THE OFFICE OF REGULATORY STAFF DIRECT TESTIMONY & EXHIBITS OF GARY C. JONES, P.E. AUGUST 9, 2012 ITA DOCKET NO: 2012-203-E Petition of South Carolina Electric & Gas Company for Updates and Revisions to Schedules Related to the Construction of a Nuclear Base Load Generation Facility at Jenkinsville, South Carolina (Redacted) Direct Testimony of 0aiy C. Jones, P.E. August 9, 2012 Docket No. 2012-203-E (Redacted) South Carolina Electric & Gas Company Page 1 1 DIRECT TESTIMONY & EXIHBITS OF 2 GARY C. JONES, P.E. 3 ON BEHALF OF 4 THE SOUTH CAROLINA OFFICE OF REGULATORY STAFF 5 DOCKET NO: 2012-203-E 6 IN RE: PETITION OF SOUTH CAROLINA ELECTRIC & GAS COMPANY FOR 7 UPDATES AND REVISIONS TO SCHEDULES RELATED TO TIlE CONSTRUCTION S OF A NUCLEAR BASE LOAD GENERATION FACILITY AT 9 JENKINSVILLE, SOUTH CAROLINA 10 11 Q. 12 A. PLEASE STATE YOUR NAME, TITLE AND BUSINESS ADDRESS. My name is Gary C. Jones, P.E. I am President of Jones Partners, Ltd., a private 13 consulting engineering firm in the electrical power generation field. My business address is 14 1222 West George Street, Chicago, Illinois, 60657-4220. 15 Q. 16 A. WHAT IS THE NATURE OF YOUR BUSINESS? As a private consultant, I provide professional engineering and consulting services to clients in the electric power industry. 17 18 Q. 19 A. PLEASE STATE YOUR EDUCATIONAL BACKGROUND AND EXPERIENCE. I received a Bachelor of Science degree in Engineering Science from Tennessee 20 Technological University in Cookeville, Tennessee, where I also participated in the Co 21 Operative Education Program with two one-year assignments at the Oak Ridge National 22 Laboratory in Oak Ridge, Tennessee. I worked for thirty-two years at Sargent & Lundy, 23 LLC, (“S&L”) an international architect-engineering and consulting engineering firm in the THE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, Sc 29201 Direct Testimony of Gary C. Jones, P.E. August 9, 2012 Docket No. 2012-203-E (Redacted) South Carolina Electric & Gas Company Page 2 I electric power industry based in Chicago, illinois. I held engineering positions of 2 increasing levels of responsibility working on the design, procurement, licensing, 3 construction support and start-up of nuclear power plant projects, culminating in the 4 position as Senior Vice President and one of the owners of the firm for the last sixteen 5 years of my tenure. lied the engineering activities associated with the design of six nuclear 6 power plants at three nuclear power plant stations, including the LaSalle County and 7 Braidwood plants for Commonwealth Edison (now Exelon) and the Marble Hill station for 8 Public Service Indiana. I also led the engineering activities associated with the restarts of 9 the LaSalle County Station Units I and 2 and the D.C. Cook Plant after these plants were 10 shut down due to operation concerns. I served for two years as head of the Mechanical 11 Department at S&L I also led the engineering activities associated with services to 12 numerous operating nuclear power plants, including modifications, technical and economic 13 studies, licensing support, procedure and process development and other consulting 14 services. 15 Among the most significant assignments on international projects were leading the 16 design review of the first indigenous Chinese nuclear power plant, Qin Shan Unit 1, and 17 participating as a senior member in the design review of the Korean nuclear power plants 18 Yonggwang Units 3 and 4, 19 Upon my retirement from S&L, I established a private consulting practice, Jones 20 Partners, Ltd., where I continued working in the nuclear power industry for two and a half 21 years until I accepted a position at the International Atomic Energy Agency (“IAEA”) in 22 Vienna, Austria. There I was a Senior Engineering Safety Officer in the Engineering Safety 23 Section of the Department of Nuclear Safety and Security. My assignments included THE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC 29201 Direct Testimony of Gary C. Jones, P.E. August 9, 2012 Docket No. 2012-203..E (Redacted) South Carolina Electric & Gas Company Page 3 1 developing international safety standards and performing safety reviews of nuclear power 2 plants. My most significant assignment was leading the safety review of the fifteen 3 operating nuclear power plants in the Ukraine. 4 Following the completion of my assignment at the IAEA, I returned to private 5 practice as a consultant to the power industry and continue that work today. 6 licensed professional engineer in the States of Missouri and South Carolina. Additional 7 details of my work experience are provided in my resume which I have included as Exhibit 8 GCJ-l, 9 Q. 10 11 I am a HAVE YOU PREVIOUSLY TESTIFIED BEFORE THE PUBLIC SERVICE COMMISSION OF SOUTH CAROLINA (“COMMISSION”)? A. 12 No. However, I have supplied testimony in various licensing, litigation and arbitration proceedings in other venues. 13 Q. 14 A. WHAT IS YOUR ASSIGNMENT IN THIS PROCEEDING? My assignment is to assist the South Carolina Office of Regulatory Staff (“ORS”) 15 in its monitoring and tracking of the construction schedule and budget related to South 16 Carolina Electric & Gas Company’s (“SCE&G” or the “Company”) V. C. Summer Units 2 17 & 3 (the “Units” or the “Project”). I began my assigrunent with ORS in August 2011. 18 Q. 19 A. WHAT IS THE PURPOSE OF YOUR TESTIMONY IN THIS PROCEEDING? The purpose of my testimony is to provide on behalf of ORS a technical review of 20 specific areas in SCE&G’s request for updates and revisions to its capital cost schedule and 21 construction schedule for the Units as delineated in their petition under Docket No. 2012.. 22 203-E (“Petition”). The specific areas which I will address are: TIlE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC 29201 Direct Testimony of Gary C. Jones, PE August 9, 2012 1 • 2 Docket No. 2012-203..E (Redacted) South Carolina Electric & Gas Company Page 4 The construction schedule, including the Base Load Review Act (“BLRA”) milestones; 3 • The Engineering, Procurement and Construction Contract (“EPC Contract”) 4 cost changes, excluding the Waste Water Discharge Piping and Health Care 5 Costs Change Orders; and, 6 • 7 The Owners Cost changes. Other areas of cost changes included in this Petition will be addressed in the 8 testimony of ORS witness Powell. 9 Q. 10 A. PLEASE DESCRIBE SCE&G’S REQUEST. SCE&G has filed this update to revise the construction schedules and capital cost 11 schedules approved through Commission Order No. 2011-345, and to supersede and 12 replace the petition filed on February 29, 2012 in Docket No. 2012-90-B. The primary 13 reasons for filing this Petition are: 14 • To change the construction schedule, including the Substantial Completion 15 Dates for the Units, which reflect the delay incurred due to the timing of 16 receiving the Combined Construction and Operating License (“COL”) and other 17 delays associated with construction; 18 • To change the costs of the Units to reflect changes in the EPC Contract amount; 19 • To change the costs of the Units to reflect changes in the Owners Cost; and, 20 • To change costs of the Units to reflect changes to the transmission tine costs. 21 The implications of these changes result in a delay of the Substantial Completion 22 Date of Unit 2 by 11 /z months to March 15, 2017 and the acceleration of the Substantial TUE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC Z9201 Direct Testimony of Gary C. Jones, P.E. August 9, 2012 Docket No. 2012-203-E (Redacted) South Carolina Electric & Gas Company Page 5 I Completion Date of Unit 3 by 7½ months to May 15, 2018 from those dates previously 2 approved by the Commission of April 1, 2016 and January 1, 2019, respectively. This also 3 results in changes to many of the approved BLRA milestone dates. However, SCE&G 4 indicates that the delay of Unit 2 will not significantly affect the generating capacity during 5 the anticipated peak load in the summer of 2016 and the acceleration of Unit 3 results in 6 cost savings that partially offset the cost increases associated with the delay in the 7 completion date of Unit 2. 8 With regard to costs, the capital costs in 2007 dollars will increase by $283.0 9 million, increasing the overall capital cost in 2007 dollars specified in Commission Order 10 No. 20 11-345 from $4.270 to $4.553 billion. However, the updated cost schedule in future 11 dollars, including Allowance for Funds Used During Construction, is forecasted to be 12 approximately $5.8 billion, which is $25 million less than the forecast reflected in the most 13 recent Commission Order No. 2011-345. This is due primarily to actual escalation and 14 revised future escalation forecasts being lower than that reflected in the Order. 15 Q. 18 19 YOU PLEASE ADDRESS THE CONSTRUCTION SCHEDULE CHANGES AND YOUR REVIEW OF THE CHANGES IN MORE DETAIL? 16 17 COULD A. SCE&G has identified three major causes of the 11 Y2 month delay in the Substantial Completion Date of Unit 2. These were: • The 9 month delay in receiving the COL from the Nuclear Regulatory 20 Commission (“NRC”) which issued the COL on March 30, 2012 instead of 21 the originally anticipated July 1, 2011 date; THE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC Z9201 Direct Testimony of Gary C. Jones, P.E, August 9, 2012 1 • Docket No. 2012-203-E (Redacted) South Carolina Ekctric & Gas Company Page 6 A delay of one additional month due to excavated rock conditions for the 2 nuclear island (“NI”) basemat for Unit 2 requiring additional fill concrete 3 beyond that originally anticipated; and, 4 • A delay of an additional 1 1/2 months due to the increased construction time 5 associated with the complexity of the shield building field assembly 6 attributable to design changes. 7 ORS’s review of these changes to the schedule were found to be reasonable. The 8 changes are cumulative in that the work associated with them is sequential (e.g., the 9 basemat concrete pour cannot be performed until the COL is issued) and site-related; 10 therefore, it cannot be performed in parallel or off-site in order to reduce the delay. 