is a "calculated" amount which is derived by applying the participants ownership share of 44% to the 100% level O&M expenses. Using 2, 3, 4, or 5 year averages to derive this forecast is not appropriate. Analysis of Last Recorded Year (2012): The participant share credit represents the Mohave participants ownership share of the 100% O&M expenses. It is a "calculated" amount which is derived by applying the participants ownership share of 44% to the 100% level O&M expenses. Using last recorded year to derive this forecast is not appropriate. Analysis of Itemized Forecast Method: Not applicable.

192 147 FERC A c c o u n t: W itn e s s : 514 Maintenance of M iscellaneous Steam Plant MOHAVE - PART BILLING TRANS T h om a s G W are Recorded / Forecast $ (000) J Labor (std escl) Non-Labor (std escl) Cither (not escl) R eco rd e d P eriod $ (000) Forecast Expenses (constant 2012$) Labor (standard escalation) Non-Labor (standard escalation) (92) (50) (87) (50) (14) (101) (101) (101) Other (not escalatable) Total (92) (50) (87) (50) (14) (101) (101) (101) Labor Prior year Total Change Total Non-Labor Prior year Total (14) (101) (101) Change (87) 0 0 Total (14) (101) (101) (101) Other Prior year Total Change Total Total Change Labor Non-Labor (87) 0 0 Other Total N/A (87) 0 0

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194 149 FERC A c c o u n t: W itn e s s : 514 Maintenance of M iscellaneous Steam Plant MOHAVE - PART BILLING TRANS Thom as G W are APPENDIX A Detail Description of Final Cost Centers Included in This Activity

195 150 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e ss: 514 M aintenance of M iscellaneous S team Plant MOHAVE - PART B ILLIN G TRANS Thom as G W are Description o f Final Cost Centers included in this activity: F MOHAVE 514 M AINTENANCE OF MISCELLANEOUS STEAM PLAN T PRODUCTION CONTROL ROOM Includes expense offset related to m aintenance of m iscellaneous steam p la n t.

196 151 FERC A c c o u n t: W itn e ss: 514 M aintenance of M iscellaneous Steam Plant MOHAVE - PART B ILLIN G TRANS Thom as G W are Recorded/Adjusted (Constant 2012$) By Final Cost Center $ (000) F MOHAVE 514 MAINTENANCE OF MISCELLANEOUS STEAM PLANT PRODUCTION CONTROL ROOM (92) (50) (87) (50) (14) Total (92) (50) (87) (50) (14) " D u e to rounding, totals may not tie to other workpaper pages.

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198 153 FERC A c c o u n t: W itness: 514 Maintenance of M iscellaneous Steam Plant MOHAVE - PART BILLING TRANS Thom as G W are APPENDIX B Detail of Total Company Adjustments to Recorded

199 154 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 514 M aintenance of M iscellaneous Steam Plant MOHAVE - PART BILLING TRANS Thom as G W are D etail o f Total C o m p a n y A d ju s tm e n ts to R eco rd e d E xp e n se s A d js - (N o m in a l $) $ (000) Labor N on-labor O ther Total

200 155 End of Workpapers for: FERC A c c o u n t: W itn e ss: 514 Maintenance of M iscellaneous Steam Plant MOHAVE - PART BILLING TRANS Thom as G W are

201 156 Workpaper - Southern California Edison / 2015 GRC - APPLICATION Beginning o f Workpapers for: FERC A c c o u n t: W itn e ss: 514 M aintenance of M iscellaneous Steam Plant MOHAVE Thom as G W are Forecast Method Chosen 2012$ (000) Recorded Forecast Labor N/A 27 0 Non-Labor Last Recorded Year Adj Other N/A 0 0 Total Description o f A ctivity: This activity shall include the cost of labor, materials used and expenses incurred in maintenance of miscellaneous steam generation plant. The book cost is included in account 316, Miscellaneous Power Plant Equipment. This activity includes the cost of labor, materials performed and expenses incurred in maintenance of miscellaneous steam generation plant. See Appendix C for Final Cost Centers included in this activity.

202 157 FERC A ccoun t: 514 M aintenance of M iscellaneous Steam Plant MOHAVE W itn e ss: Thom as G W are I DETERMINATION OF RECORDED/ADJUSTED R ecorded Period $ (000) FERC Form 1 Recorded (Nom inal $) L ab or N o n -L a b o r O th e r Total A d ju stm e n ts- (N om inal $) - see A p p e n d ix B fo r a d d itio n a l detail L ab or N on-labor (19) O ther Total 844 1, Recorded/Adjusted (Nominal $) L ab or N on-labor O ther Total 996 1, Escalation: Labor N on-labor O ther Recorded/Adjusted (Constant 2012$) L ab or , N o n-labor O th e r Total 1,137 1, Recorded Adjusted (2012$) Q Labor (std escl) Non-Labor (std escl) Other (not escl)

203 158 Workpaper - Southern California Edison / 2015 GRC - APPLICATION F E R C A c c o u n t : W itn e s s : M ain te n a n c e o f M isc e lla n e o u s S te a m Plant M O H A V E T h o m a s G W a re F o r e c a s t in g M e t h o d s - S u m m a r y o f R e s u lt s o f all M e t h o d s S tu d ie d $ (000) 2 R e c o r d e d Y e a r s ( ): Results of Averaging (A2) sd** Chosen Labor no Non-Labor no Other no Total n/a n/a 3 R e c o r d e d Y e a r s ( ): Results of Linear Trending (T3) Results of Averaging (A3) r2* Chosen sd** Chosen Labor (308) (661) (1,013) 0.99 no no Non-Labor no no Other no no Total (115) (442) (768) n/a n/a n/a n/a 4 R e c o r d e d Y e a r s ( ): Results of Linear Trending (T4) Results of Averaging (A4) r2* Chosen sd** Chosen Labor (268) (596) (924) 0.99 no no Non-Labor no no Other no no Total o CD 5 R e c o r d e d Y e a r s ( ): (513) (866) n/a n/a n/a n/a Results of Linear Trending (T5) Results of Averaging (A5) r2* Chosen sd** Chosen Labor (170) (450) (729) 0.97 no no Non-Labor no no Other no no Total 29 (231) (4901 n/a n/a n/a n/a O th e r M e th o d s: Labor Non-Labor Other Total Last Recorded Year (LRY) Itemized Forecast (IF) Chosen Chosen no no yes no no no n/a n/a F o r e c a s t A d ju stm e n ts : Labor Non-Labor Other Total Base Forecast Method Adjustments* Method N/A LRY N/A * r2 =R Squared (Based on recorded years data) ** sd = standard deviation (Based on recorded years data) *** See Appendix BFor Additional Detail

