Table Of Contents. Section Page Witness DECOMMISSIONING COST CATEGORIZATION STRUCTURE...2

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1 Application No.: Exhibit No.: Witnesses: A SCE-04 Jose Perez (U 338-E) Supplemental Testimony of Southern California Edison Company Regarding Decommissioning Cost Categorization and Employee Severance Expenses for San Onofre Nuclear Generating Station (SONGS) Unit Nos. 2 & 3 Before the Public Utilities Commission of the State of California Rosemead, California May 11, 2015

2 SCE-04: Supplemental Testimony of Southern California Edison Company Regarding Decommissioning Cost Categorization and Employee Severance Expenses for San Onofre Nuclear Generating Station (SONGS) Unit Nos. 2 & 3 Table Of Contents Section Page Witness I. INTRODUCTION...1 J. Perez II. DECOMMISSIONING COST CATEGORIZATION STRUCTURE...2 A. Cost Categorization and Tracking for Decommissioning Project Management Decommissioning Cost Estimate Appendix D...2 a) Distributed Expenses...2 b) Undistributed Expenses...3 B. SCE s Numbering Convention To Facilitate Tracking And Reporting of Decommissioning Expenses...3 C. SONGS Accounting System...6 D. Written Records of Key Decisions...8 III. SEVERANCE PLAN COSTS...9 A. Severance Plan Benefits Cash Payments Outplacement Services Education Reimbursement...11 B. Forecast of Severance Costs to be Incurred in 2015 and Later...12 Attachment 1 - SONGS Prompt DECON Base Case, 2024 DOE Acceptance, Dry Storage Attachment 2 - Witness Qualifications of Jose L. Perez -i-

3 SCE-04: Supplemental Testimony of Southern California Edison Company Regarding Decommissioning Cost Categorization and Employee Severance Expenses for San Onofre Nuclear Generating Station (SONGS) Unit Nos. 2 & 3 List Of Figures Figure Page Figure II-1 DCE Distributed Cost Item Figure II-2 DCE Undistributed Cost Item Figure II-3 DCE Numbering Convention...5 Figure II-4 WBS Numbering Convention...6 Figure II-5 SCE Cost Accounting...7 -ii-

4 I. INTRODUCTION In Decision (D.) (2012 NDCTP Phase 2 Decision), the California Public Utilities Commission (Commission) established a number of requirements for a more transparent and accountable format for cost disclosure by SCE when estimating and undertaking decommissioning activities 1 at San Onofre Nuclear Generating Station Units 2 and 3 (SONGS 2 & 3). Ordering Paragraph No. 6 directed SCE to develop a cost categorization structure for tracking decommissioning expenditures, and to submit supplemental testimony in this proceeding explaining this structure, including how the structure conforms to Ordering Paragraph No. 5 and allows for a comparison of recorded costs to the SONGS 2 & 3 decommissioning cost estimate (DCE). 2 In addition, the Commission ordered SCE to submit supplemental testimony regarding employee assistance benefits (i.e., severance benefits) provided to employees severed as a result of the SONGS 2 & 3 retirement and severance expenses forecast in the DCE for The Scoping Memo for this proceeding adopted by Administrative Law Judge (ALJ) Bushey set May 11, 2015 as the deadline for this testimony. 3 Chapter II of this supplemental testimony addresses SCE s cost categorization structure for tracking SONGS 2 & 3 decommissioning costs. Chapter III describes the severance plan benefits available to eligible severed employees and identifies the potential severance costs for 2015 and thereafter. 1 D , p Id., p. 146, Ordering Paragraph (OP) No Scoping Memo, p. 4. 1

5 II. DECOMMISSIONING COST CATEGORIZATION STRUCTURE A. Cost Categorization and Tracking for Decommissioning Project Management 1. Decommissioning Cost Estimate Appendix D The cost categorization structure for the SONGS 2 & 3 decommissioning project begins with the DCE that SCE submitted to the Commission in A , Exhibit SCE-01. The DCE contains the estimated cost and schedule for the entire SONGS 2 & 3 decommissioning work scope based on information known at the time SCE prepared the DCE. Within the body of the DCE, Table divides the work scope into the three decommissioning cost categories (license termination, spent fuel management, and site restoration), and further sub-divides the activities associated with each category into chronological periods. The DCE also includes the following appendices: (1) Appendix A List of Systems and Structures; (2) Appendix B Spent Fuel Shipping Schedule; (3) Appendix C Detailed Project Schedule; (4) Appendix D Detailed Cost Table (referred to as ); (5) Appendix E Annual Cash Flow Table; and (6) Appendix F SDG&E SONGS Decommissioning Costs (100%). DCE Appendix D, provides the line item detail for the DCE. Specifically, this table divides the work scope for each cost category/period into distributed and undistributed costs, and then into line items for each decommissioning activity that correspond to the distributed or undistributed costs for the category/period. 5 a) Distributed Expenses Distributed expenses are associated with specific decommissioning activities, including planning and preparation, decontamination, packaging, disposal, and removal of major components and systems. DCE Appendix D, provides a unique DCE item number for each specific decommissioning activity and its associated cost. For example, DCE line item 3.06 identifies the activity and associated costs for Primary System Decontamination Unit 2 for Decon (License Termination), Period Exhibit SCE-1, Appendix A-1 (Decommissioning Cost Estimate), p. A Exhibit SCE-1, Appendix A-1 (Decommissioning Cost Estimate), p. A-1-56 to A See Exhibit SCE-1, Appendix A-1 (Decommissioning Cost Estimate), p. A

6 b) Undistributed Expenses In contrast, undistributed expenses are essentially time-dependent, and include such things as utility and decommissioning general contractor staff, property taxes, insurance, regulatory fees and permits, energy costs, and security staff. These are expenses that SCE will incur across all decommissioning categories (license termination, spent fuel management, and site restoration) throughout all phases of decommissioning. DCE Appendix D, provides DCE item numbers for anticipated undistributed expenses (e.g., utility staff, security guard force, insurance, taxes), with the assigned item number repeating for all periods in that category for which the costs are expected to be incurred. B. SCE s Numbering Convention To Facilitate Tracking And Reporting of Decommissioning Expenses As noted above, DCE Appendix D line item numbers for distributed expenses are unique, with each decommissioning activity in (distributed costs) having a unique number. Due to the numbering scheme adopted in, some of the numbers used to identify distributed expenses also were used to identify undistributed expenses, even though the expenses are unrelated. For example, item number 2.01 appears as both a distributed expense (Develop Certified Fuel Handler Program, Decon. Period 2) 7 and as an undistributed expense (Utility Spent Fuel Staff, Spent Fuel Management, SNF Periods 1-5, and SNF D&D Period 1-2) 8 as shown in Figure II-1 and Figure II-2 below, which provides an excerpt from the table. 7 See Exhibit SCE-1, Appendix A-1, p. A See Exhibit SCE-1, Appendix A-1, p. A