11 In addition to changes to the Substantial Completion Dates, these delays also 12 translate into changes to other construction activities. However, not all activities are 13 affected because some activities are performed off-site and/or are not dependent on site 14 construction. This is particularly true for vendor-supplied equipment fabrication and 15 delivery schedules. In addition, as the Project progresses, knowledge and experience 16 advance and lessons learned are deployed. This means that construction durations are 17 refined and construction sequencing is modified. Therefore, not all activities on the 18 schedule were changed by the same delay interval. In some cases, they were not changed at 19 all. This can readily be seen by a quick review of the BLRA Milestone Comparison table 20 included as Exhibit GCJ-2. 21 From this Exhibit, one can determine the following with regard to the status of the 22 146 BLRA Milestones: 23 • 72 of the milestones are complete with 74 remaining; THE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC 29201 Direct Testimony of Gary C. Jones, P.E. August 9, 2012 Docket No. 2012-203-E (Redacted) South Camlina Electric & Gas Company Page 7 1 • 13 have accelerated dates; 2 • 48 have delayed dates that vary between 1 to 16 months; and, 3 • 13 dates remain unchanged. 4 The Company is still developing a complete and current integrated construction 5 schedule; therefore, it was not available for ORS review. However, SCE&G has revised 6 the major milestones and major portions of the revised construction schedule which were 7 made available and reviewed by ORS to determine whether they represented a reasonable 8 and realistic basis for scheduling Unit 2 construction to meet the revised Substantial 9 Completion Date of March 15, 2017. It should be noted that a detailed integrated schedule 10 based on the previous Substantial Completion Dates had been made available to ORS and 11 was developed to a similar level of detail and in a manner consistent with those schedules 12 for other nuclear power plants with which I have experience. The activities were well 13 defined at a level that can be readily monitored and reported and appeared to be logically 14 sequenced with reasonable durations. It is anticipated that the current version of the 15 integrated schedule will be developed to the same level of detail and in accordance with the 16 same methodology as that previously provided. 17 Q. 18 A. WHAT CONCERNS DO YOU SEE IN YOUR REVIEW? It must be noted that the revised construction schedule represents an aggressive and 19 ambitious construction approach that presents a risk to the on-time completion of the 20 Project. While similar projects are meeting and have met similarly aggressive construction 21 schedules in Asia, there is no precedent for attaining similar results on any modern nuclear 22 power plant in the United States. This represents a challenge to the Project that will require 23 rigorous diligence and sustained commitment. THE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC 29201 Direct Testimony of Gary C. Jones, P.E. August 9, 2012 Docket No. 2012-203-E (Reciacted) South Carolina Electric & Gas Company Page 8 1 Challenges have already manifested themselves as SCE&G has identified that the 2 Project is currently 63 days behind the most recently revised schedule due to various issues 3 associated with the basemat concrete pour delay. The Company is developing recovery 4 plans to mitigate this delay. In addition, fabrication delays in the structural modules are 5 occurring at the Shaw Modular Solutions (“SMS”) facility in Lake Charles, Louisiana. 6 These delays, which have previously been identified in several ORS Quarterly reports, 7 present a potentially significant schedule impact that may present challenges to the 8 construction completion schedule. Although significant and appropriate corrective actions 9 have been taken by Stone and Webster, a subsidiary of the Shaw Group, Inc. (“Shaw”), 10 Westinghouse Electric Company, LLC (“WEC”) and SCE&G to address these delays, 11 close monitoring by ORS will continue. 12 Also, of concern are the potential for additional delays associated with the shield 13 building modules. Fabrication of these shield building components has not yet begun in 14 earnest. 15 components are more complex than the structural modules and will present even greater 16 challenges to fabrication and field erection. As stated above, the shield building has already 17 contributed to a 1 Yz month delay in the Substantial Completion Date of Unit 2, which 18 prompts a concern that there may be more delays associated with these components. The 19 Company must ensure that the shield building modules receive elevated scrutiny and 20 monitoring. 21 22 Q. COULD Although there are currently no reports of schedule slippage, many of these YOU PLEASE DISCUSS FURTHER THE SUBSTANTIAL COMPLETION DATE OF UNIT 3? TIlE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC 29201 CHANGE IN THE Direct Testimony of Gary C. Jones, P.E. August 9, 2012 1 A. Docket No. 2012-203-E (Redacted) South Carolina Electric & Gas Company Page 9 SCE&G is also requesting that the Substantial Completion Date for Unit 3 be 2 accelerated to May 15, 2018, as compared to the currently approved date of January 1, 3 2019. The basis for SCE&G’s new date is an extrapolation of the draft Consortium COL 4 Delay Study commissioned via Change Order 11 to the EPC Contract which demonstrated 5 that cost savings could be gained by reducing the interval between the Substantial 6 Completion Dates of the Units to 14 months. The basis of this change was reviewed and 7 will be addressed in more detail when the EPC cost changes are summarized later in my 8 testimony. The same review approach was applied as used on Unit 2 and the same results 9 obtained. The changes to the schedule appear to be reasonable and represent a cost 10 ii effective acceleration of the Unit 3 Substantial Completion Date. Q. 12 13 ARE THERE IMPACTS TO THE BLRA MILESTONES THAT RESULT FROM THESE CONSTRUCTION SCHEDULE CHANGES? A. Yes. Changes to the construction schedule result in changes to the remaining open 14 BLRA milestones, as identified in Exhibit 1 of SCE&G’s filing. These changes are 15 reflected on the attached BLRA Milestone Comparison Table, Exhibit GCJ.2, which 16 provides the currently approved date compared with the requested revised milestone date 17 and provides a summary of the reasons for the changes to those milestone dates. These 18 changes were reviewed and were found to be reasonable and in agreement with the revised 19 construction schedule. 20 Q. WHAT ARE YOUR RECOMMENDATIONS WITH REGARD TO ACCEPTING 21 THE PROPOSED REVISED SUBSTANTIAL COMPLETiON DATES AND THE 22 REVISED BLRA MILESTONE COMPLETION DATES CONSIDERING YOUR 23 PREVIOUSLY DISCUSSED CONCERNS? THE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC 29201 Direct Testimony of Gary C. Jones, P.E. August 9, 2012 1 A. Docket No. 2012-203-E (Redacted) South Carolina Electhc & Gas Company Page 10 I recommend that the Commission accept the revised Substantial Completion Dates 2 of March 15, 2017 for Unit 2 and May 15, 2018 for Unit 3 as proposed by SCE&G in their 3 filing in Docket No. 2012-203-E. Furthermore, I recommend that the Commission approve 4 the revised BLRA Milestone Schedule proposed in this same filing. 5 Q. COULD YOU PLEASE ADDRESS THE EPC CONTRACT CHANGES WHICH 6 YOU REVIEWED AND PROVIDE MORE DETAIL ON THE CHANGES AND ON 7 YOUR REVIEW? 8 9 10 A. Yes. In their filing, SCE&G addressed four major reasons for the changes to the EPC Contract, as follows: • 11 12 from the NRC; • 13 14 • 19 The additional costs incurred as a result of the redesign of the structural modules; and, • 17 18 The additional costs associated with the redesign and increased construction costs of the shield building; 15 16 The additional costs incurred as a result of the delay in receiving the COL The additional costs incurred as a result of the bedrock under the Unit 2 NI being deeper than the test borings indicated. In addition, there were three other change orders that impacted the EPC Contract costs and were included in this filing identified as follows: 20 • Cyber Security, 21 • Waste Water Discharge Piping, and 22 • Health Care Costs. THE OFFICE OF REGULATORY STAFF 1401 Mom Street, Suite 900 Columbia, SC 29201 Direct Testimony of Gary C. Jones, P.E. August 9, 2012 Docket No. 2012-203-E (Redacted) South Carolina Electric & Gas Company Page 11 1 My testimony will address the four major reasons for the EPC cost changes and the 2 Cyber Security change order. ORS witness Powell will address the EPC cost change orders 3 on Waste Water Discharge Piping and Health Care Costs. 4 It should be noted that the four major reasons for the EPC Contract cost changes 5 were bundled together and negotiated with WEC/Shaw (“Consortium”) as a package. As 6 stated by the Company in their filing, these changes were subject to extensive negotiations 7 extending over several months before a compromise was reached and an agreement 8 (“Settlement Agreement”) was made to settle these claims for $137.5 million, the amount 9 requested in the filing. This compromise represented a significant reduction from the 10 originally proposed amount of $214 million. This final negotiated value also included a 11 credit of from Shaw reflecting an acceleration of potential rebates. 12 It should also be noted that the negotiated Settlement Agreement also included a 13 change in the escalation rates for the “Firm with Indexed Adjustment Category” of the EPC 14 Contract, wherein this portion will now be escalated at a fixed escalation rate of 15 beginning in July 2012 in lieu of the previously specified Handy-Whitman Indices. 