204 159 FERC A cc o u n t: W itn e ss: 514 Maintenance of M iscellaneous Steam Plant MOHAVE Thom as G W are R esults: Forecasting R esults Method Selected Labor N/A Non-Labor Last Recorded Year Adj Other N/A Total A n a ly s is o f F o re ca stin g M ethods Analysis of Linear Trending Method: In D and D , the CPUC stated that if costs have shown a trend in a certain direction over three or more years, the last recorded year is an appropriate base estimate. Although the years indicate a trend for the labor expenses in this account, we do not forecast any labor in this account for the Test Year This method is not applicable for non-labor because expenses have been relatively stable. A nalysis of Averaging Method: The years do not demonstrate significant fluctuations from year to year, indicating that averaging is not an appropriate method. Analysis of Last Recorded Year (2012): In D and D , the CPUC stated that if recorded expenses in an account have been relatively stable for three or more years, the last recorded year is an appropriate base estimate. The non-labor expenses have been stable from 2010 through 2012, therefore we use last recorded year as the base for non-labor. Analysis of Itemized Forecast Method: Not applicable.

205 160 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 514 M aintenance o f M iscellaneous S team Plant MOHAVE T hom as G W are I R eco rd e d P eriod Forecast Expenses (constant 2012$) Labor (standard escalation) 1,129 1, Non-Labor (standard escalation) Other (not escalatable) Total 1,137 1, $ (000) Labor Prior year Total Change (27) 0 0 Total Non-Labor Prior year Total Change Total Other Prior year Total Change Total Total Change Labor (27) 0 0 N on-labor O ther Total N/A

206 161 FERC A c c o u n t: W itn e ss: 514 Maintenance of M iscellaneous Steam Plant MOHAVE Thom as G W are This page shows the changes in Labor, Non-Labor, and Other expenditures forecast during 2013 through 2015, including reasons for the addition of personnel (labor), increased office supplies required due to an increase in activity (non-labor) Labor: 0 Not applicable. Non-Labor: 55 This non-labor increase is due to the increase in caretaking maintenance expenses over 2012 recorded. See Appendix B. Other: 0 Not applicable.

207 162 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 514 Maintenance of M iscellaneous Steam Plant MOHAVE Thom as G W are This page shows the changes in Labor, Non-Labor, and Other expenditures forecast during 2013 through 2015, including reasons for the addition of personnel (labor), increased office supplies required due to an increase in activity (non-labor) Labor: 0 Not applicable. Non-Labor: 0 Not applicable. Other: 0 Not applicable.

208 163 FERC A c c o u n t: W itn e ss: 514 Maintenance of M iscellaneous Steam Plant MOHAVE Thom as G W are This page shows the changes in Labor, Non-Labor, and Other expenditures forecast during 2013 through 2015, including reasons for the addition of personnel (labor), increased office supplies required due to an increase in activity (non-labor) Labor: 0 Not applicable. Non-Labor: 0 Not applicable. Other: 0 Not applicable.

209 164 Workpaper - Southern California Edison / 2015 GRC - APPLICATION THIS PAGE INTENTIONALLY LEFT BLANK

210 165 FERC A c co u n t: W itn e ss: 514 M aintenance of M iscellaneous Steam Plant MOHAVE Thom as G W are APPENDIX A Detail Description of Final Cost Centers Included in This Activity

