TURN explained that PG&E failed to provide a accounting for the Utility and DOC staff increase in its testimony. Moreover, TURN provided comprehensive critiques of PG&E’s attempt to justify these increases based on experiences at HBPP and other nuclear facilities. The Commission agreed with TURN’s arguments and found that PG&E failed to meet its burden of proof for $505 million in costs relating to both categories. In rejecting the case presented by PG&E, the Commission notes that the cost estimate comparisons provided by TURN for other nuclear facilities “are more convincing” than the justifications provided by PG&E. D.17-05-020, pages 38-41. 4. DCPP DCE / RIP AND SHIP TURN criticized PG&E’s assumed use of a “rip and ship” approach to demolishing all structures on the Diablo Canyon site. TURN argued that the expanded use of “rip and ship” in the current estimate should not be endorsed by the Commission. The Commission noted that TURN’s concerns regarding the “rip and ship” assumption were endorsed in the 2012 NDCTP and affirmed that “The Commission continues to share these concerns.” The Testimony of Bruce Lacy (Ex. 33), page 25. TURN opening brief, pages 36-37. TURN opening comments on Proposed Decision, page 1. D.17-05-020, page 68. Verified
TURN’s request also includes 11 hours devoted to the preparation of compensation-related filings. The time devoted to this compensation request is appropriate and should be found to be reasonable. c. Allocation of hours by issue: TURN has allocated all of our attorney and consultant time by issue area or activity, as evident on our attached timesheets. The following codes relate to specific substantive issue and activity areas addressed by TURN. TURN also provides an approximate breakdown of the number of hours spent on each task and the percentage of total hours devoted to each category. GP – 45 hours – 12% of total General Participation work essential to participation that typically spans multiple issues and/or would not vary with the number of issues that TURN addresses. This includes reviewing the initial applications and Commission rulings, initial review of utility filings and motions, reviewing responses to data requests submitted by other parties, reviewing pleadings submitted by other parties and review of the proposed decision. Includes time spent at Prehearing Conferences, workshops, and other events during the course of the proceeding. Also includes work coordinating with other parties. EH – 31 hours – 8% of total Evidentiary hearing work relating to participation in evidentiary hearings includes time preparing cross-examination for hearings, attending hearings, and reviewing hearing transcripts. DCPP – 179 hours – 46% of total Work analyzing the revised Diablo Canyon decommissioning cost estimate, reviewing supporting materials, assessing factors that may reduce the overall cost to ratepayers, analyzing applicable federal requirements, developing recommendations relating to potential reductions in cost, and providing a comprehensive summary of cost issues for testimony and briefs. HBPP – 40.5 hours – 10% of total Work analyzing the reasonableness of completed decommissioning projects at the Humboldt Bay Nuclear Plant and the “cost to complete” estimate for remaining work. SNF – 71 hours – 18% of total Work on assessing appropriate cooling periods for wet fuel along with the appropriate treatment (and reporting on) of future Verified