16 SCE&G considers this fixed escalation rate to be beneficial by providing more certainty to 17 the final cost of the Project. Although this change is not a patently obvious benefit to 18 SCE&G based on the recent Handy-Whitman indices rates, uncertainties about the future 19 levels of these indices, coupled with the relatively minor impact of this change on the 20 overall costs, indicate that it is reasonable for the Company to reduce their unknown risks 21 by locking in a fixed escalation rate. 22 23 Q. COULD YOU PLEASE DISCUSS THE REVIEW OF THE COL DELAY IN MORE DETAIL? THE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC 29201 Direct Testimony of Gary C. Jones, P.E. August 9, 2012 I A. Docket No. 201 2-203-E (Redacted) South Carolina Electric & Gas Company Page 12 Yes. The COL delay was assigned a cost of in 2007 dollars in the 2 Settlement Agreement. The draft Consortium COL Delay Study, dated November 4, 2011, 3 which provided the basis for the increased scope and increased costs, was provided for 4 review. An extrapolation of one of the options presented in the study (delaying Unit 2 by 5 nine months instead of the originally stated six months in the study) presented the basis for 6 the cost increases in Unit 2 and the cost decreases in Unit 3 in this Petition. The cost 7 increases for Unit 2 were primarily associated with having construction personnel and 8 equipment on-site for a nine month duration beyond that originally planned with lower 9 productivity because of work restrictions due to the COL delay. The option of demobilizing 10 during this period was considered infeasible because the duration was actually unknown as 11 to when the work could begin and the loss of skilled labor, support personnel and 12 equipment would not have been acceptable. 13 primarily to being able to more efficiently redeploy craft labor, support personnel and 14 equipment from Unit 2 to Unit 3 and to work more areas in parallel. The review of the basis of the added costs appeared to be reasonable and in-line 15 16 17 with the expected values. Q. 18 19 The cost decreases on Unit 3 were due COULD YOU PLEASE DISCUSS THE REVIEW OF THE SHIELD BUILDING CHANGES IN MORE DETAIL? A. Yes. The cost increase associated with the redesign of the shield building represents 20 by far the largest cost component of the four major changes. This cost is 21 2007 dollars as designated in the Settlement Agreement. Several detailed documents and 22 reports representing well over a thousand pages were provided to ORS to justify this cost 23 increase. These reports and studies supported the claims that the changes were prompted by THE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC 29201 in Direct Testimony of Gary C. Jones, P.E. August 9, 2012 Docket No. 20l2-2O3E South Carolina Electric & Gas Company (Redacted) Page 13 1 revisions in the NRC regulations and changes in the NRC’s acceptance criteria. Most, but 2 not all, of the changes can be attributed to the NRC’s review of the WEC design, which 3 was prompted by changes to the regulations addressing the need for the structure to resist 4 the effects of an aircraft impact to the shield building. The NRC significantly revised, via 5 Draft Regulatory Guide DG- 1176, dated July 2009, the required loading the shield building 6 must accommodate from that which WEC used in the original design of the Units, and 7 which formed the basis of the EPC Contract, as was delineated in Design Control 8 Document (“DCD”), Revision 16. 9 Another closely related issue was the NRC’s refusal to accept the steel/concrete 10 composite (“SCC”) wall design which WEC had included in the original design of the 11 Units. This came about via NRC directives issued on October 15, 2009 which rejected the 12 WEC SCC design. This rejection prompted a prolonged series of redesigns by WEC and 13 reviews between the NRC and WEC which culminated in the design represented by DCD, 14 Revision 19, upon which the Project’s COL was based and which forms the basis of the 15 current design. 16 I reviewed these changes to determine whether the settlement amount is reasonable. 17 The design and construction changes were extensive. I summarize some of the major 18 physical changes below, but this does not represent the full extent of these changes: 19 • The thickness of the faceplates on each side of the shield building walls was 20 increased from 0.5 inches to 0.75 inches and the material was changed from 21 ASTM 572 Grade 65 to Grade 50 in order to increase the tensile strength; 22 23 • Over 30,000 tie bars with a diameter of 0.75 inches were added to span between the faceplates to tie them together, and required a penetration THE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC 29201 Direct Testimony of Gary C. Jones, P.E. August 9, 2012 Docket No. 2012-203-E (Redacted) South Carolina Electhc & Gas Company Page 14 I through the faceplates so that they can be welded on the outside of the 2 faceplates; 3 Spacing of the Nelson studs, used to bond the concrete to the steel creating a • 4 composite unit, was revised to greatly increase the concentration and 5 number of studs on each inside face of the plates; 6 Stiffener plates, reinforcing gusset plates and other reinforcement were • 7 8 added in many areas; The air vents that provide passive cooling to the containment vessel were • 9 revised from a square configuration to be replaced by round 18 inch 10 11 Schedule 40 pipe, which is a stronger configuration; • The connections from the 8CC areas to areas of reinforced concrete in the 12 basemat and the auxiliary building were changed from hooked rebar to 13 mechanical connections using threaded rebar, bolted to plates or gussets; 14 and, 15 16 • The tension rings at the wall to roof connection were changed from I-beams to a box beam configuration with an increased plate thickness. 17 The changes required extensive redesign, reanalysis, additional procurement, and 18 additional constructability and Project impact reviews. They also required a significant 19 testing and bencbmarking program to prove the capabilities of the SCC structure, involving 20 several outside contractors and institutions. Licensing activities associated with the NRC 21 review and the actual fees required by the NRC to perform the review also represented a 22 significant cost. TUE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC 29201 Direct Testimony of Gary C. Jones, P.E. August 9, 2012 Docket No. 2012-203-E (Redacted) South Carolina Electric & Gas Company Page 15 I In addition, the changes resulted in a considerably more complex structure than 2 originally envisioned which dramatically increased the construction costs of the structure, 3 including the shop fabrication costs and the field labor costs. Welding processes and 4 procedures, non-destructive examination (“NDE”) processes and procedures and labor 5 skills and quantities were all impacted by these changes. The complexity also dictated the 6 need to build several mock-ups to refine fabrication and field construction activities. The 7 added complexity in the field erection of the shield building has contributed to the delay of 8 the Project by adding another I Y2 months to the completion schedule. 9 Based on the review of the reasons for the changes and the scope and extent of the 10 changes with the resultant impact on the added complexity of the fabrication and erection 11 process, it is my opinion that the costs associated with the changes to the shield building 12 are reasonable. 13 Q. 14 15 COULD YOU DISCUSS THE CHANGES TO THE STRUCTURAL MODULES IN MORE DETAIL? A. Yes. SCE&G provided documentation for ORS’s review that outlined the basis for 16 and the extent of changes to the structural modules. The additional costs quoted in the 17 Settlement Agreement associated with the changes to the structural modules are 18 in 2007 dollars. The reason for these changes is very similar to that already 19 described for the changes to the shield building. The changes were prompted by the NRC 20 review of the WEC design associated with the final aircraft impact rule by the NRC after 21 the EPC Contract had been signed and the basis for the design of the structural modules set 22 by the EPC Contract. This issue was further complicated by the NRC’s refusal to accept 23 the SCC design which had previously been preliminarily accepted by the NRC. This TilE OFFICE OF REGULATORY STAFF 1401 MaIn Street, Suite 900 Columbia, SC 29201 Direct Testimony of Gaiy C. Jones, P.E. August 9, 2012 Docket No. 2012-203-E (Redacted) South Camlina Electric & Gas Company Page 16 I caused similar, albeit less extensive and less costly, changes to 94 of the 134 structural 2 modules. 3 An additional issue unique to the structural modules was the use of stainless steel 4 on the inner faceplates which had a different allowable stress value than the carbon steel 5 material on the outer faceplates. Stainless steel was used on those modules that were 6 assumed to be exposed to water during postulated accident events. The NRC insisted, and 7 the American Institute of Steel Construction Code supported their position, that the 8 faceplates of a composite structure must have similar strength properties. Therefore, it was 9 required that the outside faceplate material be changed from the original ASTM A36 to the 10 more compatible ASTM A572, which is a stronger material that has properties more ii similar to those of stainless steel. 12 13 14 In addition, the following physical changes were also required in order to gain NRC acceptance of the WEC design: • Nelson stud spacing was changed from a l0”xlO” pattern to a 6”x6” pattern. 15 This significantly increases the number of Nelson studs by over 2.5 times 16 the original number; and, 17 18 • Mechanical connections with threaded rebars, bolted to reinforced plates at the basemat connections and other high stress area connections were added. 