211 166 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e ss: 514 M aintenance o f M iscellaneous S team Plant MOHAVE Thom as G W are Description o f Final Cost Centers included in this activity: * See Appendix Cfor Summary Final Cost Centers SUM M ARY MOHAVE 510 MAINTENANCE SUPERVISION & ENGINEERING ELECTRICAL ADMINISTRATION Includes labor, material, contract, and other costs o f forem en, planners, and m aintenance engineers in the direct supervision o f routine electrical m aintenance o f structures, turbines, boilers, and auxiliary equipm ent not specifically applicable to other m aintenance functional activities. F MOHAVE 507 RENTS ADMINISTRATION Includes costs for the rental of real property used, occupied, or operated in connection with steam facilities including the rental of stationary trailers used for conference room s, office facilities, etc. This activity does not include labor and m aterials, cylinder dem urrage, and rental of office equipm ent, post-office boxes, w ater coolers, etc. F MOHAVE 510 MAINTENANCE SUPERVISION & ENGINEERING ADMINISTRATION Includes labor, material, contract, and other costs o f forem en, planners, and m aintenance engineers in the direct supervision o f routine m aintenance o f structures, turbines, boilers, and auxiliary equipm ent not specifically applicable to other m aintenance function activities. F MOHAVE 511 MAINTENANCE OF STRUCTURES ADMINISTRATION Includes labor, material, contract, and other costs for m ajor m aintenance, repairs, and im provem ents o f structures, facilities, and grounds. Relates to costs associated with the heating system s and auxiliary (non-pow er producing) boilers, general lighting and ventilation, sum p pumps, yard lighting/drainage, w ate r supply, hydrants, wells, wharves, docks, w aterfront improvem ents, coal bins and bunkers, elevators, and pest control. F MOHAVE 512 MAINTENANCE OF BOILER PLAN T ADMINISTRATION Includes labor, material, contract, and other costs for repair and m aintenance o f the boiler including such item s as reheater, superheater, econom izer, waterw alls, headers, penthouse, boiler casing, safety valves, boiler control valves, coal nozzles, gas and air buckets, flue gas and air ducts, oxygen analyzer, igniters and com bustion controls, stack, burners, dam pers and duct work, and elevators (freight and personnel). F MOHAVE ADMINISTRATION 513 MAINTENANCE - ELECTRIC Includes labor, material, contract, and other costs for repair and m aintenance o f circulating w ater system. Includes circulating w ate r pumps, valves and m otors; fans and m otors; stacks; headers; louver distributors; intake and discharge tunnels; canal; traveling screens; river pum ps and m otors; riser valves and piping; and canal chlorination and chem ical system s. Also includes labor, m aterial, contract, and other costs for repair and m aintenance o f cooling tow ers including such item s as cold w ater basin, lattice structure, hot w ater basin, fan decks, louvers, drift elim inators, fill, stairs, risers, riser valves, distribution valves, headers, fans, gearboxes, drive shaft, torque tube, tubs, and lightning protection. F MOHAVE 514 MAINTENANCE OF MISCELLANEOUS STEAM PLAN T ADMINISTRATION Includes costs for com pany vehicles and reim bursem ent for personal autom obile use for com pany business. Includes the cost o f rental, m aintenance, and repairs. Vehicle costs directly attributable to other activities should be accounted for under the related final cost center. F MOHAVE 510 MAINTENANCE SUPERVISION & ENGINEERING W AREHOUSE Includes labor, material, contract, and other costs o f forem en, planners, and m aintenance engineers in the direct supervision of warehouse activities.

212 167 FERC A cc o u n t: A ctivity: W itn e s s : 514 M aintenance of M iscellaneous Steam Plant MOHAVE T h om a s G W are Description o f Final Cost Centers included in this activity: * See Appendix Cfor Summary Final Cost Centers F MOHAVE 514 MAINTENANCE OF MISCELLANEOUS STEAM PLAN T W AREHOUSE Includes labor, material, contract, and other costs for repair and m aintenance of the warehouse. F M OHAVE 510 M AIN TE N A N CE SUPERVISIO N & ENG INEERING ENVIR O N M EN TAL Includes labor, m aterial, contract, and oth er costs for hazardous-m aterials control and disposal. A ctivities include w aste-identification testing and storage, im plem entation o f personnel-protection safety regulations, event reporting, com pliance w ith disposal guidelines regarding transportation, permits, and training. F M OHAVE 511 M AIN TENANCE OF STRUCTURES ENVIRONM ENTAL Includes labor, m aterial, contract, and oth er costs for repair and m aintenance o f environm ental w a te r system s. Includes m onitoring w ells including motors, pipes, and associated electrical equipm ent; w aste -w ater ponds and leak detection system s; peripheral ditches; linings for ponds. F MOHAVE 512 MAINTENANCE OF BOILER PLAN T ENVIRONMENTAL Includes labor, m aterial; contract, and oth er costs for repair and m aintenance o f w ate r treatm ent system. Includes potable w a te r pum ps and tanks; service w ate r pum ps and tanks; lim e/soda ash system and storage bins; bulk acid; caustic and am m onia storage tanks and associated equipm ent; zeolite filters; softener ta n k and associated equipm ent; m akeup dem ineralizers and all associated equipm ent; brine concentrator w ith all related equipm ent. A lso includes labor, m aterial, contract, and oth er costs for repair and m aintenance o f the brine concentrator including such item s as evaporator, sum p, vapor, com pressor, pum ps less than 50 horsepow er, heat exchanger, piping, tanks less than 10,000 gallons, structural steel, controls, electrical switchgear, pole line 13.8 Kilovolt (kv), transformer, mist eliminators, and recirculation pump. F MOHAVE 513 MAINTENANCE OF ELECTRIC PLAN T ENVIRONMENTAL Includes labor, m aterial, contract, and oth er costs for repair and m aintenance o f circulating w ater system. Includes circulating w a te r pum ps, valves and m otors; fans and m otors; stacks; headers; louver distributors; intake and discharge tunnels; canal; traveling screens; river pum ps and m otors; riser valves and piping; and canal chlorination and chem ical system s. A lso includes labor, m aterial, contract, and oth er costs fo r repair and m aintenance o f cooling tow ers including such item s as cold w a te r basin, lattice structure, hot w ate r basin, fan decks, louvers, drift elim inators, fill, stairs, risers, riser valves, distribution valves, headers, fans, gearboxes, drive shaft, torque tube, tubs, and lightning protection. F M OHAVE ENVIR O N M EN TAL 514 M AIN TE N ANCE M IS C E LLA N E O U S STEAM Includes expense offset related to m aintenance of m iscellaneous steam p la n t. F MOHAVE 514 MAINTENANCE OF MISCELLANEOUS STEAM PLAN T SECURITY & HEALTH Includes labor, m aterial, contract, and oth er costs for repair and m aintenance o f the fire system including such item s as pum ps and m otors, fire hydrants, fire system controls, and em ergency fire pumps and all associated piping. F MOHAVE 511 MAINTENANCE OF STRUCTURES CONTRACT Includes labor, m aterial, contract, and oth er costs for repair and m aintenance o f facilities. Also includes gates and fence; em ployee carports; pavem ents and roadways; station sum p pum ps; oxygen system ; peripheral ditches; ponds and w aste w a ter ponds and perim eter lighting. Lighting on other system s such as boiler, etc., are charged to that system.

