3. The Panel's Work

After its initial organization, the Panel began its work by defining its scope and developing a work plan. The Panel decided to use public information and data wherever practical in order to achieve the Commission's goal of a fully public report. In addition, the Panel agreed to regular weekly conference calls, assignment of tasks, and mechanisms for sharing data.

In its first monthly status report in September 2010, the Panel described its initial tasks as follows:

· Building agreement on the scope of each of the six tasks specified in the D.10-07-047;

· Developing and issuing a comprehensive data request to the utilities;

· Identification and accumulation of decommissioning cost information from US nuclear plants outside California; and

· Begin development of the list of issues to be researched and compared for the decommissioning cost estimates.

In October 2010, the Panel met to discuss assigned tasks and anticipated future actions. For example, their comparison of the cost estimates for Diablo Canyon and SONGS units resulted in a draft list of issues with quantification of the cost differences. The Panel also identified issues for comparison with non-CA plants given that less information would be available for analysis.

Other work included (1) identification of background issues that needed explanation to support the comparisons between California plants and between California plants and non-California plants, (2) development of a preliminary list of common assumptions to be applied to cost estimates, and (3) identification of additional information needed regarding SCE's adjustments to the site estimate for Palo Verde. The Panel also initiated plans for working visits to each nuclear plant site and interviews with site personnel.

In November 2010, the Panel reported that it had completed (1) the preliminary categorization and quantification of differences between the California sites (Diablo Canyon and SONGS 2&3), (2) an initial evaluation of SCE's adjustments to the Palo Verde cost estimate, (3) a preliminary comparison of non-California decommissioning costs with Diablo Canyon, SONGS and Palo Verde, and (4) collection and organization of data for comparison of historical decommissioning projected costs compared with actual experience. The Panel also made progress on identifying and characterizing decommissioning background issues to support the Panel's recommendations for common assumptions, common formats, emerging radiological issues and measures to minimize future decommissioning costs.

During December 2010, the Panel completed site visits to SONGS, Diablo Canyon, and Palo Verde and conducted extensive interviews with utility personnel. ALJ Darling accompanied the Panel members during the site visits to Diablo Canyon and SONGS. In January 2011, the Panel completed its data analysis, produced a rough draft of the report, and presented the draft to the Commission staff and parties at the January 25, 2011 status conference. Following the status conference, the Panel received numerous comments from parties about the draft report.

PG&E sought clarification about access to confidential materials, particularly related to security, potential cost mitigation actions by operating utilities, and assumptions about the United States Department of Energy (DOE) performance on its obligations for disposal of greater than Class C radiological waste. The company also sought some terminology changes and consideration of local regulatory requirements for site restoration.

SCE's comments focused on questions related to comparability of cost estimates for other nuclear power plants, inside and outside California. In particular, SCE suggested incorporation of recent industry experience with cost models and actual data, and queried whether future decommissioning cost estimates could more closely reflect the manner, cost, and schedule in which a decommissioning project will likely be implemented. Other comments included a request that the Panel explicitly address the Navy lease requirements and a claim that potential license renewal would only increase costs related to the dry cask storage of spent nuclear fuel, known as "ISFSI."

TURN asked a series of questions on the issues of (1) the impact of the SONGS land lease with the United States Navy (Navy) on site restoration costs, (2) the adjustments by SCE to the cost estimate developed for Palo Verde by its primary owner, (3) sources, types, and cost impact of radiological contamination, and (4) the cost impact of potential 20-year renewal of plant operating licenses.

Energy Division suggested the Panel recommend that SCE re-negotiate its lease with the Navy, and for all utilities to reconsider the assumption of a 12 year cooling period for spent fuel, particularly whether more effective fuel management could help lower costs. Finally, Energy Division also asked the Panel to discuss the impact of possible NRC license renewals for SONGS and Diablo Canyon.

The Panel circulated a draft of the report in February before the final briefing of the Commission and parties. The Commission's Energy Division and SCE submitted additional comments to the Panel, which focused on enhancing the clarity of the Report and better informing the reader.

The Final Report was submitted unanimously by the Panel members on March 1, 2011. In Appendices G and H to the Final Report, the Panel provided responses to all the comments it received during the process. Some comments raised issues which are addressed in the Final Report, others were viewed by the Panel as beyond the scope of the assigned work.