7 Figure II-1 DCE Distributed Cost Item 2.01 Figure II-2 DCE Undistributed Cost Item In addition, item numbers used to identify undistributed expenses repeat throughout DCE Appendix D, within their associated decommissioning category due to the nature of the undistributed costs. For example, item number 2.01 for undistributed costs repeats in each period for the spent fuel management (SNF) category. 4

8 Although the numbering in is appropriate for a DCE, SCE has enhanced that numbering convention to facilitate the tracking and reporting of decommissioning expenses and compare recorded expenses to the DCE. SCE explains this numbering convention in further detail below. The numbering convention fulfills the Commission s direction for a cost categorization structure to track decommissioning expenditures in a way that facilitates comparing and reconciling actual recorded expenses to the DCE. Specifically, SCE added a coded prefix to the original numbers to achieve a unique item number for each distributed and undistributed cost. By utilizing this convention, each item number in has been revised to the following general format: XX-Y-Z-A.AA. Attachment 1 to this supplemental testimony provides a revised version of with the new numbering convention. SCE s DCE numbering convention is depicted in Figure II-3 below: Figure II-3 DCE Numbering Convention 5

9 C. SONGS Accounting System SCE also developed a Work Breakdown Structure (WBS) 9 to allow for the recording of costs in its internal SONGS accounting system. Specifically, SCE uses SAP, 10 its corporation-wide enterprise accounting system, to record all decommissioning costs. SCE created one or more accounts (usually referred to as orders ) for each WBS number. As decommissioning costs are incurred, SCE collects the recorded and/or invoiced costs for each order in SAP (including costs for SCE labor, invoiced costs, and SCE overhead costs). All costs incurred are expressed in year of expense dollars in SAP. SCE s WBS numbering convention is depicted in Figure II-4 below: Figure II-4 WBS Numbering Convention G RAPH 9 A Work Breakdown Structure is a hierarchical and incremental decomposition of a project into phases, deliverables, and work packages. 10 SAP AG (Systeme, Anwendungen und Produkte in der Datenverarbeitung Aktiengesellschaft or Systems, Applications and Products in Data Processing, Incorporated) is a German multinational software corporation that develops enterprise software to manage business operations and customer relations. SAP is headquartered in Walldorf, Baden-Württemberg, Germany, and has regional offices in 130 countries. The company has more than 282,000 customers in 190 countries. 6

10 After the decommissioning costs for each month are recorded in SAP, SCE imports a copy of the SAP recorded cost data into the SONGS Decommissioning Project Control System (DPCS) to generate reports, as illustrated in Figure II-5 below. Figure II-5 SCE Cost Accounting DPCS also contains the budgeted amounts for each WBS activity, which are generally based on the DCE s estimated cost for each activity. SCE can compare the recorded costs for each WBS activity to the corresponding budgeted amounts. The budgeted amounts for distributed cost activities reflect monthly cash flows, excluding contingency, throughout their scheduled durations. The budgeted amounts for undistributed costs reflect monthly cash flows, excluding contingency, throughout their DCE periods. SCE retains all contingency funds in management reserve accounts. Contingency funds are only applied to specific WBS items on an as-needed basis after explicit management approval. Because contingency can only be applied to specific WBS items, SCE has a record of the decommissioning activity to which each contingency dollar is applied. 7

11 Because DPCS also will allow SCE to track the physical progress of each WBS activity relative to its schedule and recorded costs, it will facilitate SCE s tracking of the earned value for each WBS activity after physical decontamination and dismantling activities begin. Earned value is an accounting principle for tracking the amount of work being completed. Such tracking will also be necessary for accurate and timely management reporting, variance trending, co-participant invoicing, and regulatory reporting. 11 DPCS tracks the recorded costs in year of expense dollars and converts them to 2014 dollars for reconciliation to the DCE. 12 The cross-referencing of the SAP order numbers with the corresponding WBS numbers in DPCS with SCE s DCE enhanced numbering convention, as described above, allows for the tracking of the costs for each decommissioning activity throughout SCE s accounting system and the reconciliation of such recorded costs to estimated costs in the DCE. SCE is then able to prepare reconciliation testimony, such as the testimony provided in A , Exhibit SCE-01A. D. Written Records of Key Decisions D Ordering Paragraph No. 5 further directs SCE to demonstrate that its cost accounting system also allows for written record of key decisions about cost, scope, or timing of a major project or activity (i.e., varies by plus or minus 10%), including the nature of the decision, who made it, factors considered, and whether and what alternatives were considered. 13 SCE uses the project controls and accounting systems described above to track cost and schedule performance. SCE separately maintains written records of key decisions, or analyses of alternatives, regarding the cost, scope, or timing of major decommissioning activities. This written record is maintained by the SONGS Decommissioning Team. Any material changes to cost, scope, or timing of major decommissioning activities, including those that result from key decisions made by the SONGS Decommissioning Team, are trended in SCE s cost accounting system and are integrated into the decommissioning budgets and schedules. Additionally, SCE s 11 SCE has not yet launched earned value tracking in DPCS, but plans to do so before major decontamination and dismantling activities commence. 12 To ensure consistency, SCE uses the same Handy-Whitman escalation factors for this purpose as it uses in the Nuclear Decommissioning Cost Triennial Proceedings (NDCTP). 13 D , p. 146, Ordering Paragraph (OP) No. 5. 8

12 1 2 cost accounting system uses an integrated change process that requires written justifications for cost, scope, schedule, and timing changes for decommissioning activities III. SEVERANCE PLAN COSTS A. Severance Plan Benefits The Edison International (EIX) Severance Plan (Severance Plan) provides assistance benefits to fulltime, non-executive, non-represented employees whose employment is terminated due to workforce reductions. Employees represented by a union receive severance benefits under the terms of the applicable collective bargaining agreements (CBA). Executive employees receive severance benefits under the terms of the applicable executive severance plan. The Severance Plan provides transition benefits to SCE employees who are severed involuntarily or who chose to accept voluntary severance under specified conditions, including the SCE employees who have already and will yet become unemployed through no fault of their own as a result of the decommissioning of SONGS 2 & In addition, the SCE severance plan is the mechanism by which SCE fulfills its statutory obligation to provide assistance in finding comparable alternate employment opportunities for its employees who become unemployed as a result of decommissioning. 15 The Severance Plan benefits provided to SCE employees who were displaced as a result of the decommissioning of SONGS 2 & 3 are the same as the benefits provide to other SCE employees whose jobs have been eliminated due to other business needs during the past several years. SCE has benchmarked its 14 Under CA Public Utilities Code Section 8322(g), Decommissioning nuclear facilities causes electric utility employees to become unemployed through no fault of their own, and these employees are entitled to reasonable job protection the costs of which are properly includable in the costs of decommissioning. 15 Under CA Public Utilities Code Section 8330, Every electrical utility involved in decommissioning, closure, or removal of nuclear facilities, shall provide assistance in finding comparable alternative employment opportunities for its employees who become unemployed as the result of decommissioning, closure, or removal. The commission or the board shall authorize the electrical utility to collect sufficient revenue through electric rates and charges to recover the cost, if any, of compliance with this section. 9