19 These changes resulted in added costs associated with redesign, reanalysis and 20 additional procurement, additional constructability reviews and schedule impact reviews 21 and adjustments. Licensing costs, including the payment of NRC fees for additional review, 22 increased over the approximately two years of interface with the NRC required to obtain 23 approval of the final design. Finally, as with the shield building, fabrication and field THE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC 29201 Direct Testimony of Gary C. Jones, P.E. August 9, 2012 Docket No. 2012-203-E (Redacted) South Carolina Electric & Gas Company Page 17 I construction costs for the structural modules increased due to the added complexity and 2 congestion. Welding processes and procedures required revision and requalification and 3 NDE processes and procedures had to be revamped. 4 Based on the review of the reasons for the changes and the scope and extent of 5 these changes, it is my opinion that the costs quoted in the Settlement Agreement for the 6 structural module changes represent a reasonable cost. 7 Q. 8 9 PLEASE PROVIDE MORE DETAIL ON THE REVIEW OF THE BEDROCK ELEVATION ISSUE. A. With regard to the changes associated with the Unit 2 bedrock elevation issue, the 10 cost of these changes was quoted in the Settlement Agreement as 11 dollars. The analysis of the basis of this cost increase indicates that the change was caused 12 by an unanticipated local anomaly in the depth of the bedrock under the NI basemat that 13 was not identified in the soil boring data provided to the Consortium. In addition to the 14 costs associated with the additional excavation and fill that was required by the increased iS depth, the major cost impact is associated with the one month delay in the construction 16 schedule that is attributed to this issue. The delay is protracted because of limitations in the 17 allowable depth of fill concrete (18 inches) that can be poured and the curing time required 18 before an additional pour can be made on top of the first pour. This restriction to 18 inches 19 is required to permit the necessary vibration of the fill concrete to consolidate and compact 20 it. Therefore, this additional depth requires seven additional pours which each require three 21 days to complete. This translates into twenty-one working days which is essentially a 22 calendar month. THE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC 29201 in 2007 Direct Testimony of Gary C. Jones, P.E. August 9, 2012 1 be reasonable. Q. 4 5 South Carolina Electric & Gas Company Page 18 Based on the review of this activity and cost of this change, I find the stated cost to 2 3 Docket No. 2012-203-E (Redacted) COULD YOU PLEASE DISCUSS THE REVIEW OF THE CYBER SECURITY CHANGE ORDER IN MORE DETAIL? A. Yes. The final area of my review for the EPC cost increase involves the changes 6 associated with strengthening the plant’s defenses against cyber attacks. This cost increase 7 was prompted by the NRC issuance of Regulatory Guide 5.71, “Cyber Security Programs 8 for Nuclear Facilities”, dated January 2010, which identifies an acceptable approach to 9 comply with 10 CFR 73.54, “Protection of Digital Computer and Communications Systems 10 and Networks”, dated May 2009. 11 SCE&G elected to approach this work in two phases. Phase I was undertaken for a 12 cost of $914,422 and will more definitively scope the total work that is required by the 13 entire program. Phase I will involve the review of the specific equipment and software of 14 the plant to identify potential vulnerabilities to cyber attack and develop approaches to 15 protect against such attacks. Phase II will complete the programming and other work 16 required to actually protect the potentially vulnerable equipment and software against the 17 identified cyber attacks. The cost of Phase II is estimated at $4.95 million. 18 SCE&G previously provided ORS with a draft of Change Order No. 14, which 19 formed the basis of the review for this cost change to the EPC Contract. This draft included 20 a detailed scope of work description submitted by the Consortium for Phase I and Phase II, 21 and an analysis of this proposal prepared by SCE&G. Phase I has been essentially 22 completed and is providing the basis for the final estimate for Phase II that is currently 23 under preparation. THE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC 29201 Direct Testimony of Gary C. Jones, P.E. August 9, 2012 Docket No, 2012-203-E (Redacted) South Carolina Electric & Gas Company Page 19 1 The review of the basis of this change establishes a well-defined basis for the 2 performance of Phase I and a good preliminary basis for Phase II. However, Phase II will 3 be better defined based on the results of Phase I and a more detailed and informed estimate 4 will be provided at that time. In addition, there are several aspects of this work that apply 5 generically to the entire generation of U.S. AP-1000 plants and the costs should be shared 6 by all U.S. AP-1000 plants. WEC has acknowledged this sharing, but has not finalized a 7 scheme as to how it will be equitably addressed with regard to the cost implications. The 8 work being performed here explores a new area in the design of nuclear power plants and 9 represents the first effort at attempting to comply with the new NRC requirements. For 10 these reasons, I believe the costs of the Phase I work should be approved, but the $4.95 11 million cost of the Phase II work should be deferred until a later filing when there is a 12 better definition of the scope and costs and the issue of cost sharing among all U.S. AP 13 1000 plants has been more clearly defined. Therefore, I recommend that the Commission 14 approve only the $914,422 cost of Phase I of the Cyber Security Change Order Request at 15 this time. 16 Q. 17 18 COULD YOU PLEASE SUMMARIZE YOUR RECOMMENDATIONS FOR TIlE APPROVAL OF THE EPC COSTS COVERED BY YOUR REVIEW? A. Yes. In summary, I support the $137.5 million adjustment to the EPC Contract 19 associated with the shield building redesign, the structural module redesign, the COL delay, 20 and the Unit 2 rock conditions as requested in the Company’s Petition under Docket No. 21 2012-203-E. 22 representing Phase I of the cyber security issue. I recommend that the costs of $4.95 In addition, I support the $914,422 adjustment to the EPC Contract THE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC 29201 Direct Testimony of Gary C. Jones, P.E. August 9, 2012 Docket No. 2012-203-E (Redacted) South Carolina Electric & Gas Company Page 20 1 million representing Phase II of the cyber security change be deferred until additional 2 information is available and that this cost be excluded from this update. 3 Q. DID YOU ALSO REVIEW THE OWNERS COST UPDATE REQUEST 4 SUBMITTED IN THE SCE&G PETITION UNDER DOCKET 2012-203-E, AND 5 COULD YOU PLEASE SUMMARIZE YOUR REVIEW? 6 A. Yes. I reviewed the Owners Cost requesting an increase in the SCE&G forecast of 7 approximately $131.6 million. My review included the three major SCE&G program plans 8 and two additional areas of increased costs. The three program plans are identified as the 9 staffing analysis, the software roadmap and the multi-unit facilities study. Documentation 10 on each of these program plans was provided by the Company to ORS for our review. 11 These three areas address a major cost component of the changes in the Owners Cost. The 12 other two cost categories can be classified as non-labor related changes to the operation, 13 maintenance and construction of the Units and miscellaneous cost increases associated with 14 obtaining various site licenses and permits, NRC fees, insurance premiums, recruitment 15 fees for hiring and other costs not readily categorized. 16 Q. 17 18 COULD YOU PLEASE DISCUSS THE REVIEW OF THE STAFFING PLAN IN MORE DETAIL? A. Yes. The costs associated with increased staffing represented by far the most 19 significant portion of the increased Owners Cost. SCE&G advised that in the latter part of 20 2011 they instituted an extensive review of their staffing levels utilizing a specially 21 constituted panel of experienced personnel to challenge and validate the assumptions on 22 staffing levels with each of their department managers. This resulted in changes to the 23 recommended staffing levels which were reviewed and resulted in an increase of Project TilE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC 29201 Direct Testimony of Gary C. Jones, P.E. August 9, 2012 Docket No. 2012-203-E (Redacted) South Carolina Electric & Gas Company Page 21 1 staff by 144 Full Time Employees (“FTE”), comprised of 124 operational and construction 2 FTEs and 20 security FTEs, above those in the approved budget associated with Order 3 2011-345. The major increases and the bases of these changes are summarized as follows: 4 • Operations and Training — increased by 30 FTEs 5 This increase was based on the need to hire and train more operators than 6 originally believed to be required because of the anticipated higher failure rates 7 of operators in their final licensing examinations. This increased failure rate has 8 been experienced industry-wide and locally within the same NRC region 9 (Region II) as the Project. 10 • Emergency Planning and Health Physics — increased by 40 FTEs 11 An NRC rulemaking published in November 2011 is requiring a limitation of 12 duties to designated emergency personnel which has resulted in an increase in 13 the number of necessary personnel throughout the nuclear industry. Underlying 14 these new requirements is concern on how to address the emergency response 15 issues resulting from the Fukushima event. 