Investigation No.: 1-10-01 Exhibit No.: SCE- Witnesses: Doug Bauder Rick Fisher (U 8-E) Errata to SCE-6: Testimony of Southern California Edison Company Responding to Certain Issues Identified in July 1, 01 ALJ Ruling Before the Public Utilities Commission of the State of California Rosemead, California July 1, 01
1 5 6 7 8 9 II. FERC ACCOUNTING FOR SONGS ASSETS This Chapter explains why SCE cannot accommodate the ALJ Ruling and explains the FERC accounting that SCE uses for SONGS fixed assets. SCE is unable to directly assign the net-investment dollars recorded on SCE s ledgers to the categories listed in Attachment 1 of the ALJ Ruling, because SCE maintains its plant and depreciation ledger consistent with FERC Uniform System of Accounts (USoA), which requires that SCE maintain its fixed asset records by FERC plant account. This accounting groups assets by type, not by system, which are comprised of many different types of assets. Table II-1 lists the Nuclear FERC plant accounts and account titles: Table II-1 Nuclear Production FERC Plant Accounts Account Title 0 Land and land rights 1 Structures and improvments Reactor plant equipment Turbogenerator units Accessory electric equipment 5 Miscellaneous power plant equipment 10 11 1 In addition, SCE maintains its plant balances by retirement unit, a lower level of detail, but still by type of asset, not system. Plant account, Reactor Plant Equipment, includes over 60 different retirement units. Table II- shows a small sample of the retirement units in plant account. 18 CFR 101. Retirement units means those items of electric plant which, when retired, with or without replacement, are accounted for by crediting the book cost thereof to the electric plant account in which included 18 CFR 101, Definitions.
Table II- Sample of Retirement Units for Account, Reactor Plant Equipment Account Retirement Unit 100 STEAM GENERATOR 101 PRESSURIZER 110 REACTOR VESSEL 115 INTERNAL SYSTEM, REACTOR VESSEL 10 CONTROL ROD DRIVE SYSTEM 01 VALVES, TWO INCHES AND LARGER 00 MOTORS, 0 HORSEPOWER AND LARGER 05 TANKS, 0,000 GALLONS AND LARGER 05 FANS, 0 HORSEPOWER AND LARGER 08 FOUNDATIONS, MISCELLANEOUS 00 SUMPS, 0,000 GALLONS AND LARGER 05 STORAGE RACKS, SPENT FUEL 1 5 6 7 8 9 Referring to these retirement unit categories, SCE is able to identify plant balances that will no longer be needed in operation, such as Retirement Unit 100, Steam Generator, and plant balances that will continue to be needed, such as Retirement Unit 05, Storage Racks, Spent Fuel (not shown). Other retirement units, however, identify components that are generic and in use throughout various systems at SONGS, such as Retirement Unit 01, Valves, Two Inches and Larger. These generic assets cannot be assigned directly to particular systems or system components, as outlined on Attachment 1 of the ALJ Ruling. SCE used the retirement unit categories in the analysis discussed in the next Chapter to determine the amount of SONGS capital assets that will continued to be used.
1 5 6 7 8 9 10 11 IV. SONGS NET INVESTMENT This Chapter will summarize the total balances and the portions that SCE has determined to be required during SONGS permanent retirement. SCE s net investment for SONGS fixed assets is $1.1 billion as of May 1, 01. This total represents a summation of accounting information for plant-in-service (plant), which is the cumulative balance of the original cost of construction and installation, offset by accumulated depreciation, which is the cumulative balance of depreciation expense charged in rates. These totals are