13 severance benefits and found that they are consistent with the severance benefits offered by industry peers and other companies of a similar size. The Severance Plan benefits and benefits under a CBA for severed SCE workers include: (1) a lump sum cash payment based on years of service; (2) outplacement services, and (3) educational reimbursement. Each of these benefits is described in greater detail below. 1. Cash Payments Under the Severance Plan, severed employees receive a cash payment processed using one of two formulas, one based on completed years of service, and another minimum benefit for participants age 40 or older (for non-represented only). Represented and non-represented employees may receive the payment calculated in Formula #1. Non-represented employees age 40 or over with few years of service receive the larger of the amounts calculated in Formula #1 or Formula #2: 16 Formula #1 Based on Completed Years of Service: Determined the number of completed years of service (number of years between vacation inservice date and termination date) Each employee is eligible to receive a minimum of 4 weeks of cash payment, plus Two weeks per completed years of service (maximum of 48 weeks) Calculation: hourly base rate times 40 to get a weekly payout; weekly payout times number of weeks based on completed years of service up to maximum amount Formula #2 Based on Employee Age (for Non-Represented Employees only) Determined whether the employee was age 40 or over Each employee is eligible to receive a minimum of 4 weeks of cash payment, plus One week of base pay per year of age over 40 (maximum of 26 weeks) Calculation: hourly base rate times 40 to get a weekly payout; weekly payout times number of years over 40 up to maximum amount 16 For example, under Formula #1, a 50-year old employee with two completed years of service would receive a cash payment for 8 weeks (4 week minimum plus 2 weeks for each of his or her 2 completed years of service). Under Formula #2, however, that employee would receive a cash payment for 14 weeks (4 week minimum plus 1 week for each of his or her 10 years of age over age 40). In this example, the Formula #2 amount would be paid (non-represented employees receive the higher of the two formulas). 10

14 Outplacement Services Employees receiving a severance package may also be eligible for outplacement assistance 17 through Lee Hecht Harrison Human Resources Consulting (LHH). LHH specializes in outplacement services, and offers a wide range of options that helps employees transition into a new job, be self-employed, or opt for retirement. Employees are advised of this program upon being severed, and have the opportunity to take advantage of this benefit if they choose to do so. The duration of this benefit is based on job classification: Classification Non-Exempt and Represented Exempt / Individual Contributor Exempt / Leader (Chief)* Outplacement Assistance Period 1 month 3 months 6 months * Must have direct reports If an employee elects to use this benefit, he/she is assigned a career coach to help them identify career options and a plan for his/her career transition. In addition, the employee may participate in career workshops, professional training courses, seminars, interactive e-learning courses, and has access to career centers that offer access to a job bank database (including access to job listings with hundreds of corporations), computers, phones, printers, fax machines, and administrative support needed to support finding a new job position. The outplacement services, described above, for severed employees are consistent with industry standards. 3. Education Reimbursement Severed employees may also be eligible to receive reimbursement for education expenses. The expenses have to be incurred within twenty-four months of the separation date. In addition, this benefit is based on the employee s years of service with SCE. Severed employees with less than five years of service on the date of separation are eligible to receive up to $5,000 in benefits and eligible employees with more than five years of service are eligible to receive up to $10,000 in benefits. 17 SCE provided this service to Non-Exempt and Represented employees for 1 month, Exempt/Individual Contributor employees for 3 months and Exempt/Leader employees for up to 6 months. Employees who were interested in utilizing this benefits are required to contact LHH within six months following the date of separation. 11

15 If the Years of Service is The Company may reimburse up to this amount of educational expenses Under 5 years $5,000 5 or more $10,000 This program includes education expenses for degree and certificate programs, professional credentials, business-oriented computer classes, and other non-degree programs that would provide vocational skill development that will advance career objectives. The institutions must be accredited by recognized agencies and/or associations. The reimbursable expenses includes tuition (deferred payments; loan amounts with school-approved repayment obligation), required enrollment/registration fees (including student body and health card fees), graduation fees, mandatory laboratory fees, required book costs, required exam and grade fees, and required test fees. To receive reimbursement for these expenses, severed employees must provide SCE with completed forms to process the reimbursement, documentation of satisfactorily completing each class with a passing grade (as defined by the educational institution), and paid receipts for all eligible expenses. These benefits are also consistent with industry standards. B. Forecast of Severance Costs to be Incurred in 2015 and Later Between June 7, 2013 and March 31, 2015, 1,157 SCE employees were voluntarily or involuntarily severed in connection with the SONGS 2 & 3 retirement. SCE provided severance benefits to these former employees. The estimated average severance benefit included in the DCE was approximately $98,000 per employee, excluding contingency. 18 To date, however, the average severed employee has received a total benefit of approximately $67,000. A portion of this underrun exists because many of the severed employees have not yet fully utilized all of the severance benefits that are available to them. To date, for example, the severed employees have used less than 10% of the total amount budgeted for educational reimbursements. However, severed employees may take up to two years to exhaust their education reimbursement benefits. 18 The severance basis used in the DCE for Reductions In Force beginning on June 30, 2013, and going through the end of the decommissioning project was $92,973 per employee, plus an SCE A&G rate of 5%. This amount included costs for transitional medical benefits, retiree medical benefits, and retiree life insurance, for which the funding was accrued in the normal pension and benefits overhead accounts associated with the wages and salaries earned by those employees. The amount also included costs for incentive program payments earned by those employees, which are also funded independently from the severance benefits. These cost will not be recorded to decommissioning accounts. 12

16 As of April 1, 2015, 375 SCE employees remain at SONGS. These employees may be eligible for a severance package at some point in the future due to the permanent retirement of SONGS. SCE plans to eliminate approximately 50 of these 375 positions at SONGS during the remainder of 2015, and anticipates providing severance packages to those displaced employees. After 2015, the remaining SCE positions at SONGS, currently projected to be approximately 325, will be eventually eliminated throughout the decommissioning project schedule as various project milestones are completed. 13

17 Attachment 1

18 A. License Termination Decon Pd 1 Transition to Decommissioning Distributed LT-1-D-1.05 WD Disposition of Legacy Wastes $0 $0 $9,153 $735 $0 $9,888 Distributed Subtotal $0 $0 $9,153 $735 $0 $9,888 Undistributed LT-1-U-1.01 WD Utility Staff $30,049 $0 $0 $0 $0 $30,049 LT-1-U-1.05 WD Insurance $0 $0 $0 $5,352 $0 $5,352 LT-1-U-1.07 WD NRC Decommissioning Fees $0 $0 $0 $1,349 $0 $1,349 LT-1-U-1.08 WD Materials and Services $0 $0 $0 $1,007 $0 $1,007 LT-1-U-1.10 WD Energy $0 $0 $0 $2,422 $0 $2,422 LT-1-U-1.17 WD Association Fees and Expenses $0 $0 $0 $315 $0 $315 LT-1-U-1.18 WD Utilities (Water, gas, phone) $0 $0 $0 $840 $0 $840 LT-1-U-1.20 WD Non-Process Computers $0 $0 $0 $224 $0 $224 LT-1-U-1.21 WD Telecommunications $0 $0 $0 $41 $0 $41 LT-1-U-1.22 WD Personal Computers $0 $0 $0 $9 $0 $9 LT-1-U-1.24 WD Environmental Permits and Fees $0 $0 $0 $818 $0 $818 Undistributed Subtotal $30,049 $0 $0 $12,378 $0 $42,426 Decon Pd 1 Subtotal $30,049 $0 $9,153 $13,113 $0 $52,315 Page 1 of 25

