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Policy Department D: Budgetary Affairs ____________________________________________________________________________________________ The management selects and controls external consultants that send their experts to work with the managing organisation (either with the management or the work level, whatever appropriate for the task). The PMU is fully integrated into the managing organisation level, defined and controlled by its management. The managing organisation’s budget control issues are a task of the national administration (source 1, the institution responsible for national fund control) as well as of EBRD (source 2, control on behalf of the EC budget contribution) and serves as control of the due diligence. Improvements of the management in the three countries are still possible. This involves on the one side to strengthen the management’s role as a planner of strategic decisions (see chapter 2.4.3), but on the other side also to hold management responsible for any failures, for perceiving/evaluating/communicating risks and for consistently controlling work planning and work progress. In order to strengthen the role of the management a clear definition of its tasks should be established. One of the tasks should involve the complete internal control of the work progress, to be reported using meaningful and significant indicators to the supervising organisations. The management and its control institutions, not any outside institutions, should be held responsible for all aspects that involve control over the decommissioning process. 4.5. PROJECT AND RISK MANAGEMENT As described in chapters 3.4.3 and 3.4.4 project and risk management should govern the whole planning process of the decommissioning project. This chapter identifies the approaches in the three countries and compares them with the best practice. 4.5.1. Project and risk management approach in the decommissioning projects Bulgaria ANNEX 3, page 150, lists several examples of projects and their delay. Among them are well foreseeable reasons for delays that can well be expected and should be detected with a functioning systematic project and risk management approach. E.g. the time that was required for unloading the pools was underestimated by the consultant group. The described reasons (delay in finishing the external storage facility through detection of unsuitable underground conditions and delayed cask delivery) point to underestimated risks that were not correctly evaluated. The condition of the underground of a site for a facility must well be known if the planning involves state-of-the-art foundation ground examination as part of the site identification, site selection and evaluation process. So risks of this kind are foreseeable, if the planning is following rules that allow for early risk identification. The example shows that project and risk management are still to be vastly improved. The responsible decommissioning organisation has to take control over all relevant issues and has to have the 112
Nuclear Decommissioning: Management of Costs and Risks ____________________________________________________________________________________________ capability and the necessary skills to independently check the work of consultants, namely that of external members of the PMU. It points to a deficient management understanding to uncritically take over inadequate estimates that an external consultant provides (see chapters 4.4.2 and 4.4.3). Lithuania The necessity to introduce project and risk management at INPP has been recognized (see ANNEX 4, page 159). The stepwise introduction of respective project management tools and their later extension to manage risks are foreseen, but still require time and support. Slovakia The overall project planning did not take place within the first years of decommissioning project. Several 'small' projects were planned without any long term project concept that would include risk management. The originally introduced decision making process has spread the decommissioning in many subprojects and is more complicated and more demanding in comparison with the aforementioned decommissioning of the other NPP under JAVYS management, meaning NPP A1. The reason is the financial model set by the Bohunice International Decommissioning Support Fund BIDSF, where many stakeholders are involved into the decision making, but the responsibilities and hierarchies are not clearly defined. The involved stakeholders are: European Commission, European Bank for Reconstruction and Development (EBRD), Ministry of Economy and a specific PMU (involving external consultants). The process is time consuming and needs a lot of staff (see ANNEX 5). The decision making about the financing of several projects has been organized in the following way (JAVYS 2013). An evaluation procedure was introduced that was based on EBRD Procurement policies, FIDIC international standards and World Bank Procurement Guidelines.as well as JAVYS. Firstly, the cheapest tenders have been considered: This approach allows to contract a company which offered a price lower than the allocated Grant from the BIDSF resources. Saved funds are transferred back to BIDSF and are used again for awaiting decommissioning projects. By saving money from BIDSF resources JAVYS effectively and responsibly takes an advantage of EU financial assistance. Each decision taken by JAVYS in the field of procurement and contract management must be approved by EBRD through its 'No-Objection'. As the license NRA SR defined organisational requirements to obtain the license, the first steps towards implementing an overall long term decommissioning plan with project and risk management were started. Within the aforementioned organisational requirements to obtain the license (in 2011), personnel trainings had to be introduced. For this reason, off-site trainings took place that also involved a risk 113
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