presented in Appendix E, conforming to the format of Attachment of the ALJ Ruling. The net investment at October 1, 01 and May 1, 01 15 as well as the amounts determined to continue to be needed is provided in Table IV-5. Category 5/1/01 Table IV-5 Net Investment Summary (SCE Share) Plant Accumulated Depreciation Net In ve stm e n t Allocation NI Required Not Required 1,00 06 7 0% Staff Level 7 57 16 9% 6 Plant Condition,078,70 76 0% 150 Still Required 98 81 1 100% 1 Total 5,119,878 1,0 % 81 10/1/01 Category Plant Accumulated Dep reciation Net In ve stm e n t Allocation NI Required Not Required Staff Level Plant Condition Still Required 5,190,81 1,50 100% 1,50 Total 5,190,81 1,50 100% 1,50 15 SCE is providing in Tables IV-5 and IV-6 the amount of assets as of October 1, 01 and May 1, 01 for illustrative purposes only, and not for the purpose of identifying the dates the Commission should use for removing certain amounts from rate base. For the reasons explained in this testimony, the Commission should not remove amounts from rate base for any period prior to when Unit has been defueled, systems laid up, and SONGS initial staffing reductions implemented. 1
1 5 6 7 8 9 10 11 1 1 1 15 16 17 18 19 0 1 5 6 7 Not included in the balances above are the net investment for Construction Work In Progress (CWIP), Marine Mitigation, Design Basis Documentation (DBD) and Deferred Debits (DD), Materials and Supplies (M&S), and Nuclear Fuel Inventory. SCE had a CWIP balance of $8 million as of October 1, 01, of which all was used and useful. The balance of CWIP as of May 1, 01, totaled $69 million, of which SCE has determined that $110 million continues to be needed for permanent retirement. SCE utilized an approach similar to that described in Chapter III for identifying what portion of CWIP will be still required with the retirement of SONGS. The ratemaking associated with these values will be submitted in SCE s August, 01 testimony. Marine Mitigation represents costs incurred to fulfill CCC requirements, including, among other things, constructing the reef and wetlands. The net balance of Marine Mitigation costs is $6 million as of October 1, 01 and May 1, 01. Nuclear DBD and DD for SONGS are regulatory assets recorded for FERC Account 18., Unrecovered Plant and Regulatory Study Costs. Although not specifically classified as Plant-In-Service, the recorded costs are included in rate base and depreciated. Nuclear DBD Study Costs represent expenditures required by the NRC to establish the nuclear design documentation system. Nuclear DD are plant-related regulatory assets that resolve accounting differences in capitalization policies between CPUC and FERC jurisdictions regarding the commercial operating dates of the units. The net balance of Nuclear DBD and DD costs was $ million as of October 1, 01 and May 1, 01. M&S includes such things as replacement repair parts and equipment used in the plant that are not currently included in capital assets. SCE had a balance of costs in M&S of $99 million (SCE Share) as of October 1, 01 and $100 million (SCE Share) as of May 1, 01. Nuclear fuel includes in-core and pre-core inventories. SCE had a balance of costs in nuclear fuel of $66 million (SCE Share) as of October 1, 01 and $71 million (SCE Share) as of May 1, 01. The ratemaking associated with these cost categories will be submitted in SCE s August, 01 testimony. Table IV-6 summarizes all of these balances. 1