19 Decon Pd 2 Decommissioning Planning and Site Modifications Distributed LT-2-D-2.01 WD Develop Certified Fuel Handler Program $143 $1 $0 $0 $36 $180 LT-2-D-2.02 WD Prepare Post-Shutdown QA Plan $427 $1 $0 $0 $107 $535 LT-2-D-2.03 WD Prepare Post-Shutdown Security Plan $427 $1 $0 $0 $107 $535 LT-2-D-2.04 WD Prepare Post-Shutdown Fire Protection Plan $427 $1 $0 $0 $107 $535 LT-2-D-2.05 WD Prepare Defueled Radiation Protection Manual $427 $1 $0 $0 $107 $535 LT-2-D-2.06 WD Prepare Preliminary Defueled Technical Specifications $0 $0 $0 $135 $34 $169 LT-2-D-2.07 WD Prepare Defueled Safety Analysis Report (DSAR) $1,279 $5 $0 $0 $321 $1,605 LT-2-D-2.08 WD Implement Technical Specification Modifications $1,332 $5 $0 $0 $334 $1,671 LT-2-D-2.09 WD Prepare Post-Shutdown Emergency Preparedness Plan $634 $1 $0 $0 $159 $793 LT-2-D-2.10 WD NRC Review of Emergency Preparedness Plan $0 $0 $0 $105 $26 $131 LT-2-D-2.11 WD Prepare Post-Shutdown Decommissioning Activities Report (PSDAR) $550 $1 $0 $0 $138 $688 LT-2-D-2.12 WD NRC Review of Post-Shutdown Decommissioning Activities Report (PSDAR) $0 $0 $0 $105 $26 $131 LT-2-D-2.13 WD Respond to NRC questions on PSDAR $34 $1 $0 $0 $9 $43 LT-2-D-2.14 WD Prepare Decommissioning Cost Estimate (DCE) $1,429 $4 $0 $0 $358 $1,791 LT-2-D-2.15 WD NRC Review of Decommissioning Cost Estimate $0 $0 $0 $105 $26 $131 LT-2-D-2.16 WD Disposition of Legacy Wastes $0 $0 $16,457 $0 $4,114 $20,571 LT-2-D-2.17 WD Perform Historic Site Assessment and Site Characterization $6,784 $838 $0 $0 $1,143 $8,765 LT-2-D-2.18 WD Planning and Design For Cold and Dark $9,716 $90 $0 $0 $2,451 $12,257 LT-2-D-2.19 WD Implement Cold and Dark (Repower Site) $16,141 $17,860 $0 $0 $8,500 $42,501 LT-2-D-2.20 WD Install 12kV Service Line to Power Temporary Power Ring $0 $0 $0 $5,250 $1,313 $6,563 LT-2-D-2.21 WD Drain and De-Energize Non-Essential Systems (DEC Process) $822 $183 $1,485 $0 $623 $3,114 LT-2-D-2.22 WD Select Decommissioning General Contractor $645 $8 $0 $0 $163 $817 LT-2-D-2.23 WD Design Spent Fuel Pool Support System Modifications $622 $8 $0 $0 $157 $787 LT-2-D-2.24 WD Design Control Room Relocation $601 $7 $0 $0 $152 $760 LT-2-D-2.25 WD Design Spent Fuel Security System Modifications $459 $5 $0 $0 $116 $580 LT-2-D-2.26 WD Install Spent Fuel Pool System Modifications - Unit 2 $1,863 $4,101 $0 $0 $1,491 $7,456 LT-2-D-2.27 WD Install Spent Fuel Pool System Modifications - Unit 3 $1,863 $4,101 $0 $0 $1,491 $7,456 LT-2-D-2.28 WD Spent Fuel Pool System Modification Training $0 $0 $0 $273 $68 $341 LT-2-D-2.29 WD Implement Control Room Modifications $1,004 $1,519 $0 $0 $631 $3,153 LT-2-D-2.30 WD Implement Spent Fuel Pool Security Modifications $525 $795 $0 $0 $330 $1,650 LT-2-D-2.31 WD Transition Project Modifications $0 $0 $0 $105 $26 $131 Distributed Subtotal $48,154 $29,538 $17,942 $6,077 $24,665 $126,376 Undistributed LT-2-U-1.01 WD Utility Staff $56,478 $0 $0 $0 $14,119 $70,597 LT-2-U-1.02 WD Utility Staff HP Supplies $0 $1,781 $0 $0 $445 $2,226 LT-2-U-1.03 WD Security Guard Force $2,087 $0 $0 $0 $522 $2,609 LT-2-U-1.04 WD Security Related Expenses $77 $0 $0 $0 $19 $96 LT-2-U-1.05 WD Insurance $0 $0 $0 $4,446 $1,111 $5,557 Page 2 of 25

20 LT-2-U-1.06 WD Site Lease and Easement Expenses $0 $0 $0 $470 $70 $540 LT-2-U-1.07 WD NRC Decommissioning Fees $0 $0 $0 $2,390 $598 $2,988 LT-2-U-1.08 WD Materials and Services $0 $3,208 $0 $0 $802 $4,010 LT-2-U-1.09 WD DAW Disposal $0 $0 $295 $0 $74 $369 LT-2-U-1.10 WD Energy $0 $0 $0 $6,338 $1,584 $7,922 LT-2-U-1.13 WD Craft Worker Training $234 $0 $0 $0 $58 $292 LT-2-U-1.14 WD Workers Compensation Insurance $0 $0 $0 $283 $71 $353 LT-2-U-1.15 WD Community Outreach $1,638 $0 $0 $1,830 $867 $4,335 LT-2-U-1.16 WD Property Tax $0 $0 $0 $2,350 $588 $2,938 LT-2-U-1.17 WD Association Fees and Expenses $0 $2,350 $0 $0 $588 $2,938 LT-2-U-1.18 WD Utilities (Water, gas, phone) $0 $738 $0 $0 $185 $923 LT-2-U-1.20 WD Non-Process Computers $0 $157 $0 $0 $39 $196 LT-2-U-1.21 WD Telecommunications $0 $157 $0 $0 $39 $196 LT-2-U-1.24 WD Environmental Permits and Fees $0 $0 $0 $2,977 $744 $3,721 LT-2-U-1.25 WD Decommissioning Advisor $0 $0 $0 $1,567 $392 $1,958 Undistributed Subtotal $60,513 $8,391 $295 $22,650 $22,915 $114,764 Decon Pd 2 Subtotal $108,667 $37,928 $18,237 $28,727 $47,581 $241,140 Page 3 of 25