213 168 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A cc o u n t: 514 M aintenance of M iscellaneous Steam Plant A ctivity: W itn e ss: MOHAVE Thom as G W are Description o f Final Cost Centers included in this activity: * See Appendix Cfor Summary Final Cost Centers F MOHAVE 514 MAINTENANCE OF MISCELLANEOUS STEAM PLAN T CONTRACT Includes labor, material, contract, and other costs for repair and m aintenance o f the fire system including such item s as pum ps and motors, fire hydrants, fire system controls, and em ergency fire pumps and all associated piping. F MOHAVE 512 MAINTENANCE OF BOILER PLAN T AU XILIARY SYSTEMS Includes labor, material, contract, and other costs for repair and m aintenance o f auxiliary boilers including such item s as suction and discharge piping valves and all related equipm ent and controls. Also includes labor, m aterial, contract, and other costs for repair and m aintenance of bottom and econom izer ash system s. Includes hoppers; crushers; bottom ash pumps, m otors and associated piping with controls; bottom ash booster pum ps and motors; bottom ash sum p tank, pumps, m otors w ith associated piping; econom izer ash hoppers w ith associated piping; surge and settling tanks; dewatering bins; conveyor and continuous recirculation pum ps and m otors; sludge return pumps; and hydroveyer booster pump motors with piping. F MOHAVE 513 MAINTENANCE OF ELECTRICAL PLAN T PRIME MOVERS Includes labor, material, contract, and other costs for repair and m aintenance o f turbine and generators. Includes collector rings and brushes; althrexes; exciters and associated equipm ent and controls; high pressure, interm ediate pressure; and low pressure turbines; turning gear and m otors; main turbine lubricating oil system ; hydrogen cooling system ; stator cooling system ; seal oil system ; main stop, control com bined reheat valves and controls; condensers; hotwell; vacuum pumps; gland steam condenser; isophase bus and cooling system ; turbine/ generator instrum entation and controls; gantry cranes and bearing cooling w ater system with all associated equipm ent. F MOHAVE 510 MAINTENANCE SUPERVISION & ENGINEERING MAINTENANCE ADMINISTRATION Includes labor, material, contract, and other costs o f forem en, planners, and m aintenance engineers in the direct supervision o f routine m aintenance o f structures, turbines, boilers, and auxiliary equipm ent not specifically applicable to other m aintenance function activities. F MOHAVE 512 MAINTENANCE OF BOILER PLAN T PULVERIZERS Includes labor, material, contract, and other costs for repair and m aintenance o f mills including such item s as mill motors, piping up to the isolation gates (screw gates), riffle distributors, mill discharge dam pers, steam sm othering system, hot air gates, hot and mixed air duct, and associated mill controls and equipment. F MOHAVE 514 MAINTENANCE OF MISCELLANEOUS STEAM PLANT Includes costs for com pany vehicles and reim bursem ent for personal autom obile use for com pany business. Includes the cost o f rental, m aintenance, and repairs. Vehicle costs directly attributable to other activities should be accounted for under the related final cost center. F MOHAVE 511 MAINTENANCE OF STRUCTURES SUPPORT GROUPS Includes labor, material, contract, and other costs for m ajor m aintenance, repairs, and im provem ents o f structures, facilities, and grounds. Relates to costs associated with the heating system s and auxiliary (non-pow er producing) boilers, general lighting and ventilation, sum p pumps, yard lighting/drainage, w ate r supply, hydrants, wells, wharves, docks, w aterfront improvem ents, coal bins and bunkers, elevators, and pest control.

214 169 FERC A c c o u n t: 514 M aintenance o f M iscellaneous S team Plant A ctivity: W itn e ss: MOHAVE Thom as G W are Description o f Final Cost Centers included in this activity: * See Appendix Cfor Summary Final Cost Centers F MOHAVE 512 MAINTENANCE OF BO ILER PLAN T CRANES Includes labor, material, contract, and other costs for repair and m aintenance o f cranes. Includes centrifuge cranes, m arconaflow cranes, slurry tank cranes, fly ash silo cranes dewatering bin cranes, boiler cranes, and other outdoor cranes built under FERC 312. This excludes indoor shop cranes and gantry cranes. F MOHAVE 513 MAINTENANCE OF ELECTRICAL PLAN T ELECTRICAL DISTRIBUTION Includes labor, material, contract, and other costs for repair and m aintenance o f electrical distribution. Includes 4 Kilovolt (kv) and 13.8kV busses and switchgear; 480V, 4kV, 13.8kV, 22kV, and 500kV transform ers; 480V substations, circuit breakers, and associated equipm ent; 480V m otor control centers; station batteries battery chargers; DC distribution sw itchboards including the station annunciator system ; 480V, 4kV, and 13kV pow er cables w ith associated equipm ent. This final cost center does not include any station transm ission switchyard work. F MOHAVE 507 RENTS PRODUCTION CONTROL ROOM Includes expense offset related to Facility M anagem ent: Rents. F MOHAVE 510 MAINTENANCE SUPERVISION & ENGINEERING PRODUCTION CONTROL ROOM Includes expense offset related to Maintenance Supervision & Engineering. F MOHAVE 511 MAINTENANCE OF STRUCTURES PRODUCTION CONTROL ROOM Includes expense offset related to m aintenance of structures. F MOHAVE 512 MAINTENANCE OF BOILER PLAN T PRODUCTION CONTROL ROOM Includes expense offset related to Maintenance of Boiler Plant. F MOHAVE 513 MAINTENANCE OF ELECTRICAL PLAN T PRODUCTION CONTROL ROOM Includes expense offset related to m aintenance o f electric p la n t. F FUEL PIPELINE 510 SUPERVISION & MAINTENANCE M ECHANICAL SERVICES Includes labor, material, contract, and other costs o f forem en, planners, and m aintenance engineers in the direct supervision o f routine m aintenance o f structures, pipelines, and auxiliary equipm ent not specifically applicable to other m aintenance function activities. F FIRE SYSTEM Includes labor, material, contract, and other costs for repair and m aintenance o f the fire system including such item s as pum ps and motors, fire hydrants, fire system controls, and em ergency fire pumps and all associated piping.