16 • Engineering— increased by 22 FTEs 17 Most of the additional engineers (17) are assigned to tasks associated with 18 programs that were originally intended to be developed by the AP-1000 Owners 19 Group (“APOG”). However, the restrictions imposed by WEC on sharing 20 information with utilities that had not signed an EPC Contract has resulted in 21 APOG not being able to fulfill the tasks originally anticipated, which must now 22 be performed by SCE&G and Southern Company alone. The remaIning 23 engineers arc assigned to program and maintenance support and oversight. THE OFFICE OF REGULATORY STAFF 1401 MaIn Street, Suite 900 Columbia, SC 29201 Direct Testimony of Gary C. Jones, P.E. August 9, 2012 I • Docket No. 2012-203-E (Redacted) Quality Systems — South Carolina Electric & Gas Company Page 22 increased by 20 FTEs 2 These additions to the Quality Assurance and Quality Control programs have 3 been identified as required in order to meet SCE&G’s obligations for 4 construction and supplier oversight. Quality issues have been identified at 5 several vendors and other subcontractors (e.g., the SMS facility previously 6 discussed) that require an increased number of inspections, audits and reviews. 7 In addition, recent site developments have also indicated the need for increased 8 construction surveillances, inspections, audits and reviews. The current staff of 9 7 is insufficient to fulfill the functions required as construction and fabrication 10 11 activities rapidly increase. • Security Personnel — increased by 20 FTEs 12 These increases are required in order to meet recent NRC regulations that 13 increased the levels of security required at all U.S. nuclear facilities. 14 The adjustments in other departments were comparatively minor increases, with the 15 exception of a 16 FTE decrease in the Maintenance Department. This reduction came about 16 in recognition of the ability to share more staff and more skills with the existing V.C. 17 Summer (“VCS”) Unit 1 crew. 18 There were other considerations that also increased the cost of staffing. The most 19 significant of these were the need to account for increased costs due to the COL delay and 20 the need to accelerate the hiring of some staff to reflect the advance in the Unit 3 21 Substantial Completion Date. 22 The staffing analysis also indicated cost effective planning because it demonstrated 23 the transfer of selected individuals between the Units and into different roles as the plants THE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC 29201 Direct Testimony of Gary C. Jones, P.E. August 9, 2012 Docket No. 2012-203-E (Redacted) South Carolina Electric & Gas Company Page 23 1 progress through the construction stage and into the testing and operations phases. 2 Reductions in staff at certain appropriate times were also demonstrated. 3 The staffing increases appear to have a reasonable basis and in many cases were 4 driven by NRC regulatory changes. The final staffing levels are not outside the range of the 5 construction and operations staffing levels on similar plants with which I am familiar. 6 Therefore, I conclude that the requested increase in staffing levels represents a reasonable 7 component of the requested increase in the Owners Cost. 8 Finally, the cost basis of $72.3 million presented for these staff additions was 9 reviewed against expectations based on my experience and was found to be reasonable and 10 in-line with anticipated staffing costs for similar nuclear power plants with which I am 11 familiar. 12 Q. 13 14 COULD YOU PLEASE DISCUSS THE REVIEW OF THE SOFTWARE ROADMAP PROGRAM PLAN IN MORE DETAIL? A. Yes. SCE&G developed the software roadmap upon the realization that the 15 configuration management and work management systems that were in-place for VCS Unit 16 1 were inadequate to serve three nuclear units and that their software needed to be further 17 assessed and updated. The software roadmap was developed in conjunction with the 18 corporate Jnformation Technology (IT) group and each of the VCS departments. Each 19 department identified their software needs and presented a business case that justified the 20 need for the software. The corporate IT group coordinated and ensured consistency of the 21 overall software plan. 22 1 reviewed the software plan and found that SCE&G planned to utilize 23 commercially available software with which I am, for the most part, familiar and which is TUE OFFICE OF REGULATORY STAFF 1401 MaIn Street, Suite 900 Columbia, SC 29201 Direct Testimony of Gary C. Jones, P.E. August 9, 2012 Docket No, 2012-203-E (Redacted) South Carolina Electnc & Gas Company Page 24 I used on other nuclear power plants of which I have knowledge. However, among their 2 most significant software expenditures will be the purchase of a new configuration 3 management package and an upgrade of their work management system which is based on 4 a proprietary system being developed by 5 company. In both cases, these systems will replace outdated systems currently utilized by 6 VCS Unit 1 which are incapable of effectively serving a multi-unit plant. Both of these 7 software systems will process and store vast amounts of data and will produce valuable 8 work products for the plant. 9 utilized by VCS Units 1, 2 and 3. SCE&G is currently discussing the procurement of 10 configuration software systems with several vendors which have well established programs 11 that are utilized on other nuclear power plants, and with which I am familiar. However, 12 SCE&G is also considering utilizing vendors who do not have well developed programs 13 and are not suppliers to other nuclear power plants. The development and implementation 14 of work management and configuration management software by inexperienced vendors 15 represent some added risk to the Project. These risks have been acknowledged by SCE&G 16 and actions have been taken or assessments are underway to mitigate these risks. This is an 17 area that ORS will specifically monitor. a small software development is a small company and this system will only be 18 The other additional software under consideration represents areas where similar 19 software has been applied on other nuclear power plants with which I am familiar, 20 including the following: 21 • Flow Accelerated Corrosion software for identifying piping and component 22 areas of potential degradation and assessing areas subjected to these adverse 23 effects; THE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC 29201 Direct Testimony of Gary C. Jones, P.E. August 9, 2012 Docket No. 2012-203-E (Redacted) South Carolina Electric & Gas Company Page 25 I • Air-operated and motor-operated valve testing programs; 2 • Maintenance Rule implementation and management software; and, 3 • Whole body counting and radiation exposure monitoring software. 4 The software plan also addresses on-going software licensing fees and vendor 5 maintenance services. It estimated the costs of these on a reasonable basis, generally 6 assuming 20% of software costs as an annual fee. Costs associated with specific IT 7 hardware required to support the implementation of these programs, such as special 8 cabling, routers, work stations, etc., are also addressed in the plan. 9 Based on the review of this software plan, the software requirements identified and 10 the costs associated with these additions of $28.7 million appear to be reasonable and 11 consistent with that found on similar nuclear power plants with which I am familiar. 12 Q. 13 14 COULD YOU PLEASE ADDRESS YOUR REVIEW OF THE MULTI-UNIT FACILITIES PLAN? A. Yes. The multi-unit facilities study represented a comprehensive assessment of all 15 new and existing facilities that may be required by the entire nuclear complex represented 16 by VCS Units 1, 2 and 3. Not all facilities included in this report (“Facilities Plan”) were 17 fully developed as far as conceptual planning and cost estimates. Also, some of the 18 facilities were not assigned to the budgets for Units 2 and 3, but were to be paid for by 19 corporate or exclusively by VCS Unit 1. In the case of the Nuclear Operations Building, the 20 majority of the costs necessary to construct this facility have been previously approved by 21 the Commission. The amount represented in the Company’s current filing represents an 22 increase to the previously approved amount. However, the following near term facilities 23 were sufficiently developed to include in this update and have a cost component assigned THE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC 29201 Direct Testimony of Gary C. Jones, P.E. August 9, 2012 Docket No. 2012-203-5 (Redacted) South Camlina Electric & Gas Company Page 26 1 to Units 2 and 3. In some cases, the costs of each of these buildings represent an allocation 2 among VCS Units 1, 2 and 3 of the total cost of the facility since they will be shared among 3 all three VCS units. Therefore, this review addresses only the following facilities: 4 • Maintenance of Existing Facifities — increased by $1.9 million 5 This is the largest component of cost within the increase identified by the 6 Facilities Plan. The increased levels of staffing and the acceleration of the 7 timing of hiring the staff result in the increases in the maintenance and 8 operational cost of these buildings. 9 • Service Building Furnishings increased by $1.3 million — 10 The cost of constructing the Service Building is included in the EPC Contract; 11 however, it did not include the costs associated with furnishing and equipping 12 the Service Building. The review associated with developing the Facilities Plan 13 identified this circumstance and this increase addresses this need. 14 • Maintenance Facilities — increased by $1.4 million 15 Similar to the Service Building, the cost of the Maintenance Facilities are 16 included in the EPC Contract, but not the furnishings, tools or equipment. This 17 increase reflects these additional costs. 18 • Nuclear Operations Building (“NOB”) — increased by $0.7 million 19 The increased staffing levels required a reconfiguration and reallocation of the 20 NOB. This cost reflects these changes. 21 • Emergency Services Building— increased by $1.0 million THE OFFICE OF REGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC 29201 Direct Testimony of Gary C. Jones, PE. August 9, 2012 Docket No. 2012-203-li (Redacted) South Carolina Electric & Gas Company Page 27 1 The increased emergency services personnel and equipment mandated by the 2 changes in NRC requirements and the upcoming changes associated with the 3 lessons learned from the Fukushima event required this additional facility to be 4 built. 