21 Decon Pd 3 Decommissioning Preparations and Reactor Internals Segmentation Distributed LT-3-D-3.01 WD Prepare Integrated Work Sequence and Schedule for Decommissioning $952 $0 $0 $0 $238 $1,190 LT-3-D-3.02 WD Prepare Detailed Work Procedures and Activity Specifications for Decommissioning $14,920 $70 $0 $0 $3,748 $18,738 LT-3-D-3.03 WD Planning and Design of Primary System Decontamination $516 $4 $0 $0 $130 $649 LT-3-D-3.04 WD Planning and Design Site Infrastructure Improvements $341 $4 $0 $0 $86 $431 LT-3-D-3.05 WD Design Containment Access Modifications $557 $6 $0 $0 $141 $705 LT-3-D-3.06 WD Primary System Decontamination - Unit 2 $1,447 $1,857 $2,228 $0 $1,383 $6,914 LT-3-D-3.07 WD Primary System Decontamination - Unit 3 $1,447 $1,857 $2,228 $0 $1,383 $6,914 LT-3-D-3.08 WD Hot Spot Decontamination - Unit 2 $580 $887 $743 $0 $552 $2,761 LT-3-D-3.09 WD Hot Spot Decontamination - Unit 3 $580 $913 $743 $0 $559 $2,794 LT-3-D-3.10 WD Modify Containment Access- Unit 2 $315 $611 $0 $0 $231 $1,157 LT-3-D-3.11 WD Modify Containment Access- Unit 3 $315 $611 $0 $0 $231 $1,157 LT-3-D-3.12 WD Remove and Dispose of Missile Shields - Unit 2 $206 $30 $81 $0 $79 $395 LT-3-D-3.13 WD Remove and Dispose of Reactor Head - Unit 2 $879 $453 $2,463 $0 $949 $4,744 LT-3-D-3.14 WD Remove and Dispose of Missile Shields - Unit 3 $437 $178 $3,375 $0 $997 $4,987 LT-3-D-3.15 WD Remove and Dispose of Reactor Head - Unit 3 $879 $453 $2,463 $0 $949 $4,744 LT-3-D-3.16 WD Finalize Residual Radiation Inventory $125 $0 $0 $287 $103 $516 LT-3-D-3.17 WD Prepare Activity Specifications $7,328 $696 $0 $0 $2,006 $10,031 LT-3-D-3.18 WD Select Shipping Casks and Obtain Shipping Permits $49 $0 $0 $0 $12 $62 LT-3-D-3.19 WD Design, Specify, and Procure Special Items and Materials $972 $5,379 $0 $0 $1,588 $7,938 LT-3-D-3.22 WD Test Special Cutting and Handling Equipment and Train Operators $1,157 $148 $0 $0 $326 $1,631 LT-3-D-3.23 WD Finalize Internals and Vessel Segmenting Details - Unit 2 $212 $16 $0 $0 $57 $284 LT-3-D-3.24 WD Segment, Package and Dispose of Reactor Internals - Unit 2 $5,669 $2,036 $62,661 $0 $17,591 $87,957 LT-3-D-3.25 WD Transfer Internals Segmentation Equipment to Unit 3 $131 $19 $0 $0 $37 $187 LT-3-D-3.26 WD Finalize Internals and Vessel Segmenting Details - Unit 3 $212 $16 $0 $0 $57 $284 LT-3-D-3.27 WD Segment, Package and Dispose of Reactor Internals - Unit 3 $5,669 $2,036 $62,661 $0 $17,591 $87,957 LT-3-D-3.28 WD Construct New Change Rooms, Hot Laundry, In-Plant Laydown Areas $0 $1,290 $0 $0 $194 $1,484 LT-3-D-3.29 WD Procure Non-Engineered Standard Equipment $0 $5,454 $0 $0 $1,364 $6,818 Distributed Subtotal $45,893 $25,024 $139,643 $287 $52,583 $263,431 Undistributed LT-3-U-1.01 WD Utility Staff $79,350 $0 $0 $0 $19,837 $99,187 LT-3-U-1.02 WD Utility Staff HP Supplies $0 $2,693 $0 $0 $673 $3,366 LT-3-U-1.03 WD Security Guard Force $5,484 $0 $0 $0 $1,371 $6,855 LT-3-U-1.04 WD Security Related Expenses $326 $0 $0 $0 $82 $408 LT-3-U-1.05 WD Insurance $0 $0 $0 $8,000 $2,000 $10,000 LT-3-U-1.06 WD Site Lease and Easement Expenses $0 $0 $0 $1,235 $185 $1,420 LT-3-U-1.07 WD NRC Decommissioning Fees $0 $0 $0 $6,281 $1,570 $7,851 LT-3-U-1.08 WD Materials and Services $0 $4,582 $0 $0 $1,145 $5,727 LT-3-U-1.09 WD DAW Disposal $0 $0 $424 $0 $106 $529 Page 4 of 25

22 LT-3-U-1.10 WD Energy $0 $0 $0 $10,226 $2,556 $12,782 LT-3-U-1.11 WD Decommissioning General Contractor Staff $62,219 $0 $0 $0 $15,555 $77,773 LT-3-U-1.12 WD DGC HP Supplies $0 $1,558 $0 $0 $389 $1,947 LT-3-U-1.13 WD Craft Worker Training $1,842 $0 $0 $0 $460 $2,302 LT-3-U-1.14 WD Workers Compensation Insurance $0 $0 $0 $742 $186 $928 LT-3-U-1.15 WD Community Outreach $4,303 $0 $0 $4,808 $2,278 $11,390 LT-3-U-1.16 WD Property Tax $0 $0 $0 $6,175 $1,544 $7,719 LT-3-U-1.17 WD Association Fees and Expenses $0 $6,175 $0 $0 $1,544 $7,719 LT-3-U-1.18 WD Utilities (Water, gas, phone) $0 $1,106 $0 $0 $277 $1,383 LT-3-U-1.19 WD Tools and Equipment $0 $182 $0 $0 $45 $227 LT-3-U-1.20 WD Non-Process Computers $0 $412 $0 $0 $103 $515 LT-3-U-1.21 WD Telecommunications $0 $412 $0 $0 $103 $515 LT-3-U-1.22 WD Personal Computers $0 $0 $0 $89 $22 $111 LT-3-U-1.24 WD Environmental Permits and Fees $0 $0 $0 $7,822 $1,955 $9,777 LT-3-U-1.25 WD Decommissioning Advisor $0 $0 $0 $4,117 $1,029 $5,146 Undistributed Subtotal $153,524 $17,119 $424 $49,495 $55,017 $275,579 Decon Pd 3 Subtotal $199,417 $42,144 $140,067 $49,782 $107,600 $539,009 Page 5 of 25