215 170 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 514 M aintenance o f M iscellaneous S team Plant MOHAVE Thom as G W are Recorded/Adjusted (Constant 2012$) By Final Cost Center $ (000) * See AppendixC for Summary Final Cost Centers SU M M AR Y MOHAVE 510 MAINTENANCE SUPERVISION & ENGINEERING ELECTRICAL ADMINISTRATION (2) F MOHAVE 507 RENTS ADMINISTRATION (110) (105) (135) (98) (6) F F F F F F F F F F F MOHAVE 510 MAINTENANCE SUPERVISION & ENGINEERING ADMINISTRATION MOHAVE 511 MAINTENANCE OF STRUCTURES ADMINISTRATION MOHAVE 512 MAINTENANCE OF BOILER PLANT ADMINISTRATION MOHAVE ADMINISTRATION 513 MAINTENANCE - ELECTRIC MOHAVE 514 MAINTENANCE OF MISCELLANEOUS STEAM PLANT ADMINISTRATION MOHAVE 510 MAINTENANCE SUPERVISION & ENGINEERING WAREHOUSE MOHAVE 514 MAINTENANCE OF MISCELLANEOUS STEAM PLANT WAREHOUSE MOHAVE 510 MAINTENANCE SUPERVISION & ENGINEERING ENVIRONMENTAL MOHAVE 511 MAINTENANCE OF STRUCTURES ENVIRONMENTAL MOHAVE 512 MAINTENANCE OF BOILER PLANT ENVIRONMENTAL MOHAVE 513 MAINTENANCE OF ELECTRIC PLANT ENVIRONMENTAL (35) F MOHAVE ENVIRONMENTAL 514 MAINTENANCE MISCELLANEOUS STEAM F F F F MOHAVE 514 MAINTENANCE OF MISCELLANEOUS STEAM PLANT SECURITY & HEALTH MOHAVE 511 MAINTENANCE OF STRUCTURES CONTRACT MOHAVE 514 MAINTENANCE OF MISCELLANEOUS STEAM PLANT CONTRACT MOHAVE 512 MAINTENANCE OF BOILER PLANT AUXILIARY SYSTEMS (7) (16) F MOHAVE 513 MAINTENANCE OF ELECTRICAL PLANT PRIME MOVERS

216 171 FERC A c c o u n t: W itn e s s : 514 M aintenance o f M iscellaneous S team Plant MOHAVE Thom as G W are Recorded/Adjusted (Constant 2012$) By Final Cost Center $ (000) * See Appendix Cfor Summary Final Cost Centers F F F F F F F F F F F F MOHAVE 510 MAINTENANCE SUPERVISION & ENGINEERING MAINTENANCE ADMINISTRATION MOHAVE 512 MAINTENANCE OF BOILER PLANT PULVERIZERS MOHAVE 514 MAINTENANCE OF MISCELLANEOUS STEAM PLANT MOHAVE 511 MAINTENANCE OF STRUCTURES SUPPORT GROUPS MOHAVE 512 MAINTENANCE OF BOILER PLANT CRANES MOHAVE 513 MAINTENANCE OF ELECTRICAL PLANT ELECTRICAL DISTRIBUTION MOHAVE 507 RENTS PRODUCTION CONTROL ROOM MOHAVE 510 MAINTENANCE SUPERVISION & ENGINEERING PRODUCTION CONTROL ROOM MOHAVE 511 MAINTENANCE OF STRUCTURES PRODUCTION CONTROL ROOM MOHAVE 512 MAINTENANCE OF BOILER PLANT PRODUCTION CONTROL ROOM MOHAVE 513 MAINTENANCE OF ELECTRICAL PLANT PRODUCTION CONTROL ROOM FUEL PIPELINE 510 SUPERVISION & MAINTENANCE MECHANICAL SERVICES (105) (88) 15 (14) 0 (546) (480) (390) (227) (81) (197) (125) (134) (58) 7 (81) 9 (61) (44) F FIRE SYSTEM Total 1,135 1, ** Due to rounding, totals may not tie to other workpaper pages.

217 172 Workpaper - Southern California Edison / 2015 GRC - APPLICATION THIS PAGE INTENTIONALLY LEFT BLANK

218 173 FERC A c c o u n t: W itn e s s : 514 Maintenance of M iscellaneous Steam Plant MOHAVE Thom as G W are APPENDIX B Detail of Total Company Adjustments to Recorded

219 174 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A cco u n t: W itness: 514 M aintenance of M iscellaneous Steam Plant MOHAVE Thom as G Ware D etail o f Total C o m p a n y A d ju s tm e n ts to R eco rd e d E xp e n se s A d js - (N o m in a l $) $ (000) Labor N on-labor O ther (19) Total 844 1, Organizational Unit Adjustm ent 1 GBU-CPT-OU-M OHAVE ROLL UP TO 514 This adjustm ent rem oves dollars from Mohave FERC and transfers them to FERC 514. Labor N on-labor (19) O ther Total 844 1, Organizational Unit Adjustm ent 2 GBU-CPT-OU-FYA MOHAVE - 514ADJ CARETAKING MAINTENANCE Increase caretaking m aintenance expense from 2012 recorded. Labor N on-labor O ther Total

220 175 FERC A ccoun t: W itness: 514 Maintenance of M iscellaneous Steam Plant MOHAVE Thom as G W are APPENDIX C Final Cost Centers Included in This Activity