5 • Main Access and Plant Access Facilities — increased by $1.0 million 6 Although the Main Access Facility met the minimum regulatory requirements, 7 SCE&G elected to increase the security of this building by hardening it to better 8 withstand credible security threats and improve the overall security access to the 9 V.C. Summer Plant. In addition, the equipment, furnishings and fixtures of both 10 the Main Access and Plant Access Facilities could not be finalized until the 11 designs of these facilities were available. The increased costs now reflect the 12 addition of this equipment, furnishings and fixtures. 13 • Temporary/Modular Buildings — increased by $1.0 million 14 Additional temporary office space is required to accommodate the larger staff 15 and accelerated hiring during the construction phase of the Project and until the 16 permanent facilities are completed and ready for occupancy. 17 These increases are partially offset by an approximately $0.5 million reduction in 18 the security training classroom facilities, making the total increase $7.8 million. Based on 19 the review of the Facilities Plan and subsequent discussions with SCE&G, I find these cost 20 increases to be justified and reasonable. 21 22 Q. WHAT IS YOUR RECOMMENDATION WITH REGARD TO THE APPROVAL OF THE OWNERS COST? THE OFFICE OF REGULATORY STAFF 1401 MaIn Street, SuIte 900 Columbia, SC 29201 Direct Testimony of Gary C. Jones, P.E August 9, 2012 I A. Docket No. 2012-203.E (Redacted) South Carolina Electric & Gas Company Page 28 Based on the review as summarized above, I have determined that the $131.6 2 million for the increased Owners Cost, as stated in the Petition filed under Docket No. 3 2012-203 -E represents a reasonable cost increase for the Project. 4 Q. 5 A. DOES THIS CONCLUDE YOUR TESTIMONY? Yes, it does. THE OFFICE OF HEGULATORY STAFF 1401 Main Street, Suite 900 Columbia, SC 29201 Exhibit GCJ-1 Page 1 o13 GARY C. JONES Curriculum Vitae 1222 West George Street Chicago, Illinois 60657 +1-773 665 7402 Home +1-312-402-2954 Mobile garvjonesoartners.net EXPERTISE: Power Plant Design System Design and Engineering Safety Reviews Project Management Engineering Management Quality Improvement Safety Standards Development Project Development Reengineering Business Management Executive Consulting Resource Allocation International Business Application of Safety Standards PROFESSIONAL EXPERIENCE: December 2008 —Present JONES PARTNERS, LTD., ChIcago, IL, USA President Leader of a private energy consulting firm. Providing confidential nuclear power plant engineering consulting services to a large European nuclear steam supply system contractor and to the South Carolina Office of Regulatory Staff. Provided consulting engineering services to the International Atomic Energy Agency on the safety review of Ukrainian nuclear power plants in 2009 and served in July 2011 as part of the team to review the Egyptian Request for Proposal for their first nuclear power plant. Instructor at ASME seminar on new nuclear power plant system design in June 2009 in Atlanta, GA, June 2010 in Bethesda, MD, June 2011 in Columbia, SC and June 2012 in Augusta, GA. July 2006— November 2008 Austria INTERNATIONAL ATOMIC ENERGY AGENCY, Vienna, Senior Engineering Safety Officer Team leader in the development, review and revision of international nuclear safety standards and in assisting IAEA Member States in the application of these safety standards to their nuclear facilities through workshops, training courses, missions, conferences, seminars, scientific visits and other means. Project Manager of a multi-million dollar European Commission funded program to assess the compliance of the 15 Ukrainian nuclear power plants with IAEA Safety Standards. 2004— July 2006 JONES PARTNERS, LTD., Chicago, IL, USA PresIdent Leader of a private energy consulting and real estate investment firm. 1971 .-. 2003 SARGENT & LUNDY, L..LC, Chicago, IL Exhibit GCJ-1 Page 2 of 3 1988-2003 Sr. Vice PresidentlOwner Led a multi-million dollar global consulting organization to perform high level, quality driven consulting assignments in the development, assessment, design, construction and operation of power facilities. • Led the engineering and design for the restart of nuclear power plants and directed staff in all disciplines associated with plant restart, providing licensing interface and analytical support for submissions to the Nuclear Regulatory Commission. • Provided the full range of architect-engineering services to support the on-going operation of nuclear power plants including safety review, licensing and regulatory support, corrective action programs and procedure and test review. • Served as Mechanical Department Manager and executive in charge of all mechanical discipline resources in the company including standards, software, recruitment, project staffing, training, quality performance and budget. • Developed strategies and resources to increase business creating a profitable, respected organization; ensured financial performance, technical compliance and human resource management and development. • Directed the assessment and implementation of the Sargent & Lundy conversion from a partnership to a Limited Liability company; managed the development and implementation of regional offices. • SELECTED LEADERSHIP ROLES INCLUDE: o Served as interim Mechanical and Structural Chief Engineer for Commonwealth Edison Company Nuclear Division responsible for oversight and corporate engineering at all nuclear power plants. o Senior review board member for the Dresden Integrated System Inspection. o Independent safety review for Peoples Republic of China’s first indigenous nuclear power plant, Gin Shan, including visits to the PRC and interface with the Shanghai Nuclear Engineering Design Institute. o Independent design review of Korea Electric Power Corporation/Korea Power Engineering Company Yonggwang 3 and 4 nuclear power plant. o Developed industry standards, guidelines and software applications In conjunction with the Electric Power Research Institute. o Remediation and decommissioning studies and assessments for Savannah River and Argonne National Laboratory environmental cleanup of nuclear and hazardous wastes. o Root cause investigations to determine reasons for failure and recommendations for fixes of various power plant systems including diesel generators, pumps, valves and other major components and systems. Exhibit GCJ- 1 Page 3 of 3 1976-1988 • • • • • o Development and implementation of new business strategies, processes, standards and procedures as Executive Director of Nuclear Services. o Company-wide Malcolm Baldrige self-assessment and the Total Quality Management implementation in addition to special post-implementation assessment teams. AssociatelProject Manager, Sr. Mechanical Project Engineer Planned, coordinated and monitored performance for full scope engineering and design projects for Commonwealth Edison’s Braidwood and Indiana’s Marble Hill nuclear stations. Managed 1,500 engineering personnel assigned to projects. Project Manager for Design Basis Verification Program at TVA’s Watts Bar Nuclear power plant. Led the mechanical Nuclear Steam Supply System process and physical engineering and design for Commonwealth Edison’s dual unit LaSalle nuclear power station. Served as principal technical interface and author of the LaSalle County Station Final Safety Analysis report. Mechanical Engineer 1971-1976 • Performed engineering duties for multiple nuclear power plants. 1966-1967 1968-1969 • • OAK RIDGE NATIONAL LABORATORY, Oak Ridge, TN, USA Cooperative Education Assignments Radioisotopes Division Reactor Operations Division EDUCATION: • Bachelor of Science, Engineering Science Mechanical and Nuclear Tennessee Technological University in Cookeville, TN • University of Michigan Executive Program — REGISTRATIONS: • Professional Engineer — Missouri and South Carolina ASSOCIATIONS: • American Nuclear Society • American Society of Mechanical Engineers • Founder, Past President and current Vice President of the Engineers Without Borders USA-Chicagoland Professional Chapter • Member of the Great Lakes Region Technical Advisory Committee of Engineers Without Borders-USA • Board Member of SALUTE, Inc., a non-profit organization assisting military service personnel and their families BLRA Order No. 2010-12 and Docket No. 2012-203-E Revised Milestones Comparison VC Summer Units 2 and 3 1 Approve Engineering Procurement and Construction Agreement Complete Complete 2 Issue P.0.s to nuclear component fabricators for Units 2 and 3 Containment Vessels Complete Complete Contractor Issue P0 to Passive Residual Heat Removal Heat Exchanger Fabricator First Payment Unit 2 Complete Complete 4 Contractor issue P0 to Accumulator Tank Fabricator Unit 2 Complete Complete S Contractor Issue P0 to Core Makeup Tank Fabricator Units 2 & 3 Complete Complete 6 Contractor Issue P0 to Squib Valve Fabricator Units 2 & 3 Complete Complete 7 Contractor Issue P0 to Steam Generator Fabricator Units 2 & 3 Complete Complete 8 Contractor Issue Long lead Material PG to Reactor Coolant Pump Fabricator Units 2 & Complete Complete 9 Contractor Issue P0 to Pressurizer Fabricator Units 2 & 3 Complete Complete 10 Contractor Issue P0 to Reactor Coolant Loop Pipe Fabricator First Payment Units 2 & Complete Complete Reactor Vessel internals Issue Long lead Material P0 to Fabricator Units 2 and 3 Complete Complete 12 Contractor Issue Long lead Material P0 to Reactor Vessel Fabricator Units 2&3 Complete Complete 13 Contractor Issue P0 to Integrated Head Package Fabricator Units 2 & 3 Complete Complete 14 Control Rod Drive Mechanism issue P0 for long lead Material to Fabricator Units 2 and 3- first payment Complete Complete 15 Issue P0.s to nuclear component fabricators for Nuclear