23 Decon Pd 4 Plant Systems and Large Component Removal Distributed LT-4-D-4.01 WD Upgrade Rail Spur $0 $0 $0 $3,277 $819 $4,096 LT-4-D-4.02 WD Install GARDIAN System $0 $0 $0 $525 $131 $656 LT-4-D-4.03 WD Scaffolding for Non-Essential System Removal $3,516 $1,144 $200 $0 $1,215 $6,075 LT-4-D-4.04 WD Asbestos Abatement and Hazardous Waste Disposal for Non-Essential Systems - Unit 2 $0 $0 $0 $1,050 $525 $1,575 LT-4-D-4.05 WD Lead Abatement for Non-Essential Systems Removal - Unit 2 $2,287 $23 $411 $0 $1,361 $4,082 LT-4-D-4.06 WD Remove, Package and Dispose of Non-Essential Systems - Unit 2 $33,512 $5,597 $31,969 $0 $17,769 $88,847 LT-4-D-4.07 WD Asbestos Abatement and Hazardous Waste Disposal for Non-Essential Systems - Unit 3 $0 $0 $0 $1,050 $525 $1,575 LT-4-D-4.08 WD Lead Abatement for Non-Essential Systems - Unit 3 $2,287 $399 $411 $0 $1,549 $4,647 LT-4-D-4.09 WD Remove, Package and Dispose of Non-Essential Systems - Unit 3 $36,851 $6,313 $36,610 $0 $19,944 $99,718 LT-4-D-4.10 WD Remove Underground Diesel Tank - Unit 2 $111 $45 $0 $41 $49 $247 LT-4-D-4.11 WD Remove Underground Diesel Tank - Unit 3 $111 $45 $0 $41 $49 $247 LT-4-D-4.12 WD Remove and Dispose of Spent Fuel Storage Racks - Unit 2 $42 $36 $4,922 $0 $1,250 $6,250 LT-4-D-4.13 WD Remove and Dispose of Spent Fuel Storage Racks - Unit 3 $42 $36 $4,922 $0 $1,250 $6,250 LT-4-D-4.14 WD Remove and Dispose of Legacy Class B and C Waste - Unit 2 $0 $0 $500 $0 $125 $625 LT-4-D-4.15 WD Remove and Dispose of Legacy Class B and C Waste - Unit 3 $0 $0 $500 $0 $125 $625 LT-4-D-4.16 WD Drain Spent Fuel Pool and Process Liquid Waste - Unit 2 $557 $703 $0 $0 $315 $1,575 LT-4-D-4.17 WD Drain Spent Fuel Pool and Process Liquid Waste - Unit 3 $557 $703 $0 $0 $315 $1,575 LT-4-D-4.18 WD Segment, Package and Dispose of Spent Fuel Pool Island Equipment $11 $2 $107 $0 $30 $150 LT-4-D-4.19 WD Segment and Dispose of Fuel Pool Bridge Crane - Unit 2 $85 $12 $168 $0 $66 $332 LT-4-D-4.20 WD Segment and Dispose of Fuel Pool Bridge Crane - Unit 3 $85 $12 $168 $0 $66 $332 LT-4-D-4.21 WD Flush and Drain Essential Systems Following Fuel Pool Closure $226 $181 $2,970 $0 $844 $4,221 LT-4-D-4.22 WD Scaffolding for Essential System Removal $989 $322 $56 $0 $342 $1,708 LT-4-D-4.23 WD Asbestos Abatement and Hazardous Waste Disposal for Essential Systems $0 $0 $0 $788 $394 $1,181 LT-4-D-4.24 WD Lead Abatement for Essential Systems Removal $332 $58 $59 $0 $225 $674 LT-4-D-4.25 WD Remove, Package and Dispose of Essential Systems $33,774 $5,869 $17,264 $0 $14,227 $71,134 LT-4-D-4.26 WD Removal and Disposal of Spent Resins, Filter Media and Tank Sludge $90 $40 $7,425 $0 $1,889 $9,445 LT-4-D-4.27 WD Reactor Vessel Insulation Removal and Disposal - Unit 2 $105 $12 $147 $0 $66 $331 LT-4-D-4.28 WD Segment, Package and Dispose of Reactor Pressure Vessel - Unit 2 $1,044 $2,834 $29,313 $0 $8,298 $41,489 LT-4-D-4.29 WD Transfer Rx Vessel Segmentation Equipment to Unit 3 $122 $18 $0 $0 $35 $175 LT-4-D-4.30 WD Procure Replacement Non-Engineered Standard Equipment $0 $454 $0 $0 $114 $568 LT-4-D-4.31 WD Reactor Vessel Insulation Removal and Disposal - Unit 3 $105 $12 $147 $0 $66 $331 LT-4-D-4.32 WD Segment, Package and Dispose of Reactor Pressure Vessel - Unit 3 $1,044 $2,834 $29,313 $0 $8,298 $41,489 LT-4-D-4.33 WD Remove and Dispose of Steam Generators - Unit 2 $2,789 $1,288 $18,154 $0 $5,558 $27,788 LT-4-D-4.34 WD Remove and Dispose of Pressurizer - Unit 2 $462 $70 $2,620 $0 $788 $3,940 LT-4-D-4.35 WD Remove and Dispose of Steam Generators - Unit 3 $2,789 $1,288 $18,154 $0 $5,558 $27,788 LT-4-D-4.36 WD Remove and Dispose of Pressurizer - Unit 3 $462 $70 $2,620 $0 $788 $3,940 LT-4-D-4.37 WD Remove and Dispose of Turbine Gantry Crane - Unit 2 $445 $229 $0 $4 $170 $848 Page 6 of 25

