5. Recommendations
The Panel developed 12 recommendations for utilities to incorporate into future decommissioning cost estimates beginning with the 2012 NDCTPs. These recommendations follow verbatim below:34
1. Actual data should be used, where appropriate, as a basis for estimated costs. Actual data, however, should be reviewed to remove any embedded contingency and preclude unnecessary contingency.
2. Plant security should be involved with the development or review of the security assumptions and costs used in the decommissioning cost estimate, to ensure that the costs are appropriate for the projected security needs during decommissioning. This should not involve sharing of Safeguards35 information with estimators or the public.
3. The utilities should avail themselves of every opportunity to obtain volumetric contamination or activation data with which the decommissioning cost estimate contamination assumptions can be verified or modified. These opportunities are expected to include plant modifications and maintenance activities (similar to the recent steam generator replacements). Similarly, data from site monitoring should be used to confirm or adjust decommissioning assumptions. The results of these efforts should be reviewed in the NDCTPs and the effort adjusted depending upon the results. In addition, the utilities should follow industry activities with respect to hard-to-detect nuclides, including tritium and carbon 14, and update the estimates as additional industry knowledge and experience is gained.
4. The utilities should consider sharing decommissioning activity performance and cost data, where practical, and where the sharing does not violate confidentiality or concerns on commercially sensitive data. The data can also be provided in a form that protects those concerns, if practical.
5. The utilities should consider and use common assumptions where appropriate. The Panel suggests that these assumptions include:
a. DOE performance;
b. State requirements for severance payments;
c. State requirements for site restoration; and
d. Alternatives and pricing for LLRW burial.
6. The utilities should consider and agree on a Common Summary Format (Summary) for use in the next NDCTP that includes decommissioning cost estimate assumptions and results.
7. The Panel recommends that assumptions in the Summary be organized into categories, to include:
a. Common assumptions from recommendation 5;
b. Extent of site and building contamination; and
c. Low-level radioactive and hazardous waste anticipated to be present on site at the start of decommissioning.
8. The Panel recommends that results compared in the Summary include:
a. Craft and non-craft labor hours, total, and by period;
b. Security labor hours, total, and by period (non-safeguards);
c. Average craft, non-craft, and security labor rates;
d. LLRW handled, and removed from site;
e. Clean waste handled, and all waste removed from site; and
f. Major "activity" and "period" costs that are comparable between the estimates.
9. The Panel recommends that the Commission consider requesting that the next SONGS 2 and 3 cost estimate quantify the increased cost associated with the Navy lease above that required for site restoration comparable to that assumed in the Diablo Canyon estimate. The Panel understands that this effort may have considerable added cost.
10. The SCE adjustments to the PV estimate for waste volume should be reviewed and corrected, if submitted again.
11. The SCE adjustments to the PV estimate for large component removal, contingency, and spent nuclear fuel should be fully explained each time they are used.
12. The Panel has concluded that it is reasonable for PG&E and SCE to use different contingency values to reflect the different risks faced at both sites, and that the values used for both estimates are not unreasonable.
34 Final Report at 46-47.
35 NRC prohibits disclosure of security information categorized as "Safeguards."
