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Policy Department D: Budgetary Affairs ____________________________________________________________________________________________ Regulatory aspects (Continued) Have you encountered difficulties caused by regulatory action so far in your project (major delays, necessary re-planning caused by regulation, difficulties in finding common understanding)? If so: what were the reasons for that in your view (incompetence, unwillingness, misunderstandings, etc.) Are the different roles of you as the operator and the regulatory body clear for you (does the regulatory body remain in its own role, would you expect more assistance, etc.)? In which fields could the regulatory body ease your planning, technical and financial structures (should there be more detailed regulation, should there be more written regulation, etc.)? Is it difficult for you to understand the regulatory issues? How would you evaluate your relationship with the regulatory body (cautious, trustfully, distantly, frustrating)? 146
Nuclear Decommissioning: Management of Costs and Risks ____________________________________________________________________________________________________________ ANNEX 3 - WRITTEN ANSWERS FROM BULGARIA Conceptual planning within the project: The overall plan of the project, it’s major packages, it’s serial flow etc. The content of the Plan for the decommissioning of Units 1 and 2 of Kozloduy NPP is developed in accordance with: The requirements of Art. 59 of the Regulation for the procedure for issuing licenses and permits for safe use of nuclear energy; The requirements of the BNRA in the Manual РР-2/2010; The IAEA instructions, in 'Standard Format and Content for Safety Related Decommissioning Documents', SRS No 45. The Plan contains 24 chapters. The Work Breakdown Structure for the preparation and the implementation of the decommissioning process contains the main structural components of the transition from units operation to their decommissioning and dismantling. It is developed according to 'International Structure for Decommissioning Costing (ISDC) of Nuclear Installations (NEA7088, OECD 2012)'. The first level of the Work Breakdown Structure includes the following key phases: 01 Preparation for decommissioning activities; 02 End of operation activities; 03 Supply of equipment and materials; 04 Dismantling activities; 05 RAM and RAW treatment and disposal; 06 Site management and maintenance; 07 Project management and engineering; 08 SF and nuclear material management. 147
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