24 LT-4-D-4.38 WD Remove and Dispose of Turbine Gantry Crane - Unit 3 $445 $229 $0 $4 $170 $848 LT-4-D-4.39 WD Prepare License Termination Plan $1,646 $149 $0 $0 $449 $2,244 Distributed Subtotal $126,926 $31,029 $209,131 $6,779 $95,755 $469,620 Undistributed LT-4-U-1.01 WD Utility Staff $71,956 $0 $0 $0 $17,989 $89,945 LT-4-U-1.02 WD Utility Staff HP Supplies $0 $2,715 $0 $0 $679 $3,394 LT-4-U-1.03 WD Security Guard Force $4,638 $0 $0 $0 $1,159 $5,797 LT-4-U-1.04 WD Security Related Expenses $1,007 $0 $0 $0 $252 $1,259 LT-4-U-1.05 WD Insurance $0 $0 $0 $3,653 $913 $4,566 LT-4-U-1.06 WD Site Lease and Easement Expenses $0 $0 $0 $1,044 $157 $1,201 LT-4-U-1.07 WD NRC Decommissioning Fees $0 $0 $0 $5,312 $1,328 $6,639 LT-4-U-1.08 WD Materials and Services $0 $4,204 $0 $0 $1,051 $5,255 LT-4-U-1.09 WD DAW Disposal $0 $0 $1,568 $0 $392 $1,960 LT-4-U-1.10 WD Energy $0 $0 $0 $7,568 $1,892 $9,460 LT-4-U-1.11 WD Decommissioning General Contractor Staff $125,798 $0 $0 $0 $31,449 $157,247 LT-4-U-1.12 WD DGC HP Supplies $0 $5,834 $0 $0 $1,458 $7,292 LT-4-U-1.13 WD Craft Worker Training $7,788 $0 $0 $0 $1,947 $9,735 LT-4-U-1.14 WD Workers Compensation Insurance $0 $0 $0 $628 $157 $785 LT-4-U-1.15 WD Community Outreach $3,639 $0 $0 $4,066 $1,926 $9,632 LT-4-U-1.16 WD Property Tax $0 $0 $0 $5,222 $1,306 $6,528 LT-4-U-1.18 WD Utilities (Water, gas, phone) $0 $1,007 $0 $0 $252 $1,258 LT-4-U-1.19 WD Tools and Equipment $0 $423 $0 $0 $106 $529 LT-4-U-1.20 WD Non-Process Computers $0 $348 $0 $0 $87 $435 LT-4-U-1.21 WD Telecommunications $0 $348 $0 $0 $87 $435 LT-4-U-1.24 WD Environmental Permits and Fees $0 $0 $0 $6,615 $1,654 $8,268 LT-4-U-1.25 WD Decommissioning Advisor $0 $0 $0 $2,611 $653 $3,264 Undistributed Subtotal $214,826 $14,879 $1,568 $36,718 $66,893 $334,884 Decon Pd 4 Subtotal $341,752 $45,908 $210,699 $43,497 $162,649 $804,504 Page 7 of 25

25 Decon Pd 5 Building Decontamination Distributed LT-5-D-5.01 WD Decon Containment Building - Unit 3 $6,056 $3,318 $54,825 $0 $16,050 $80,249 LT-5-D-5.02 WD Decon Penetration Building - Unit 3 $1,065 $351 $2,933 $0 $1,087 $5,437 LT-5-D-5.03 WD Decon Safety Equipment and MSIV Building - Unit 3 $905 $390 $5,562 $0 $1,715 $8,573 LT-5-D-5.04 WD Decon Fuel Handling Building - Unit 3 $1,275 $577 $16,101 $0 $4,488 $22,442 LT-5-D-5.05 WD Decon Turbine Building - Unit 3 $100 $95 $3,925 $0 $1,030 $5,150 LT-5-D-5.06 WD Decon Containment Building - Unit 2 $6,056 $3,318 $54,825 $0 $16,050 $80,249 LT-5-D-5.07 WD Decon Penetration Building - Unit 2 $1,065 $351 $2,933 $0 $1,087 $5,437 LT-5-D-5.08 WD Decon Safety Equipment and MSIV Building - Unit 2 $911 $396 $5,777 $0 $1,771 $8,854 LT-5-D-5.09 WD Decon Fuel Handling Building - Unit 2 $1,275 $577 $16,101 $0 $4,488 $22,442 LT-5-D-5.10 WD Decon Turbine Building - Unit 2 $100 $95 $3,925 $0 $1,030 $5,150 LT-5-D-5.11 WD Decon Auxiliary Radwaste Building - Common $943 $691 $17,999 $0 $4,908 $24,541 LT-5-D-5.12 WD Decon Auxiliary Control Building - Common $198 $163 $38 $0 $100 $499 LT-5-D-5.13 WD Decon Condensate Area and Tunnels - Units 2 & 3 $375 $316 $403 $0 $274 $1,368 LT-5-D-5.14 WD Excavate, Remove and Dispose of Yard Area Drains $1,159 $128 $240 $0 $382 $1,908 LT-5-D-5.15 WD Remove and Dispose of Contaminated Sumps, Trenches and Pavement $185 $21 $746 $0 $238 $1,191 LT-5-D-5.16 WD Remove and Dispose of Radiologically Contaminated Soil $192 $216 $1,158 $0 $392 $1,958 LT-5-D-5.17 WD Segment, Package and Dispose of Contaminated Decon Equipment and Tooling $38 $6 $92 $0 $34 $170 LT-5-D-5.18 WD Radiological Survey of Structures During Decon $4,702 $3,666 $0 $0 $1,255 $9,623 Distributed Subtotal $26,600 $14,676 $187,585 $0 $56,379 $285,240 Undistributed LT-5-U-1.01 WD Utility Staff $29,516 $0 $0 $0 $7,379 $36,895 LT-5-U-1.02 WD Utility Staff HP Supplies $0 $997 $0 $0 $249 $1,247 LT-5-U-1.03 WD Security Guard Force $2,520 $0 $0 $0 $630 $3,150 LT-5-U-1.04 WD Security Related Expenses $560 $0 $0 $0 $140 $701 LT-5-U-1.05 WD Insurance $0 $0 $0 $1,985 $496 $2,481 LT-5-U-1.06 WD Site Lease and Easement Expenses $0 $0 $0 $567 $85 $652 LT-5-U-1.07 WD NRC Decommissioning Fees $0 $0 $0 $2,886 $722 $3,608 LT-5-U-1.08 WD Materials and Services $0 $1,668 $0 $0 $417 $2,086 LT-5-U-1.09 WD DAW Disposal $0 $0 $464 $0 $116 $580 LT-5-U-1.10 WD Energy $0 $0 $0 $2,336 $584 $2,920 LT-5-U-1.11 WD Decommissioning General Contractor Staff $56,286 $0 $0 $0 $14,071 $70,357 LT-5-U-1.12 WD DGC HP Supplies $0 $3,170 $0 $0 $792 $3,962 LT-5-U-1.13 WD Craft Worker Training $1,693 $0 $0 $0 $423 $2,116 LT-5-U-1.14 WD Workers Compensation Insurance $0 $0 $0 $341 $85 $426 LT-5-U-1.15 WD Community Outreach $862 $0 $0 $964 $457 $2,283 LT-5-U-1.16 WD Property Tax $0 $0 $0 $2,837 $709 $3,547 LT-5-U-1.18 WD Utilities (Water, gas, phone) $0 $413 $0 $0 $103 $517 LT-5-U-1.19 WD Tools and Equipment $0 $204 $0 $0 $51 $255 Page 8 of 25

26 LT-5-U-1.20 WD Non-Process Computers $0 $189 $0 $0 $47 $236 LT-5-U-1.21 WD Telecommunications $0 $189 $0 $0 $47 $236 LT-5-U-1.22 WD Personal Computers $0 $0 $0 $71 $18 $88 LT-5-U-1.24 WD Environmental Permits and Fees $0 $0 $0 $3,594 $899 $4,493 LT-5-U-1.25 WD Decommissioning Advisor $0 $0 $0 $825 $206 $1,031 Undistributed Subtotal $91,437 $6,832 $464 $16,406 $28,728 $143,866 Decon Pd 5 Subtotal $118,037 $21,508 $188,049 $16,406 $85,106 $429,106 Page 9 of 25