Table IV-6 Total Net Investment by Category (SCE Share) Total N et Investment R equired N et Investment Category 10/1/1 05/1/1 10/1/1 05/1/1 Fixed Asset Net Investment 1,50 1,1 1,50 81 CW IP 8 69 8 110 Marine Mitigation 6 6 6 6 Nuclear DBD & DD M a te ria ls & S up p lie s 9 9 100 99 100 N uclear Fuel 66 71 66 71 Total,09,10,09 1,011 1
1 5 6 7 8 9 10 11 1 1 1 15 16 17 V. FORECAST OF REDUCED EMPLOYEE HEADCOUNT AT SONGS Based on SCE s announcement on June 7, 01, to permanently retire SONGS &, SONGS staffing levels 16 will be reduced to 575 employees by September, 01. 17 The reduction to 575 employees is possible because many of the functions that were required to support SONGS & operations are no longer required. SCE developed the SONGS permanent retirement staffing level of 575 by analyzing a combination of (1) staffing plans of other nuclear facilities that are decommissioning, and () the work required in a permanent retirement state. SCE then made adjustments to account for differences between those facilities and SONGS. For example, the sites SCE analyzed are each single unit sites, therefore it was necessary to adjust for two units. Another difference at SONGS is Security, which comprises approximately 50% of the SONGS retirement staff. The large Security staffing level is required because of the compact physical layout of the SONGS site, the close proximity to both the beach and public roads, as well as the need to meet applicable federal regulations. This organization is based upon NRC acceptance of 10 CFR 50.8 defueled certification and completion of required 10 CFR 50.5(q) Emergency Plan changes. Table V-7 below provides staffing by division. 16 No SCE Corporate positions that directly support SONGS are included in the 575 (e.g., Finance, Human Resources, and Communications). These positions are also being reduced to reflect SONGS permanent retirement. 17 SCE plans to further reduce staffing in 01 to 00 employees. 15
Table V-7 SONGS Staffing as of September 01 Site Management & Administration 9 Operations 71 Radiation Protection & Chemistry Maintenance & Work Control 65 Safety, Human Performance, PI 1 Oversight & Nuclear Safety Concerns 7 Initial Decommissioning Plan 1 Regulatory & Emergency Planning 16 Engineering 9 Security 00 Total 575 1 SCE is not providing any non-labor O&M expense testimony as the analysis is currently in development. SCE reserves the right to submit testimony at a later date. 16
Appendix E Net Investments
Southern California Edison San Onofre Nuclear Generating Station Net Investment by Unit & Common as of October 1, 01 ($, SCE Share) DEPRECIATION DEPRECIABLE AVG GROSS PLANT EST. FUTURE NET SALVAGE RESERVE BALANCE SERV REM LIFE ANNUAL October 1, 01 % AMOUNT October 1, 01 October 1, 01 CURVE LIFE / RATE ACCRUAL UNIT 0 Easements - 0.0% - - - License 9.1-1 Structures & Improvements 5,8,55 0.0% - 6,89, 8,959,90 License 9.1 986, Reactor Plant Equipment 1,178,66,788 0.0% - 687,711,9 90,65,8 License 9.0 5,517,05 Turbogenerator Units 01,11,09 0.0% - 6,10,700 7,98,9 License 8. 8,908,79 Accessory Electric Equipment 18,95,5 0.0% - 80,05,988 8,9,65 License 9.1,10,950 5 Misc. Power Plant Equipment 8,60,1 0.0% -,88,696,76,8 License 8.5 560,5 x COR/RWIP - 0.0% (9,8,08) 9,8,08-5X GRT 8,509,08-7.1% (600,78) 7,885,050 1,,76 Various.8% 1,657 9X General / Intangibles,1 0.0% - (151,10) 185, Various 8.