221 176 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e ss: 514 M aintenance of Miscellaneous Steam Plant MOHAVE Thom as G W are Final Cost Centers included in this activity: Summary Final Cost Centers: MOHAVE 510 MAINTENANCE SUPERVISION & ENGINEERING ELECTRICAL ADMINISTRATION F F201187

222 177 FERC A cc o u n t: A c t iv it y : W itn e s s : 514 Maintenance of M iscellaneous Steam Plant MOHAVE T h om a s G W are Individual Final Cost Centers: F F F F F F F F F F F F F F F F F F F F F F F F F F F F F F F526386

223 178 Workpaper - Southern California Edison / 2015 GRC - APPLICATION End o f Workpapers for: FERC A c c o u n t: W itn e s s : 514 Maintenance of M iscellaneous Steam Plant MOHAVE Thom as G W are

224 179 Beginning o f Workpapers for: FERC A cc o u n t: W itn e s s : 500 O peration Supervision and Engineering MOHAVE Thom as G W are Forecast Method Chosen 2012$ (000) Recorded Forecast Labor N/A 0 0 Non-Labor N/A 0 0 Other N /A 0 0 Total 0 0 Description o f A ctivity: This activity package has zero dollars; all costs have been transferred to other activities. Final Cost Centers included in this activity (See Appendix A for additional detail): F F F F F F F526233

225 180 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A ccoun t: 500 O peration Supervision and Engineering MOHAVE W itn e s s : T hom as G W are DETERMINATION OF RECORDED/ADJUSTED R ecorded Period $ (0 0 0 ) FERC Form 1 Recorded (Nominal $) L ab or N on-labor (74) (430) (266) (124) (44) O ther Total A djustm ents- (Nominal $) see A ppendix B fo r additional detail L abor (951) (953) (683) (483) (172) N on-labor O ther Total (877) (523) (417) (359) (128) Recorded/Adjusted (Nominal $) L abor N on-labor O ther Total Escalation: L abor N on-labor O ther R ecorded/adjusted (Constant 2012$) L ab or N on-labor O ther Total Recorded A djusted (2012$) _ Labor (std escl) Non-Labor (std escl) Other (not escl)

226 181 FERC A c c o u n t W itn e s s : 500 O peration S upervision and Engineering MOHAVE Thom as G W are APPENDIX A Detail Description of Final Cost Centers Included in This Activity

227 182 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 500 Operation Supervision and Engineering MOHAVE Thom as G W are Recorded/Adjusted (Constant 2012$) By Final Cost Center $ (000) F MOHAVE ADMINISTRATION F F MOHAVE 500 OPERATION SUPERVISION AND ENGINEERING MOHAVE CREDITS 500 OPERATION SUPERVISION & ENGINEERING F FINANCIAL SERVICES MOHAVE 500 OPERATION SUPPORT AND ENGINEERING F F OPERATIONS SUPPORT & PERFORMANCE IMPROVEMENT- MOHAVE 500 OPERATION SUPERVISION & ENGINEERING WESTMINSTER 553 MAINTENANCE GENERATION & ELECTRICAL PLANT F BUSINESS PLANNING & DEVELOPMENT - MOHAVE 500 OPERATION SUPERVISION & ENGINEERING Total ** Due to rounding, totals may not tie to other workpaper pages.

228 183 FERC A c c o u n t: W itn e s s : 500 O peration Supervision and Engineering MOHAVE Thom as G W are APPENDIX B Detail of Total Company Adjustments to Recorded

229 184 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 500 O peration Supervision and Engineering MOHAVE Thom as G W are D etail o f Total C o m p a n y A d ju s tm e n ts to R eco rd e d E xp e n se s A d js - (N o m in a l $) $ (000) Labor (951) (953) (683) (483) (172) N on-labor O ther Total (877) (523) (417) (359) (128) O rganizational Unit Adjustm ent 1 A &G FINC-RSL.CPT-OUX-CNTRLS -XFER TO GBU This adjustm ent transfers labor recorded in Financial Services Miscellaneous Expenses 930 to FERC accounts 500, 535 and 546. Labor N on-labor O ther Total O rganizational Unit Adjustm ent 2 GBU -CPT.LM M -OUX-GP& S 557 This adjustm ent transfers integrated planning expenses from Generation FERC 500, 501, 506, 535 and 546 to FERC 557 for historical consistency and w here they are being forecast. Labor (340) (385) N on-labor (93) (133) O ther Total (433) (518) O rganizational Unit Adjustm ent 3 GBU-CPT-OU-M OHAVE -A D J 506 AND 514 This adjustm ent removes dollars from Mohave-related FERC and 507 and transfers them to FERC 506 O perations and removes dollars from M ohave-related FERC Accounts and transfers them to FERC Account 514 M aintenance. Labor (625) (568) (683) (483) (172) N on-labor O ther Total (458) (6) (417) (359) (128) 0 0 0

230 185 End of Workpapers for: FERC A c c o u n t: W itn e ss: 500 Operation Supervision and Engineering MOHAVE Thom as G W are

231 186 Workpaper - Southern California Edison / 2015 GRC - APPLICATION Beginning o f Workpapers for: FERC A c c o u n t: W itn e ss: 501 Fuel MOHAVE Thom as G W are Forecast Method Chosen $ (0 0 0 ) Recorded Forecast Labor N /A 0 0 N on-labor N /A 0 0 Other N /A 0 0 Total 0 0 Description o f A ctivity: This activity package has zero dollars and is not forecast. See Appendix C for Final Cost Centers included in this activity.