27 Decon Pd 6 License Termination During Demolition Distributed LT-6-D-6.01 WD Final Status Survey $9,613 $3,088 $0 $2,360 $2,259 $17,320 LT-6-D-6.02 WD Prepare Final Report of Dismantling Program $164 $4 $0 $0 $42 $210 Distributed Subtotal $9,777 $3,091 $0 $2,360 $2,301 $17,530 Undistributed LT-6-U-1.01 WD Utility Staff $1,378 $0 $0 $0 $345 $1,723 LT-6-U-1.04 WD Security Related Expenses $4 $0 $0 $0 $1 $5 LT-6-U-1.07 WD NRC Decommissioning Fees $0 $0 $0 $13,535 $3,384 $16,919 LT-6-U-1.08 WD Materials and Services $0 $47 $0 $0 $12 $58 LT-6-U-1.09 WD DAW Disposal $0 $0 $62 $0 $16 $78 LT-6-U-1.10 WD Energy $0 $0 $0 $1,872 $468 $2,340 LT-6-U-1.11 WD Decommissioning General Contractor Staff $651 $0 $0 $0 $163 $814 LT-6-U-1.12 WD DGC HP Supplies $0 $301 $0 $0 $75 $376 LT-6-U-1.15 WD Community Outreach $2,386 $0 $0 $2,666 $1,263 $6,315 LT-6-U-1.18 WD Utilities (Water, gas, phone) $0 $10 $0 $0 $3 $13 Undistributed Subtotal $4,420 $357 $62 $18,074 $5,728 $28,641 Decon Pd 6 Subtotal $14,197 $3,449 $62 $20,434 $8,029 $46,171 A. License Termination Subtotal $812,119 $150,936 $566,266 $171,959 $410,965 $2,112,246 Page 10 of 25

28 B. Spent Fuel SNF Pd 1 Spent Fuel Management Transition Distributed SFM-1-D-7.01 WD Security Shut Down Strategy $0 $0 $0 $8,388 $0 $8,388 SFM-1-D-7.02 WD Design and Fabricate Spent Fuel Canisters $0 $0 $0 $8,842 $0 $8,842 SFM-1-D-7.03 WD Post Fukushima Modifications - Unit 2 $0 $0 $0 $126 $0 $126 SFM-1-D-7.05 WD Cyber Security Modifications $0 $0 $0 $1,901 $0 $1,901 Distributed Subtotal $0 $0 $0 $19,258 $0 $19,258 Undistributed SFM-1-U-2.01 WD Utility Spent Fuel Staff $38,478 $0 $0 $0 $0 $38,478 SFM-1-U-2.04 WD Security Guard Force $69,889 $0 $0 $0 $0 $69,889 SFM-1-U-2.09 WD Emergency Preparedness Fees $0 $0 $0 $2,340 $0 $2,340 SFM-1-U-2.10 WD Spent Fuel Maintenance $0 $0 $0 $32 $0 $32 Undistributed Subtotal $108,367 $0 $0 $2,372 $0 $110,739 SNF Pd 1 Subtotal $108,367 $0 $0 $21,630 $0 $129,997 Page 11 of 25

29 SNF Pd 2 Spent Fuel Transfer to Dry Storage Distributed SFM-2-D-8.01 WD Security Shut Down Strategy $0 $0 $0 $2,855 $714 $3,569 SFM-2-D-8.02 WD Decay Heat Analysis $0 $0 $0 $105 $26 $131 SFM-2-D-8.03 WD Zirconium Fire/ Shine Analysis $0 $0 $0 $105 $26 $131 SFM-2-D-8.05 WD NRC Review of Irradiated Fuel Management Plan $0 $0 $0 $105 $26 $131 SFM-2-D-8.07 WD ISFSI Pad Study $0 $0 $0 $103 $26 $129 SFM-2-D-8.08 WD Design ISFSI Expansion $0 $0 $0 $3,150 $788 $3,938 SFM-2-D-8.09 WD Construct ISFSI Expansion $0 $0 $0 $33,600 $8,400 $42,000 SFM-2-D-8.10 WD Purchase and Fabrication of Spent Fuel Canisters and AHSMs - Unit 2 $0 $49,613 $0 $0 $12,403 $62,016 SFM-2-D-8.11 WD Purchase and Fabrication Spent Fuel Canisters and AHSMs - Unit 3 $0 $50,794 $0 $0 $12,698 $63,492 SFM-2-D-8.12 WD Deliver and Load Spent Fuel Canisters and Transfer to ISFSI - Unit 2 $71,338 $17,478 $0 $0 $22,204 $111,021 SFM-2-D-8.13 WD Deliver and Load Spent Fuel Canisters and Transfer to ISFSI - Unit 3 $73,037 $17,894 $0 $0 $22,733 $113,664 Distributed Subtotal $144,375 $135,779 $0 $40,023 $80,044 $400,221 Undistributed SFM-2-U-2.01 WD Utility Spent Fuel Staff $90,824 $0 $0 $0 $22,706 $113,530 SFM-2-U-2.02 WD Utility Staff HP Supplies $0 $6,590 $0 $0 $1,647 $8,237 SFM-2-U-2.04 WD Security Guard Force $112,313 $0 $0 $0 $28,078 $140,391 SFM-2-U-2.05 WD Security Related Expenses $1,334 $0 $0 $0 $333 $1,667 SFM-2-U-2.06 WD Insurance $0 $0 $0 $4,408 $1,102 $5,510 SFM-2-U-2.08 WD NRC Spent Fuel Fees $0 $0 $0 $1,107 $277 $1,383 SFM-2-U-2.09 WD Emergency Preparedness Fees $0 $0 $0 $18,756 $4,689 $23,445 SFM-2-U-2.10 WD Spent Fuel Maintenance $0 $0 $0 $2,131 $533 $2,664 SFM-2-U-2.11 WD Materials and Services $0 $5,848 $0 $0 $1,462 $7,310 SFM-2-U-2.12 WD DAW Disposal $0 $0 $275 $0 $69 $343 SFM-2-U-2.13 WD Energy $0 $0 $0 $3,991 $998 $4,989 SFM-2-U-2.15 WD Craft Worker Training $2,119 $0 $0 $0 $530 $2,649 SFM-2-U-2.18 WD Utilities (Water, gas, phone) $0 $3,572 $0 $0 $893 $4,465 SFM-2-U-2.22 WD Personal Computers $0 $0 $0 $14 $3 $17 Undistributed Subtotal $206,590 $16,010 $275 $30,406 $63,320 $316,601 SNF Pd 2 Subtotal $350,965 $151,789 $275 $70,429 $143,364 $716,822 Page 12 of 25