island structural CA2O Modules Complete Complete - - - - - - - - - - - Provided by South Carolina Electric & Gas Company at the request of ORS 1 Exhibit GCJ-2 BLRA Order No. 2010-12 and Docket No. 2012-203-E Revised Milestones Comparison VC Summer Units 2 and 3 Milestone Description Explanation 16 Start Site Specific and balance of plant detailed design 17 Instrumentation & Control SmuIator Contractor Place Notice to Proceed Units 2 & 3 18 Complete Complete Complete Complete Steam Generator Issue Final P0 to Fabricator for Units 2 and 3 Complete Complete 19 Reactor Vessel Internals Contractor Issue P0 for long lead Material (Heavy Plate and Heavy Forgings) to Fabricator Units 2 & 3 Complete Complete 20 Contractor Issue Final P0 to Reactor Vessel Fabricator Units 2 & 3 Complete Complete 21 VarIable Frequency Drive Fabricator Issue Transformer P0 Units 2 & 3 Complete Complete 22 Start clearing, grubbing and grading Complete Complete 23 Core Makeup Tank Fabricator Issue Long Lead Material P0 Units 2 & 3 Complete Complete 24 Accumulator Tank Fabricator Issue Long Lead Material P0 Units 2 & 3 Complete Complete 25 Pressurizer Fabricator Issue Long Lead Material P0 Units 2 & 3 Complete Complete 26 Reactor Coolant Loop Pipe Contractor Issue P0 to Fabricator Second Payment Units 2 & 3 Complete Complete 27 Integrated Head Package Issue P0 to Fabricator Units 2 and 3- second payment Complete Complete 28 Control Rod Drive Mechanisms Contractor Issue P0 for Long Lead Material to Fabricator— Units 2 & 3 Complete Complete 29 Contractor Issue P0 to Passive Residual Heat Removal Heat Exchanger Fabricator Second Payment Units 2 & 3 Complete Complete Start Parr Road intersection work. Complete Complete - - - - — - - - - - - - 30 - - Exhibit GCJ-2 - Provided by South Carolina Electric & Gas Company at the request of ORS 2 BLRA Order No 2010-12 and Docket No. 2012-203-c Revised Milestones Comparison VC Summer Units 2 and 3 31 Reactor Coolant Pump Issue Final P0 to Fabricator Units 2 and 3 32 Integrated Heat Packages Fabrkator Issue Long Lead Material P0 Units 2 & 33 Complete Complete Complete Complete Design Finalization Payment 3 Complete Complete 34 Start site development Complete Complete 35 Contractor Issue P0 to Turbine Generator Fabricator Units 2 & 3 Complete Complete 36 Contractor Issue P0 to Main Transformers Fabricator Units 2 & 3 Complete Complete Core Makeup Tank Fabricator Notice to Contractor Receipt of Long Lead Material Units 2 & 3 Complete Complete 38 Design Finalization Payment 4 Complete Complete 39 Turbine Generator Fabricator Issue P0 for Condenser Material Unit 2 Complete Complete Complete Complete Passive Residual Heat Removal Heat Exchanger Fabricator Receipt of Long Lead Material Units 2 & 3 Complete Complete Design Finalization Payment S Complete Complete Start erection of construction buildings, to include craft facilities for personnel, tools, equipment; first aid facilities; field offices for site management and support personnel; temporary warehouses; and construction hiring office. Complete Complete Reactor Vessel Fabricator Notice to Contractor of Receipt of Flange Nozzle Shell Forging Unit 2 Complete Complete Design Finalization Payment 6 Complete Complete - - - - - Reactor Coolant Pump Fabricator Issue Long Lead Material Lot 2 Units 2 & - 41 - 42 45 Provided by South Carolina Electric & Gas Company at the request of ORS 3 Exhibit GCJ-2 BLRA Order No. 2010-12 and Docket No. 2012-203-E Revised Milestones Comparison VC Summer Units 2 and 3 I. - Order No. 2010-12. Date Exhibit GCJ-2 Explanation Instrumentation and Control Simulator Contractor Issue P0 to Subcontractor for Radiation Monitor System Units 2 & 3 Complete Complete Reactor Vessel Internals Fabricator Start Fit and Welding of Core Shroud Assembly Unit 2 Complete Complete Turbine Generator Fabricator Issue P0 for Moisture Separator rFeedwater Heater Material Unit 2 Complete Complete Complete Complete 10/31/2011 7/31/2012 Control Rod Drive Mechanisms Fabricator to Start Procurement of Long lead Material Unit 2 Complete Complete Contractor Notified that Pressurizer Fabricator Performed Cladding on Bottom Head Unit 2 Complete Complete Start excavation and foundation work for the standard plant for Unit 2 Complete Complete Steam Generator Fabricator Notice to Contractor of Receipt of 2nd Steam Generator Tubesheet Forging Unit 2 Complete Complete Reactor Vessel Fabricator Notice to Contractor of Outlet Nozzle Welding to Flange Nozzle Shell Completion Unit 2 Complete Complete Turbine Generator Fabricator Notice to Contractor Condenser Fabrication Started Unit 2 Complete Complete Complete preparations for receiving the first module an site for Unit 2. Complete Complete Steam Generator Fabricator Notice to Contractor of Receipt of 1st Steam Generator Transition Cone Forging Unit 2 Complete Complete - - - - - Reactor Coolant Loop Pipe Fabricator Acceptance of Raw Material Unit 2 - Reactor Vessel Internals Fabricator Start Weld Neutron Shield Spacer Pads to Assembly Unit 2 - - - - — - - - - Provided by South Carolina Electric & Gas Company at the request of ORS 4 Unit 2 Due to schedule refinement and sequencing. BLRA Order No. 2010-12 and Docket No. 2012-203-E Revised Milestones Comparison VC Summer Units 2 and Exhibit GCJ-2 3 Docket No. ‘I Tracking. Descñption’ io Explanation Reactor Coolant Pump Fabricator Notice to Contractor of Manufacturing of Completion Unit 2 Complete Complete Reactor Coolant ioop Pipe Fabricator Notice to Contractor of Machining, Heat Treating & Non-Destructive Testing Completion Unit 2 Complete Complete Makeup Tank Fabricator Notice to Contractor of Satisfactory Completion of Hydrotest Unit 2 5/31/2011 9/30/2012 Complete Complete Control Rod Drive Mechanisms Fabricator to Start Procurement of Lang Lead Material Unit 3 Complete Complete Turbine Generator Fabricator Notice to Contractor Condenser Ready to Ship Unit 2 Complete Complete Start placement of mud mat for Unit 2 7/14/2011 6/29/2012 Steam Generator Fabricator Notice to Contractor of Receipt of 1st Steam Generator Tubing Unit 2 Complete Complete Pressurizer Fabricator Notice to Contractor of Welding of Upper and Intermediate Shells Completion Unit 2 Complete Complete Reactor Vessel Fabricator Notice to Contractor of Closure Head Cladding )letlon Unit 3 2/28/2012 10/3/2011 - Crane Fabricator Issue P0 for Main Hoist Drum and Wire Rope Units Unit 2 Due to vendor delays, CCL approval and schedule refinement and sequencing. Unit 2 CCL approval and additional fill concrete in the nuclear island. 6/30/2012 Unit 3 Due to schedule refinement and review. 8/24/2012 Unit 2 COL approval and additional fill concrete in the nuclear island. - -. - - - - - ,Begin Unit 2 first nuclear concrete placement Provided by South Carolina Electric & Gas Company at the request of ORS 5 BLRA Order No. 2010-12 and Docket No. 2012-203-E Revised Milestones Comparison VC Summer Units 2 and 3 hjbit GCJ-2 • --I MiteSIone’ptiUn Reactor Coolant Pump Fabricator Notice to Contractor of Statôr Core Completion Unit 2 - 71 Fabricator Start Fit and Welding of Core Shroud Assembly Unit 2 Complete Complete 72 Steam Generator Fabricator Notice to Contractor of Completion of 1st Steam Generator Tubing installation Unit 2 Complete Complete Reactor Coolant Loop Pipe Shipment of Equipment to Site Unit 2 12/31/2012 12/31/2012 Control Rod Drive Mechanism Ship Remainder of Equipment (Latch Assembly & Rod Travel Housing) to Head Supplier Unit 2 12/31/2011 Pressurizer Fabricator Notice to Contractor of Welding of Lower Shell to Bottom Head Completion Unit 2 Complete Steam Generator Fabricator Notice to Contractor of Completion of 2nd Steam Generator Tubing Installation- Unit 2 61 30/2011 77 Design Finalization Payment 14 Complete 18 Set module CAO4 for Unit 2 1/27/2012 11/6/2012 7 Passive Residual Heat Removal Heat Exchanger Fabricator Notice to Contractor of Final Post Weld Heat Treatment Unit 2 Complete Complete Passive Residual Heat Removal Heat Exchanger Fabricator Notice to Contractor of Completion of Tubing Unit 2 1/31/2011 5/31/2012 Polar Crane Fabricator Notice to Contractor of Girder Fabrication Completion Unit 2 2/28/2012 - 73 - - Unit 2 On schedule. Unit 2 Due to delay in predecessor schedule activities. Unit 2 This milestone completed in May 2012. Unit 2 COL approval, additional till concrete in the nuclear island, and schedule sequencing and detailing. Unit 2 This milestone completed in May 2012. Unit 2 Due to schedule refinement and review. - - 75 6/30/2012 Complete - 76 5/31/2012 Complete - 80 - 81 - Provided by South Carolina Electric & Gas Company at the request of ORS 6 10/31/2012 ___ BLRA Order No. 2010-12 and Docket No, 2012-203-E Revised Milestones Comparison Exhibit GCJ-2 VC Summer Units 2 and 3 Docket No. Order No. 2012-203-E eitoneOescrIp 2010-12 Revised Unit Explanation Date Turbine Generator Fabricator Notice to Contractor Condenser Ready to Ship Unit 3 8/31/2013 - 83 Set Containment Vessel ring #1 tot Unit 2 4/3/2012 Completion 8/31/2013 1/7/2013 Unit 3 On schedule. Unit 2 COL approval, additional fill concrete in the nuclear island, and schedule sequencing and detailing. Unit 2 Due to schedule refinement and review. Unit 3 On schedule. Reactor Coolant Pump Fabricator Delivery of Casings to Port of Export Unit 2 3/31/2012 Reactor Coolant Pump Fabricator Notice to Contractor of Stator Core Completion Unit 3 8/31/2013 Reactor Vessel Fabricator Notice to Contractor of Receipt of Core Shell Forging Unit 3 Complete Complete 87 Contractor Notified that Pressurizer Fabricator Performed Cladding on Bottom Head Unit 3 Complete Complete 88 Set Nuclear island structural module CAO3 for Unit 2 8/30/2012 6/26/2013 Unit 2 COL approval, additional fill concrete in the nuclear island, and schedule sequencing and detailing. 89 Squib Valve Fabricator Notice to Contractor of Completion of Assembly and Test for Squib Valve Hardware Unit 2 5/31/2012 5/31/2012 Unit 2 On schedule. 