232 187 FERC A ccoun t: W itn e s s : 501 Fuel MOHAVE T hom as G W are DETERMINATION OF RECORDED/ADJUSTED R ecorded Period $ (000) FERC Form 1 Recorded (Nom inal $) Labor N on-labor 5, ,183 (11) 0 O ther Total 5,731 1,012 1,183 (11) 0 A djustm ents- (Nominal $) see A ppendix B fo r additional detail L ab or (32) (77) Non-Labor (5,699) (935) (1,183) 11 0 O ther Total (5,731) (1,012) (1,183) 11 0 Recorded/Adjusted (Nominal $) L ab or Non-Labor O ther Total Escalation L ab or Non-Labor O ther Recorded/Adjusted (Constant 2012$) L ab or Non-Labor O ther Total Recorded A djusted (2012$) _g Labor (std escl) Non-Labor (std escl) Other (not escl)

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234 189 FERC A c c o u n t W itn e s s : 501 Fuel MOHAVE Thom as G W are APPENDIX A Detail Description of Final Cost Centers Included in This Activity

235 190 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC Account: Activity: Witness: 501 Fuel MOHAVE Thomas G Ware Recorded/Adjusted (Constant 2012$) By Final Cost Center $ (000) * See Appendix Cfor Summary Final Cost Centers SUMMARY 539 MISCELLANEOUS HYDRAULIC EXPENSE F MOHAVE 501 FUEL ADMINISTRATION EXPENSE F MOHAVE 501 FUEL F MOHAVE 501 FUEL PRODUCTION CONTROL ROOM F MOHAVE 501 FUEL COAL LABOR F MISCELLANEOUS GENERAL EXPENSES F F F MOHAVE 501 COAL EXPENSE - CORPORATE REGULATORY ACCOUNTING MOHAVE 501 FUEL CONTROL ROOM ACCOUNT MOHAVE CORPORATE ACCOUNTING ADJUSTMENT-FUEL Total ** Due to rounding, totals may not tie to other workpaper pages.

236 191 FERC A c c o u n t W itn e s s : 501 Fuel MOHAVE Thom as G W are APPENDIX B Detail of Total Company Adjustments to Recorded

237 192 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 501 Fuel MOHAVE Thom as G Ware D etail o f Total C o m p a n y A d ju s tm e n ts to R eco rd e d E xp e n se s A d js - (N o m in a l $) $ (000) Labor (32) (77) N on-labor (5,699) (935) (1,183) O ther Total (5,731) (1,012) (1,183) C om pany W ide A djustm ent 1 G R C -JA B -C W -M O H C O A LFU E L This ratem aking adjustm ent rem oves the cost o f coal fuel burned at the M ohave generating station. S uch costs are recovered through the Energy Resource R ecovery A ccoun t (E R R A) reasonableness proceeding and w ill not be recovered in the general rate case. Labor N on-labor (5,694) (966) (128) O ther Total (5,694) (966) (128) Organizational Unit Adjustm ent 1 GBU -CPT.LM M -OUX-GP & S 557 This adjustm ent tra nsfers integrated planning expenses from G eneration FERC 500, 501, 506, 53 5 and 546 to FERC 557 for historical consistency and where they are being forecast. Labor (37) (77) N on-labor (13) (3) O th er Total (50) (80) Organizational Unit Adjustm ent 2 GBU-CPT-OU-M OHAVE - ADJ 506 AND 514 This adjustm ent rem oves dollars from M ohave-related FERC and 507 and tra nsfers them to FERC 506 O perations and rem oves dollars from M ohave-related FERC A ccounts and transfers the m to FERC A ccount 514 M aintenance. Labor N on-labor 8 34 (1,055) O ther Total (1,055)

238 193 End o f Workpapers for: FERC A c c o u n t: W itn e s s : 501 Fuel MOHAVE T hom as G W are

239 194 Workpaper - Southern California Edison / 2015 GRC - APPLICATION Beginning o f Workpapers for: FERC A c c o u n t: W itn e s s : 502 S team Expenses MOHAVE Thom as G W are Forecast Method Chosen $ (0 0 0 ) Recorded Forecast Labor N/A 0 0 Non-Labor N/A 0 0 O ther N /A 0 0 Total 0 0 Description o f A ctivity: This activity package has zero dollars; all costs have been transferred to other activities. Final C ost Centers included in this activity (See Appendix A for additional detail): F F F F F F516576

240 195 FERC A ccoun t: 502 Steam Expenses MOHAVE W itn e ss: Thom as G W are DETERMINATION OF RECORDED/ADJUSTED I R ecorded Period $ (0 0 0 ) FERC Form 1 Recorded (Nom inal $) L ab or N o n -L a b o r (34) (134) (1) O th e r Total (77) 0 A d ju stm e n ts- (N om inal $) - see A p p e n d ix B fo r a d d itio n a l detail Labor (325) (168) (111) (57) (D N on-labor (87) (87) O ther Total (412) (255) (77) 77 0 Recorded/Adjusted (Nominal $) Labor N on-labor O ther Total Escalation: Labor N on-labor O ther Recorded/Adjusted (C onstant 2012$) Lab or N o n-labor O th e r Total Recorded Adjusted (2012$) Labor (std escl) Non-Labor (std escl) Other (not escl)

241 196 Workpaper - Southern California Edison / 2015 GRC - APPLICATION THIS PAGE INTENTIONALLY LEFT BLANK

242 197 FERC A c c o u n t W itn e s s : 502 Steam E xpenses MOHAVE Thom as G W are APPENDIX A Detail Description of Final Cost Centers Included in This Activity

243 198 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e s s : 502 Steam Expenses MOHAVE Thom as G W are Recorded/Adjusted (Constant 2012$) By Final Cost Center $ (000) F F F F F F MOHAVE 502 STEAM EXPENSES ADMINISTRATION MOHAVE 502 STEAM EXPENSES ENVIRONMENTAL MOHAVE 502 STEAM EXPENSE WATER & CHEMISTRY MANAGEMENT MOHAVE 502 STEAM EXPENSE BOILER SYSTEMS MOHAVE 502 STEAM EXPENSE PRODUCTION CONTROL ROOM MOHAVE 502 STEAM EXPENSES CHEMICALS Total ** Due to rounding, totals may not tie to other workpaper pages.