%,81 Total Fixed Assets,190,70,190 (600,78) 1,56,61,09 68,58,8 69,8,8 18 Nuclear DBD & DD 15,70,7 0.0% - 1,6,56.5 1,079,980 License 9.1 118,897 18 Marine Mitigation - 0.0% - - - 9.1 - Total Deferred Debits 15,70,7-1,6,57 1,079,980 118,897 Total Unit,06,07,57 (600,78) 1,577,,51 69,8,81 69,57,180 UNIT 0 Easements - 0.0% - - - License 9.1-1 Structures & Improvements 1,9,6 0.0% - 00,11,1 1,18,1 License 9.1 1,51,5 Reactor Plant Equipment 981,19,95 0.0% - 668,08, 1,11,071 License 9.0,801,0 Turbogenerator Units,557,67 0.0% - 08,5,6,1,00 License 8.,05,10 Accessory Electric Equipment 69,086,000 0.0% -,876,16 6,09,87 License 9.1,986,0 5 Misc. Power Plant Equipment 1,180,15 0.0% - 0,701,68 10,78,87 License 8.5 1,,76 x COR/RWIP - 0.0% (,95,9),95,9-5X GRT 7,856,81-7.1% (55,660) 7,79,8 1,11,80 Various.8%,11 9X General / Intangibles 170,86 0.0% - (100,) 70,709 Various 8.% 1,998 Total Fixed Assets 1,855,56,91 (55,660) 1,,559,99 1,559,10 5,76,87 18 Design Basis Documentation (DBD) 15,96,05 0.0% - 1,, 1,05,86 License 9.1 116,0 Marine Mitigation - 0.0% - - - 9.1 - Total Deferred Debits 15,96,05-1,, 1,05,86 116,0 Total Unit 1,870,860,596 (55,660) 1,57,80,91 1,61,965 5,878,89 COMMON 0 Easements 1,10,058 0.0% - 59,706 511,5 License 9.1 56,96 1 Structures & Improvements 556,701,8 0.0% -,907,715 1,79,768 License 9.1 1,518,580 Reactor Plant Equipment 170,71,967 0.0% - 18,58,60,6,7 License 9.0,707,09 Turbogenerator Units 11,185,557 0.0% - 8,67,06,558,95 License 8. 0,980 Accessory Electric Equipment 1,96,8 0.0% - 1,1,51 10,06,771 License 9.1 1,108,08 5 Misc. Power Plant Equipment 181,,87 0.0% - 176,889,8,,050 License 8.5 51,65 x COR/RWIP - 0.0% 16,859,9 (16,859,9) - 5X GRT 0,06,8-7.1% (,119,895) 15,65,657 16,501,079 Various.8% 85,76 9X General / Intangibles 9,870,009 0.0% -,96,8 5,9,781 Various 8.%,099,15 Total Fixed Assets 1,1,0,071 (,119,895) 98,159,56 08,90,710 5,167,67 18 Deferred Debits,1,50 0.0% - 1,11,51 1,010,51 License 9.1 111,0 18 Marine Mitigation 6,890,71 0.0% - 16,67,59 6,,119 9.1 5,090,986 Total Deferred Debits 65,01,1-17,759,8 7,5,70 5,0,06 Total 1,09,,85 (,119,895) 955,919,100 55,5,080 0,69,878 TOTAL SONGS 0 Easements 1,10,058 0.0% - 59,706 511,5 License 9.1 56,96 1 Structures & Improvements 1,05,,60 0.0% - 1,060,509,70 1,95,70 License 9.1 15,956,177 Reactor Plant Equipment,0,508,09 0.0% - 1,8,78,786 86,9,6 License 9.0 9,05,7 Turbogenerator Units 55,856,58 0.0% -,19,9 111,66,86 License 8. 1,66,875 Accessory Electric Equipment 70,777,77 0.0% - 66,5,66 8,5,07 License 9.1 9,05,0 5 Misc. Power Plant Equipment 71,107,11 0.0% - 51,0,157 19,676,985 License 8.5,1,99 COR/RWIP - 0.0%,568,68 (,568,68) - 5X GRT 6,9,60-7.1% (,75,9) 0,809,95 18,857,608 Various.8% 1,17,50 9X General / Intangibles 50,07,508 0.0% -,69,596 6,79,91 Various 8.%,116,15 Total SONGS Production 5,190,6,65 (,75,9),9,1,00 1,9,08,66 10,58,88 18 Design Basis Documentation (DBD),11,0 0.0% - 9,976,99,1,09 License 9.1 6,19 Marine Mitigation 6,890,71 0.0% - 16,67,59 6,,119 9.1 5,090,986 Total SONGS DBD & Debit 96,011,755-6,6,5 9,87,1 5,7,1 Total SONGS 5,86,76,07 (,75,9),990,955,8 1,98,595,859 15,795,95 107 Construction Work In Progress 8,0,55 - - 8,0,55 15 Materials & Supplies 99,59,05 - - 99,59,05 10 Nuclear Fuel 66,09,8 - - 66,09,8 Total SONGS Investment 6,079,66,70,091,98,7 E-1
Southern California Edison San Onofre Nuclear Generating Station Net Investment by Unit & Common as of May 1, 01 ($, SCE Share) DEPRECIATION DEPRECIABLE AVG GROSS PLANT EST. FUTURE NET SALVAGE RESERVE BALANCE SERV REM LIFE ANNUAL May 1, 01 % AMOUNT May 1, 01 May 1, 01 CURVE LIFE / RATE ACCRUAL UNIT 0 Easements - 0.0% - - - License 9.1-1 Structures & Improvements 5,87,115 0.0% - 0,75,16 1,651,978 License 9.1 1,61,06 Reactor Plant Equipment 1,15,86,15 0.0% - 707,05,101 6,1,0 License 9.0 9,60,7 Turbogenerator Units 90,5,01 0.0% - 1,69,98 77,60,086 License 8. 