Link to the study - European Parliament - Europa
Link to the study - European Parliament - Europa Link to the study - European Parliament - Europa
Policy Department D: Budgetary Affairs ____________________________________________________________________________________________ 3.4.5. Regulatory approach Requirements German nuclear regulation, as applicable for the EWN project, consists of different levels. In respect to decommissioning the following framework is relevant 11 : The phase between shutdown and issuance of the decommissioning permit is regulated as ongoing operation (post-operational phase). Removal, deconstruction or alternative use of items that are not relevant for safety is possible and requires the consent of the supervising regulator. The operator’s overall plan for decommissioning describes the deconstruction phases, the necessary means and tools and the measures that are foreseen to guarantee the safety of the public and of the workers. With these documents, together with the environmental impact study, the operator applies for a permit. Additional underlying documents might be necessary. If the regulator’s review of these documents ends with a positive finding, the permit is granted (general decommissioning license). The decommissioning permit spans all phases of the project, usually adds further license conditions and is not time-limited. During decommissioning the operator designs, plans and describes sub-projects or work packages that detail and substantiate the overall plan, in accordance with its general license. Depending upon practice, the operator has to seek regulatory consent with these plans or has to apply for formal approval of the supervising agency. The role of the (general) decommissioning license as an end to the operating license and as a basic permit to decommission the facility is illustrated in Figure 26. Figure 26: The decommissioning license under German regulation Source: Authors Specific to German regulatory practice is the continued regulatory oversight. It includes sub-project applications and approvals, on-site control (e.g. expert accompanied inspections, double checking, etc.), independent assessments (e.g. independent sampling, exemplary proof by second party). The necessary approval processes can be closely adapted to the decommissioning project’s phases and to their progress. 11 For a comprehensive description of the complete German regulatory framework see: BfS 2009 88
Nuclear Decommissioning: Management of Costs and Risks ____________________________________________________________________________________________ The formal approval processes (general license, approval for sub-projects, etc.) require additional time and resources and are associated with additional risks (time delays, forced plan changes, etc.) to the project. Project planning has to consider the necessary time and resources for those activities. To minimize those risks the applied regulatory approach shall be to seek consent already in early planning phases. Practice Necessary times to apply for and to achieve regulatory consent are included in the workflow model of the PMIS tool and are regularly updated. EWN seeks regulatory consent already in the conceptual stage of work package design and planning. This assures that the supervisory agency is able to voice its concerns already in an early phase and that the later approval of the agency to final plans and work packages requires no extensive times. 3.4.6. Cost estimates All cost estimates in the EWN decommissioning project were performed by use of the project management tool described in chapter 3.4.3. From the experiences in this case the tool provides reliable estimates. By application of correction factors experiences made during the first phase estimates were integrated and reliability increased. Figure 27 shows the overall cost development for the five Greifswald reactors. Figure 27: Costs of decommissioning the five Greifswald reactors Source: (EWN 2012a) As can be seen the cost contributions from the single sub-projects are very different. It further shows that the needs are very different over time. The initial phase, where large investments have to be made for equipment, waste management treatment and storage facilities, is the most cost-intensive. 89
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Nuclear Decommissioning: Management of Costs and Risks<br />
____________________________________________________________________________________________<br />
The formal approval processes (general license, approval for sub-projects, etc.) require additional<br />
time and resources and are associated with additional risks (time delays, forced plan changes, etc.) <strong>to</strong><br />
<strong>the</strong> project. Project planning has <strong>to</strong> consider <strong>the</strong> necessary time and resources for those activities. To<br />
minimize those risks <strong>the</strong> applied regula<strong>to</strong>ry approach shall be <strong>to</strong> seek consent already in early<br />
planning phases.<br />
Practice<br />
Necessary times <strong>to</strong> apply for and <strong>to</strong> achieve regula<strong>to</strong>ry consent are included in <strong>the</strong> workflow model of<br />
<strong>the</strong> PMIS <strong>to</strong>ol and are regularly updated.<br />
EWN seeks regula<strong>to</strong>ry consent already in <strong>the</strong> conceptual stage of work package design and planning.<br />
This assures that <strong>the</strong> supervisory agency is able <strong>to</strong> voice its concerns already in an early phase and<br />
that <strong>the</strong> later approval of <strong>the</strong> agency <strong>to</strong> final plans and work packages requires no extensive times.<br />
3.4.6. Cost estimates<br />
All cost estimates in <strong>the</strong> EWN decommissioning project were performed by use of <strong>the</strong> project<br />
management <strong>to</strong>ol described in chapter 3.4.3. From <strong>the</strong> experiences in this case <strong>the</strong> <strong>to</strong>ol provides<br />
reliable estimates. By application of correction fac<strong>to</strong>rs experiences made during <strong>the</strong> first phase<br />
estimates were integrated and reliability increased.<br />
Figure 27 shows <strong>the</strong> overall cost development for <strong>the</strong> five Greifswald reac<strong>to</strong>rs.<br />
Figure 27: Costs of decommissioning <strong>the</strong> five Greifswald reac<strong>to</strong>rs<br />
Source: (EWN 2012a)<br />
As can be seen <strong>the</strong> cost contributions from <strong>the</strong> single sub-projects are very different. It fur<strong>the</strong>r shows<br />
that <strong>the</strong> needs are very different over time. The initial phase, where large investments have <strong>to</strong> be<br />
made for equipment, waste management treatment and s<strong>to</strong>rage facilities, is <strong>the</strong> most cost-intensive.<br />
89