Nuclear Power Plant Decommissioning

Brief

The owner of a nuclear generating station was forced to retire the plant prematurely and permanently due to several defective steam generators. Following the unexpected retirement, the owner began the decommissioning planning process for the station.

The decommissioning of a nuclear power plant is a complex and costly process that involves the decontamination and dismantlement of plant structures and systems, management of spent nuclear fuel, disposition of low-level radiological waste, and restoration of the plant site. The decommissioning of commercial nuclear power plants in the United States is principally regulated by the Nuclear Regulatory Commission (NRC), often with cost oversight by the state public utility commission.

What we did

HKA assisted with financial analysis, “pre-mortem” project evaluation and analysis, project controls, vendor procurement, and regulatory support throughout the decommissioning of the nuclear generating station.

• Strategic Financial Analysis. Evaluated the costs/benefits of alternative decommissioning strategies (i.e., SAFSTOR vs. Prompt DECON) and various decommissioning projects, such as “islanding” the spent fuel pool. As part of these efforts, HKA personnel prepared financial analysis and presentations for executive and senior management review and decision making.
• Project Evaluation & Analysis. Identified, organised, and reviewed key contemporaneous project documents and performed necessary interviews of project personnel pertaining to major decommissioning decisions, subprojects, or other work scopes. HKA personnel identified and investigated potential issues and challenges and subsequently developed, vetted, and memorialised their resolution with project personnel. Final work product was packaged to assist with responding to future inquiries or investigations initiated by the state public utility commission, intervenors, or other stakeholders.
• Project Controls. Worked with plant finance personnel to implement a new Decommissioning Project Control System to track decommissioning costs and assisted in developing a project controls dashboard/standardized report to meet the needs of senior management and other stakeholders (e.g., plant co-owners). The implementation enables the owner to efficiently reconcile costs and annual cash flows to its Decommissioning Cost Estimate (DCE), which was formally approved by the state public utility commission.
• Vendor Procurement. Assisted in the procurement of certain decommissioning services (e.g., decommissioning general contractor, dry fuel storage vendor) by assisting with development of the requests for proposal (RFPs), preparing and responding to requests for additional information (RAIs), and the review and analysis of vendor bids.
• Regulatory Support. Assisted with preparation of testimony and financial analyses related to various state public utility commission proceedings, including General Rate Case (GRC), Order Instituting an Investigation (OII), Nuclear Decommissioning Cost Triennial Proceeding (NDCTP), and special purpose cost reasonableness reviews. Worked with the owner’s personnel and intervenors to develop a process and framework for performing future prudence reviews.

Outcomes

Although the project is ongoing, DCEs and incurred costs and schedule delay to date have been approved by the state public utility commission (i.e., no significant disallowances, resulting in virtually 100% recovery of decommissioning costs from customers).