9,,565 Accessory Electric Equipment 0,109,795 0.0% - 81,510, 8,599,71 License 9.1,9,7 5 Misc. Power Plant Equipment 51,057,796 0.0% -,508,69 6,59,7 License 8.5 770,509 x COR/RWIP - 0.0% (19,0,85) 19,0,85-5X GRT 8,18, -7.1% (57,57) 7,60,99 1,07,08 Various.8% 86,56, 9X General / Intangibles,1 0.0% - (150,59) 18,57 Various 8.% 16, Total Fixed Assets,158,898,8 (57,57) 1,555,11,6 60,1,79 5,1,501 18 Nuclear DBD & DD 15,70,7 0.0% - 1,686,971 1,015,66 License 9.1 111,78 18 Marine Mitigation - 0.0% - - - 9.1 - Total Deferred Debits 15,70,7-1,686,971 1,015,66 111,78 Total Unit,17,600,818 (57,57) 1,569,88, 605,7,158 5,55,8 UNIT 0 Easements - 0.0% - - - License 9.1-1 Structures & Improvements 1,17,1 0.0% - 9,008,7 19,09,166 License 9.1,11,771 Reactor Plant Equipment 91,55,55 0.0% - 60,98,69 7,597,176 License 9.0 6,99,686 Turbogenerator Units,9,55 0.0% - 09,568,,76,1 License 8.,007,075 Accessory Electric Equipment 7,19,7 0.0% -,598,1 8,595,159 License 9.1,9,008 5 Misc. Power Plant Equipment 0,890,571 0.0% -,575,77 7,1,8 License 8.5 860,570 x COR/RWIP - 0.0% (,897,51),897,51-5X GRT 7,856,81-7.1% (55,660) 7,61,68 1,09,9 Various.8% 76,6,1 9X General / Intangibles 170,86 0.0% - (98,51) 68,87 Various 8.%,071,605 Total Fixed Assets 1,809,168,8 (55,660) 1,79,06,617 0,658,91 6,5,88 18 Nuclear DBD & DD 15,96,05 0.0% - 1,05,9 990,811 License 9.1 109,080 18 Marine Mitigation - 0.0% - - - 9.1 - Total Deferred Debits 15,96,05-1,05,9 990,811 109,080 Total Unit 1,8,6,5 (55,660) 1,9,70,011 1,69,10 6,,918 COMMON 0 Easements 1,10,058 0.0% - 6,09 80,69 License 9.1 5,916 1 Structures & Improvements 559,8, 0.0% - 5,07,819 10,876,1 License 9.1 11,56,07 Reactor Plant Equipment 17,79,65 0.0% - 10,97,7 70,819,91 License 9.0 7,868,880 Turbogenerator Units 11,8,571 0.0% - 11,659,8 (175,757) License 8. (0,88) Accessory Electric Equipment 1,887,00 0.0% - 1,518,80 10,68,6 License 9.1 1,11,56 5 Misc. Power Plant Equipment 180,59,916 0.0% - 17,781,198 6,81,718 License 8.5 801,61 x COR/RWIP - 0.0% 16,976,79 (16,976,79) - 5X GRT 8,89,50-7.1% (,09,881) 1,67,89 16,60,55 Various.8% 1,017,76,86 9X General / Intangibles 50,91,77 0.0% - 8,90,6 1,97,90 Various 8.% 619,88,57 Total Fixed Assets 1,150,955,69 (,09,881) 98,555,06 1,0,68 1,658,155,00 18 Nuclear DBD & DD,1,50 0.0% - 1,17,69 99,809 License 9.1 10,566 18 Marine Mitigation 65,0,670 0.0% - 19,675,56 5,75,107 9.1 5,06,159 Total Deferred Debits 67,5,17-0,88,56 6,69,916 5,10,75 Total 1,18,98,86 (,09,881) 959,0,56 61,15,18 1,66,96,1 TOTAL SONGS 0 Easements 1,10,058 0.0% - 6,09 80,69 License 9.1 5,916 1 Structures & Improvements 1,07,888,788 0.0% - 1,069,151,0 18,77,559 License 9.1 15,7,860 Reactor Plant Equipment,59,176,1 0.0% - 1,1,8,19 8,88,11 License 9.0 9,87,01 Turbogenerator Units 55,11,18 0.0% -,9,598 111,190,50 License 8. 1,10,757 Accessory Electric Equipment 77,190,97 0.0% - 69,67,50 87,56,757 License 9.1 9,69,97 5 Misc. Power Plant Equipment 7,5,8 0.0% - 51,865,9 0,677,890 License 8.5,,69 x COR/RWIP - 0.0% (5,1,170) 5,1,170-5X GRT,888,08-7.1% (,169,115) 9,675,7 18,81,975 Various.8% 1,580,57,09 9X General / Intangibles 51,118,6 0.0% - 8,691,57,6,690 Various 8.% 61,876,5 Total SONGS Production 5,119,0, (,169,115),87,761,186 1,9,0,50,6,9,79 18 Nuclear DBD & DD,11,0 0.0% - 0,165,057,955,986 License 9.1 5,0 18 Marine Mitigation 65,0,670 0.0% - 19,675,56 5,75,107 9.1 5,06,159 Total Deferred Debits 98,51,71-9,80,60 8,701,09 5,61,588 Total SONGS 5,17,56,15 (,169,115),9,601,806 1,98,11,,,9,7 107 Construction Work In Progress 68,518,008 - - 68,518,008 15 Materials & Supplies 100,5,668 - - 100,5,668 10 Nuclear Fuel 71,077,55 - - 71,077,55 Total SONGS Investment 6,057,85,066,17,95,75 E-