90 Accumulator Tank Fabricator Notice to Contractor of Satisfactory Completion of Hydrotest- Unit 3 12/31/2012 3/31/2013 Unit 3 Due to schedule refinement and review. 91 Polar Crane Fabricator Notice to Contractor of Electric Panel Assembly Completion Unit 2 7/31/2012 Unit 2 Due to schedule refinement and review. Unit 2 COL approval, additional fill concrete in the nuclear island, and schedule sequencing and detailing. 84 85 86 - 7/31/2012 8/31/2013 - - 2 Start containment large bore pipe supports for Unit 2 4/9/2012 Provided by South Carolina Electric & Gas Company at the request of ORS 7 3/31/2013 6/28/2013 BLRA Order No. 2010-12 and Docket No. 2012-203-E Revised Milestones Comparison VC Summer Units 2 and 3 Integrated Head Package Shipment of Equipment to Sfte Unit 2 10/31/2012 Reactor Coolant Pump Fabricator Notice to Contractor of Final Stator Assembly Completion Unit 2 11/30/2012 - 94 95 - Unit 2 Due to delay in predecessor schedule activities. Steam Generator Fabricator Notice to Contractor of Completion of 2nd Steam Generator Tubing Installation Unit 3 5/31/2013 6/30/2013 Unit 3 Due to schedule refinement and review. Steam Generator Fabricator Notice to Contractor of Satisfactory Completion of 1st Steam Generator Hydrotest Unit 2 5/31/2012 1/31/2013 Unit 2 Due to COL approval and schedule refinement and suencing. - 96 Due to schedule refinement and revew. 3/31/2013 5/31/2013 Exhibit GCJ-2 - 97 Start concrete fill of Nuclear Island structural modules CAO1 and CAO2 for Unit 2 2/26/2013 4/3/2014 Unit 2 COL approval, additional fill concrete in the nuclear island, and schedule sequencing and detailing. 98 Passive Residual Heat Removal Heat Exchanger Delivery of Equipment to Port of Entry Unit 2 4/30/2012 12/31/2012 Unit 2 Due to schedule refinement and sequencing. Refueling Machine Fabricator Notice to Contractor of Satisfactory Completion of Factory Acceptance Test Unit 2 2/28/2013 11/30/2013 Unit 2 Due to delay in predecessor schedule activities. Deliver Reactor Vessel Internals to Port of Export Unit 2 7/31/2013 1/31/2014 Unit 2 Due to schedule refinement and sequencing. - - 100 - 101 Set Unit 2 Containment Vessel 3 4/17/2013 4/24/2014 Unit 2 COL approval, additional fill concrete in the nuclear island, and schedule sequencing and detailing. 102 Steam Generator Contractor Acceptance of Equipment at Port of EntryUnit 2 3/31/2013 7/31/2013 Unit 2 Due to schedule refinement and review. 103 Turbine Generator Fabricator Notice to Contractor Turbine Generator Ready toShip-Unit2 4/30/2013 4/30/2013 Unit 2 On schedule. - Provided by South Carolina Electric & Gas Company at the request of ORS 8 BLRA Order No. 2010-12 and Docket No. 2012-203-E Revised Milestones Comparison VC Summer Units 2 and 3 104 Pressurizer Fabricator Notice to Contractor of Satisfactory Completion of Hydrotest Unit 3 2/28/2014 Polar Crane Shipment of Equipment to Site Unit 2 5/31/2013 * 105 106 Receive Unit 2 Reactor Vessel on site from fabricator 107 Set Unit 2 Reactor Vessel 108 Steam Generator Fabricator Notice to Contractor of Completion of 2nd Channel Head to Tubesheet Assembly Welding Unit 3 12/31/2013 Reactor Coolant Pump Fabricator Notice to Contractor of Final Stator Assembly Completion Unit 3 8/31/2014 Reactor Coolant Pump Shipment of Equipment to Site (2 Reactor Coolant Pumps) Unit 2 9/30/2013 5/20/2013 6/18/2013 - 109 - 110 3/31/2014 1/31/2014 5/13/2014 6/23/2014 12/31/2013 8/31/2014 Unit 3 Due to schedule refinement and sequencing. Unit 2 Due to schedule refinement and sequencing. Unit 2 CCL approval, additional fill concrete in the nudear island, and schedule sequencing and detailing. Unit 2 CCL approval, additional fill concrete in the nudear island, and schedule sequencing and detailing. Unit 3 On schedule. Unit 3 On schedule. Unit 2 Due to schedule refinement and review. Unit 3 The Unit 3 FNC was offset by 14 months from the Unit 2 FNC per agreement between SCE&G & Consortium. Unit 2 COL approval, additional fill concrete in the nuclear island, and schedule sequencing and detailing. Unit 2 On schedule. Unit 3 On schedule. - - 10/31/2013 111 Place first nuclear concrete for Unit 3 8/1/2013 10/9/2013 112 Set Unit 2 Steam Generator 9/9/2013 10/23/2014 113 Main Transformers Ready to Ship Unit 2 9/30/2013 114 Complete Unit 3 Steam Generator Hydrotest at fabricator 2/28/2014 Provided by South Carolina Electric & Gas Company at the request of ORS 9 9/30/2013 2/28/2014 Exhibit GCJ-2 BLRA Order No. 2010-12 and Docket No. 2012-203-E Revised Milestones Comparison VC Summer Units 2 and 3 Order No. 2010-12 Date Docket No. 2012-203-E Revised Completion I-. tak.ñg Milestone Descnption 115 Set Unit 2 Containment Vessel Bottom Head on basemat legs 11/21/2011 10/11/2012 116 Set Unit 2 Pressurizer Vessel 1/24/2014 5/16/20 14 117 Reactor Coolant Pump Fabricator Notice to Contractor of Satisfactory Completion of Factory Acceptance Test Unit 3 2/28/2015 Deliver Reactor Vessel Internals to Port of Export Unit 3 6/30/2015 Main Transformers Fabricator Issue P0 for Material Unit 3 4/30/2014 - 118 119 — - 120 Complete welding of Unit 2 Passive Residual Heat Removal System piping 3/19/2014 121 Steam Generator Contractor Acceptance of Equipment at Port of Entry Unit 4/30/2015 - 122 Refueling Machine Shipment of Equipment to Site Unit 3 123 Set Unit 2 Polar Crane - - 5/31/2014 - 4/3/2014 124 Reactor Coolant Pumps Shipment of Equipment to Site- Unit 3 6/30/2015 125 Main Transformers Ready to Ship Unit 3 9/30/2014 - - Provided by South Carolina Electric & Gas Company at the request of ORS 10 2/28/2015 6/30/2015 2/28/2015 2/5/2015 4/30/2015 2/28/2015 1/9/2015 6/30/2015 7/31/2015 Exhibit GCJ-2 -. Unit Explanation Unit 2 COL approval, additional 1111 concrete in the nuclear island, and schedule sequencing and detailing. Unit 2 COL approval, additional fill concrete in the nuclear island, and schedule sequencing and detailing. Unit 3 On schedule. Unit 3 On schedule. Unit 3 Due to schedule refinement and review. Unit 2 COL approval, additional fill concrete in the nuclear island, and schedule sequencing and detailing. Unit 3 On schedule. Unit 3 Due to schedule refinement and review. Unit 2 COL approval, additional fill concrete in the nuclear island, and schedule sequencing and detailing. Unit 3 On schedule. Unit 3 Due to schedule refinement and review. BLRA Order No. 2010-12 and Docket No. 2012-203-E Revised Milestones Comparison 126 127 Spent Fuel Storage Rack- Shipment of last Rack Module Unit 3 12/31/2014 - Start electrical cable pulling In Unit 2 AuxilIary Building 12/26/2014 7/31/2014 8/14/2013 Exhibit GCJ-2 Unit 3 Due to schedule refinement and review. Unit 2 COL approval, additional fill concreted for nuclear island and schedule sequencing and detailing. 128 Complete Unit 2 Reactor Coolant System cold hydro 8/3)2015 1/22/2016 Unit 2 COL approval, additional till concreted for nuclear island, additional duration for Shield Bldg construction, and schedule sequencing and detailing. 129 Activate class IE DC power in Unit 2 Auxilary Building. 3/5/2015 3/15/2015 Unit 2 COL approval, additional fill concreted for nuclear island and schedule sequencing and detailing. Unit 2 COL approval, additional fill concreted for nuclear island, additional duration for Shield Bldg construction, and schedule sequencing and detailing. Unit 3 Schedule sequencing and detailing. Unit 2 COL approval, additional fill concreted for nuclear island, additional duration for Shield Bldg construction, and schedule sequencing and detailing. 130 Complete Unit 2 hot functional test. 9/21/2015 5/3/2016 __________ ___ 131 132 Install Unit 3 ring 3 for contamment vessel 7/30/2015 load Unit 2 nuclear fuel 10/28/2015 Provided by South Carolina Electric & Gas Company at the request of ORS 11 8/25/2015 9/15/2016 BLRA Order No. 2010-12 and Docket No. 2012-203-E Revised Milestones Comparison Exhibit VC Summer Units 2 and GCJ-2 3 OrdèrNO. 2010.12 Docket No. 2012-203-E Revised Date Completion I. Un, 133 Unit 2 Substantial Completion 4/1/2016 3/15/2017 Unit 2 COL approval, additional fill concreted for nuclear island, additional duration for Shield Bldg construction, and schedule sequencing and detailing. 134 Set Unit 3 Reactor Vessel 10/1/2015 10/22/2015 Unit 3 Schedule sequencing and detailing. 135 Set Unit 3 12/22/2015 2/25/2016 Unit 3 Schedule sequencing and detailing. 136 Set Unit 3 Pressurizer Vessel 5/16/2016 7/16/2015 Unit 3 Schedule sequencing, detailing and compression. 137 Complete welding of Unit 3 Passive Residual Heat Removal System piping 6/20/2016 6/16/2016 Unit 3 Schedule sequencing and detailing. 138 Set Unit 3 polar crane 7/18/2016 5/9/2016 Unit 3 Schedule sequencing, detailing and compression. 139 Start Unit 3 Shield Building roof slab rebar placement 1/16/2017 5/26/2016 Unit 3 Schedule sequencing, detailing and compression. 140 Start Unit 3 Unit 3 Schedule sequencing and detailing. Steam Generator 412 Auxiliary Building electrical cable pulling 4/6/2017 11/7/2014 *_________ __ 3 Auxiliary Budding class IE DC 141 Activate Unit 142 Complete Unit 3 power Reactor Coolant System cold hydro Provided by South Carolina Electric & Gas Company at the request of ORS 12 6/9/2017 5/15/2016 Unit 3 Unit 3 substantial completion 14 months after Unit 2 substantial completion. 1/1/2018 3/22/2017 Unit 3 Unit 3 substantial completion 14 months after Unit 2 substantial completion. BLRA Order No. 2010-12 and Docket No. 2012-203-E Revised Milestones Comparison VC Summer Units 2 and 3 Exhibit GCJ-2 Unit 3 substantial completion 14 months after Unit 2 substantial completion. Complete Unit 3 hot functional test 2/15/2018 144 Complete Unit 3 nuclear fuel load 7/31/2018 11/15/2017 Unit 3 Unit 3 substantial completion 14 months after Unit 2 substantial completion. 145 Begin Unit 3 full power operation 10/31/2018 4/8/2018 Unit 3 Unit 3 substantial completion 14 months after Unit 2 substantial completion. 146 Unit 3 Substantial Completion 1/1/2019 5/15/2018 Unit 3 Unit 3 substantial completion 14 months after Unit 2 substantial completion. Provided by South Carolina Electric & Gas Company at the request of ORS 13