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Policy Department D: Budgetary Affairs ____________________________________________________________________________________________ After issuance of decommissioning licence (and consecutive start of dismantling works) it is not possible from the legal and technical point of view to return to operation of the NPP. No organisational or political decision thus cannot further hinder the process, as there are strict deadlines imposed on JAVYS in the decommissioning licence and the NPP already lacks many essential components preventing its re-start. The financial planning within the project How and on which knowledge/estimate base are financial plans set up and updated? The cost estimates were always part of the relevant studies and/or decommissioning plans that have been prepared or reviewed by external competent bodies. JAVYS’ requirement was always to have them set based on the latest international experience and respective internationally accepted methodologies. The key documentation 'Conceptual decommissioning plan' was a result of the study performed by German-based Energiewerke Nord that had a long experience in decommissioning of similar power plant in Greifswald. The latter Decommissioning strategy was based on the Yellow book methodology and its latest revision is based on the latest fine-tuned Yellow book update - the International Structure of Decommissioning Costing that is a methodology prepared jointly by EC, IAEA and OECD- NEA (issued in 2012). The financial plan was based: - On estimated flow and contamination of material from similar Greifswald NPP. After Decommissioning database of the NPP V1 was elaborated, new tailor made figures were able to be introduced; - Decommissioning as a labour intensive industry was based on price level of salaries at the time of elaboration of the document, significant changes in the national political and economic system resulted in an update, increase of the respective cost estimate of decommissioning works. How is, from the view of the licence holder, the decision process organized (internal and external process, structure of checks, approvals, past experiences with the decision process)? The overall decision making process is much more complicated and more demanding than for example the decommissioning of the other NPP under JAVYS management, meaning NPP A1. The reason is the financial model set by the BIDSF fund’s administrator – the European Bank for Reconstruction and Development – and involvement of more stakeholders – European Commission, European Bank for Reconstruction and Development, Ministry of Economy and specific Project Management Unit (involving external Consultants). The process is more time consuming, needing more staff devoted to the management of the overall process and reporting tasks. In compliance with the Framework Agreement (Section 3) signed between the Slovak Government and the EBRD in 2001, Slovenské Elektrárne, a.s. and later JAVYS established the Project Management Unit ('PMU'). The PMU is composed of JAVYS experts and international Consultant staff. PMU is currently represented by internal organizational unit titled 'Division of Decommissioning and PMU', chaired by the vice-chairman of JAVYS’ Board of Directors. In order to manage the preparatory works and implementation phase of BIDSF projects, project teams for implementation of respective BIDSF projects were established within JAVYS. 168
Nuclear Decommissioning: Management of Costs and Risks ____________________________________________________________________________________________ BIDSF funding of projects requires that internal approval processes have to encompass also the roles of PMU Consultant and the EBRD. The role of the PMU Consultant is to elaborate certain technical documents and/or authorise technical (and tender) documents elaborated by JAVYS staff according to the Framework Agreement between EBRD and Slovak Republic. The role of the EBRD is, among other, to approve of technical and tender procedures by providing its 'no-objection' for all activities during respective phases of BIDSF projects` implementation. The decommissioning management system is focused on speed up and effectiveness of all activities, for which it uses: - daily meetings of project managers, - Integral Project Base Time Schedule 'IPBTS' (updated on weekly basis based on outcomes from the Weekly Internal meetings), - Weekly Internal meetings (attendees: JAVYS project managers, PMU Consultant, the EBRD representative), - Monthly Progress meeting (attendees: JAVYS management, PMU Consultant, the EBRD representative, representatives of Ministry of Economy and National Nuclear Fund), - Quarterly reports on status of BIDSF projects implementation (submitted to the General Directors` Meeting) External bodies in decommissioning decision making: a) Semi-annual on-site visits of EC (DG ENER) representatives in JAVYS (JAVYS reports on status of progress in BIDSF projects implementation), b) The Joint Committee Meeting submitting new BIDSF projects for granting (participants: the Ministry of Economy, the EBRD, the National Nuclear Fund, the Nuclear Regulatory Authority), c) The Assembly of Contributors of BIDSF fund approving grants for new BIDSF projects (participants: EC, donor states, EBRD, Ministry of Economy), d) Annual Nuclear Decommissioning Assistance Programme Meeting (organized by Energy section of the European Commission; held in Luxembourg ) Experience with decision processes: Documents prepared by JAVYS are being submitted to external bodies for their approval according to Slovak legislation. The authorities are bound to issue their licences and/or approvals within time limits set up in the Slovak legislation and JAVYS conservatively schedules the longest possible deliberation time period into its projects’ time schedule. Any necessity to provide further responses to possible additional queries by the authorities is also included in the time schedule. JAVYS also informs external bodies in advance before the final requests are submitted by JAVYS to these authorities for their final approval. Apart from legislation-bound approvals, there exists also second group of documents that are being approved (non-objected) by the EBRD, as the administrator of the BIDSF fund. Since the EBRD is not bound by any time limits for issuing their non-objection, this aspect represents external uncertainty in planning of decommissioning activities. 169
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