244 199 FERC A c c o u n t W itn e s s : 502 S team Expenses MOHAVE Thom as G W are APPENDIX B Detail of Total Company Adjustments to Recorded

245 200 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e ss: 502 S team Expenses MOHAVE Thom as G W are D etail o f Total C om p any A d ju s tm e n ts to R ecorded E xpenses A d js - (N om inal $) $ (000) Labor (325) (168) (111) (57) (1) N on-labor (87) (87) O ther Total (412) (255) (77) O rganizational Unit Adjustm ent 1 GBU-CPT-OU-M OHAVE -A D J 506 AND 514 This adjustm ent removes dollars from Mohave-related FERC and 507 and transfers them to FERC 506 O perations and removes dollars from M ohave-related FERC Accounts and transfers them to FERC Account 514 Maintenance. Labor (325) (168) (111) (57) (1) N on-labor (87) (87) O ther Total (412) (255) (77)

246 201 End of Workpapers for: FERC A c c o u n t: W itness: 502 Steam Expenses MOHAVE Thom as G W are

247 202 Workpaper - Southern California Edison / 2015 GRC - APPLICATION Beginning o f Workpapers for: FERC A c c o u n t: W itn e ss: 505 Electric Expenses MOHAVE Thom as G W are Forecast Method Chosen $ (0 0 0 ) Recorded Forecast Labor N/A 0 0 N on-labor N /A 0 0 O ther N /A 0 0 Total 0 0 Description o f A ctivity: This activity package has zero dollars; all costs have been transferred to other activities. Final C ost C enters included in this activity (See A ppendix A fo r additional detail): F F F F526389

248 203 FERC A ccoun t: W itn e s s : 505 Electric Expenses MOHAVE T hom as G W are DETERMINATION OF RECORDED/ADJUSTED R ecorded Period $ (000) FERC Form 1 Recorded (Nominal $) L ab or N on-labor (28) 91 8 (3) 0 O ther Total (3) 0 A djustm ents- (Nominal $) see A ppendix B fo r additional detail L abor (110) (68) (D 0 0 N on-labor 28 (91) (8) 3 0 O ther Total (82) (159) (9) 3 0 Recorded/Adjusted (Nominal $) L abor N on-labor O ther Total E scalation: Labor Non-Labor O ther Recorded/Adjusted (Constant 2012$) L ab or Non-Labor O ther Total Recorded A djusted (2012$) _g Labor (std escl) Non-Labor (std escl) Other (not escl)

249 204 Workpaper - Southern California Edison / 2015 GRC - APPLICATION THIS PAGE INTENTIONALLY LEFT BLANK

250 205 FERC A c c o u n t W itness: 505 Electric Expenses MOHAVE Thom as G W are APPENDIX A Detail Description of Final Cost Centers Included in This Activity

251 206 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e ss: 505 Electric Expenses MOHAVE Thom as G W are Recorded/Adjusted (Constant 2012$) By Final Cost Center $ (000) F F F MOHAVE 505 ELECTRICAL EXPENSE WATER & CHEMICAL MANAGEMENT MISCELLANEOUS EXPENSES SHAREHOLDER FUNDED MOHAVE 505 ELECTRICAL EXPENSE PRODUCTION CREDIT F WATER TREATMENT Total ** Due to rounding, totals may not tie to other workpaper pages.

252 207 FERC A c c o u n t W itness: 505 Electric Expenses MOHAVE Thom as G W are APPENDIX B Detail of Total Company Adjustments to Recorded

253 208 Workpaper - Southern California Edison / 2015 GRC - APPLICATION FERC A c c o u n t: W itn e ss: 505 Electric Expenses MOHAVE Thom as G W are D etail o f Total C om p any A d ju s tm e n ts to R ecorded E xpenses A d js - (N om inal $) $ (000) Labor (110) (68) (1) Non-Labor 28 (91) (8) Other Total (82) (159) (9) Organizational Unit Adjustm ent 1 GBU-CPT-OU-M OHAVE -A D J 506 AND 514 This adjustm ent removes dollars from Mohave-related FERC and 507 and transfers them to FERC 506 O perations and removes dollars from M ohave-related FERC Accounts and transfers them to FERC Account 514 Maintenance. Labor (110) (68) (1) Non-Labor 28 (91) (8) Other Total (82) (159) (9)

254 209 End of Workpapers for: FERC A c c o u n t: W itness: 505 Electric Expenses MOHAVE Thom as G W are

255 210 Workpaper - Southern California Edison / 2015 GRC - APPLICATION Beginning o f Workpapers for: FERC A c c o u n t: W itn e ss: 507 Rents MOHAVE Thom as G W are Forecast Method Chosen $ (0 0 0 ) Recorded Forecast Labor N/A 0 0 N on-labor N /A 0 0 O ther N /A 0 0 Total 0 0 Description o f A ctivity: This activity package has zero dollars; all costs have been transferred to other activities. Final C ost C enters included in this activity (See A ppendix A fo r additional detail): F F201199

256 211 FERC A ccoun t: 507 Rents MOHAVE W itn e s s : T hom as G W are DETERMINATION OF RECORDED/ADJUSTED R ecorded Period $ (0 0 0 ) FERC Form 1 Recorded (Nominal $) L ab or N on-labor (36) (37) (64) (48) (6) O ther Total (36) (37) (64) (48) (6) A djustm ents- (Nominal $) see A ppendix B fo r additional detail L abor N on-labor O ther Total Recorded/Adjusted (Nominal $) L abor N on-labor O ther Total Escalation: L abor N on-labor O ther R ecorded/adjusted (Constant 2012$) L ab or N on-labor O ther Total Recorded A djusted (2012$) _g Labor (std escl) Non-Labor (std escl) Other (not escl)