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Policy Department D: Budgetary Affairs ____________________________________________________________________________________________ Figure 41: Process for achieving the license for stage I in Slovakia Source: (JAVYS 2013) The listed durations were comparatively short, which lets assume that the process is well-designed and the bilateral understanding is good. On the other side, the splitting of licenses in such short periods includes the risk that the process might require longer periods than previously expected. This might be especially the case with later stages because those include work in radiologically controlled areas, the handling of materials under elevated doses, the decision over materials with higher contamination and more sophisticated waste management decisions. In short, the experiences made with the regulatory approach were good, but the staged process in the future bears risks so that caution should be included to address possible bottlenecks. 4.6.2. Comparison and evaluation of the regulatory approach In the two best practices the regulatory approach was recognized as central. The necessary permit applications require time as well as a mutual consent between the operator and the regulatory body. It has to be seen here that the relevant guiding documents, governing requirements for decommissioning and waste acceptance, still are in progress or are only recently issued. The staged processes with time-limited duration of licenses have risks that the necessary licensing of the next stage may interfere with a smooth and continuous decommissioning. That has to be accounted for in the risk assessment. All three countries describe their relationship with the regulatory body as 'good' and based on continuous discussions already in the pre-planning stage. 4.6.3. Recommendations for the regulatory approach Licensing issues should be carefully considered within the risk assessment and should not be underestimated, because failures and delays in this field can have major consequences for the 118
Nuclear Decommissioning: Management of Costs and Risks ____________________________________________________________________________________________ decommissioning process. The good practice identified so far should be continued and upgraded to match to the upcoming more sensitive worksteps. 4.7. COST ESTIMATES Cost planning is a fundamental requirement for any project. Without a transparent and as detailed as possible (at a certain project stage) cost planning it is not possible to obtain financing of a decommissioning project. And without secured financing it is not possible to perform a project. At the same time the cost planning is the basis for the cost controlling of the project. Cost planning is only reliable if it is based on: A detailed planning, identifying all steps to be made; Inventory data for masses and contamination; A thorough risk evaluation. 4.7.1. Cost estimates of the decommissioning projects Bulgaria Bulgaria performs cost estimates on the basis of (see ANNEX 3) A detailed work plan (work breakdown structure); Underlying sub-tasks on the second level; Estimated labor costs; investment costs; operating costs and incidental costs for those activities. Bulgaria applies the cost estimation standards as recommended in (NEA 2013), which are based on an explicit project management approach. 38 % of the total costs are labor costs (ANNEX 3). The most influence on changes to the cost estimates are seen with adjustments of the work schedule. The differences between previous cost estimates and the actual costs are seen as follows: 'The main reasons for the divergence in the forecast cost appraisals and the real ones are due to the changes made in the initial schedule and in the terms for implementation of the main activities, ensuring the implementation of the Decommissioning plan for Units 1-4.' (ANNEX 3, page 151) This has to be seen on the background of the delays in four projects for waste treatment facilities (ANNEX 3, page 150). The risk that further delays occur, delaying work on critical pathes, can increase costs further. This points to the already discussed weaknesses of the project management organisation (see chapters 4.5.2 and 4.5.3). 119
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