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 ____________________________________________________________________________________________ management training in Lyon and risk analysis training offered by EDF-CIDEN respectively took place. The first step towards more comprehensive decommissioning planning was taken in 2007 when the so called 'Conceptual decommissioning plan' (in further text 'decommissioning plan') was developed that comprises of two main decommissioning stages. According that, the decommissioning activities should be completed in 2025 (ANNEX 5). The 1 st stage of the decommissioning was started in 2011 and the 2 nd stage shall start in 2015 according to the decommissioning plan. Subsequently, as described in 'Combined Programming Document – Bohunice Programme' (CPD 2012) (also see ANNEX 5), several tasks/projects and their objectives were defined that are co-financed within the EU assistance. According to the status in 2012, the project 'Management and preparation of decommissioning activities' has been implemented. The objective is to ensure the effective project management in compliance with western management methodologies. Among other things, the international standards in the quality management, risk management, interface management, scheduling and costs calculation should be implemented. As support it was proposed to contract a consultant to provide JAVYS with expertise or to cooperate with JAVYS. 4.5.2. Comparison and evaluation of the project and risk management with best practice All three investigated cases point to serious deficiencies in the understanding of management, responsibilities and decision processes. A consultant group or an external PMU consultant can never take over responsibilities for failures or mal-planning of processes, because his work has principally to be independently checked by the management of the managing organisation, corrected or upgraded if necessary, and finally adopted by the finally responsible management (and its control institution). It then is the management’s (and its control institutions) failure to accept inadequate planning or consultant work. This misperception in the current understanding of management duties and responsibilities and their control has already been discussed in chapter 4.4.3. Project management which is performed isolated in a PMU unit instead of being integrated into the whole organisation cannot work properly. INPP has clearly recognized that and now tries to integrate this as a holistic approach. Compared to best practice this has to be evaluated as being in an 'early stage of implementation'. Bulgaria and Slovakia are on that way, too, but 'responsibility sharing' between the management, its national administration institution, external consultants and EBRD still is an issue. 4.5.3. Recommendations for project and risk management A complete and adequate project and risk management, including the respective task-tailored IT tools (PMIS), for the decommissioning project has to be considered a state-of-the-art requirement. Improving, completing and fully implementing project and risk management should be given highest priority. Management should set up respective work methods and tools, the controlling institutions should supervise their design and timely implementation in the managing process. 114
Nuclear Decommissioning: Management of Costs and Risks ____________________________________________________________________________________________ 4.6. REGULATORY APPROACH The identification of best practices has shown that decommissioning requires: An overall permit procedure on a more general base; Close supervision and regulatory procedures to decide on the sub-project level; Close communication of plans in early stages; Integration of licensing milestones and regulatory approval times in the overall project plan. Failures to achieve these objectives can cause serious delays and additional costs. 4.6.1. Regulatory approach in the decommissioning projects Bulgaria Bulgaria’s regulatory agency BNRA has regulated the safety aspects of decommissioning already in 2004, mainly dealing with the issue of still needed safety systems (BNRA 2004). The requirements for achieving a decommissioning license were later regulated, as Safety Guide (BNRA 2010). DP RAO applied in 2012 for this license: 'In June 2012 SD RAW submitted applications to NRA for issuance of licenses for decommissioning of Unit 1 and Unit 2 of Kozloduy NPP. As a result of the review of the enclosed documents, it was assessed that a part of the presented documents need further development, in order to satisfy the legislative requirements for justification of main activities upon decommissioning.' (BNRA 2012) Also still pending is the regulation for wastes and for releasing wastes from regulatory control (ANNEX 3, page 156). The relationships between the operator and the regulatory body are described in ANNEX 3 as 'clear, well regulated' and 'based on mutual confidence'. Lithuania The Lithuanian regulatory body VATESI has issued its regulation on decommissioning in 1999 (VATESI 1999). In accordance with respective international safety requirements in IAEA 1999 this regulation called for a decommissioning plan for the facility, to be updated every three years. The current plan was provided for regulatory approval last year: 'In 2012, the updated Final Decommissioning Plan of Ignalina NPP was submitted for review by VATESI. Ignalina NPP is planning to revise the plan and to resubmit it for review by VATESI in 2013.' (VATESI 2012) The regulatory framework of the decommissioning project is seen by the regulatory body in a seven stage process, completely depending from the fuel unloading process, see Figure 38. 115
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Policy Department D: Budgetary Affairs<br />
____________________________________________________________________________________________<br />
management training in Lyon and risk analysis training offered by EDF-CIDEN respectively <strong>to</strong>ok<br />
place.<br />
The first step <strong>to</strong>wards more comprehensive decommissioning planning was taken in 2007 when <strong>the</strong><br />
so called 'Conceptual decommissioning plan' (in fur<strong>the</strong>r text 'decommissioning plan') was developed<br />
that comprises of two main decommissioning stages. According that, <strong>the</strong> decommissioning activities<br />
should be completed in 2025 (ANNEX 5).<br />
The 1 st stage of <strong>the</strong> decommissioning was started in 2011 and <strong>the</strong> 2 nd stage shall start in 2015<br />
according <strong>to</strong> <strong>the</strong> decommissioning plan. Subsequently, as described in 'Combined Programming<br />
Document – Bohunice Programme' (CPD 2012) (also see ANNEX 5), several tasks/projects and <strong>the</strong>ir<br />
objectives were defined that are co-financed within <strong>the</strong> EU assistance. According <strong>to</strong> <strong>the</strong> status in<br />
2012, <strong>the</strong> project 'Management and preparation of decommissioning activities' has been implemented.<br />
The objective is <strong>to</strong> ensure <strong>the</strong> effective project management in compliance with western<br />
management methodologies. Among o<strong>the</strong>r things, <strong>the</strong> international standards in <strong>the</strong> quality<br />
management, risk management, interface management, scheduling and costs calculation should be<br />
implemented.<br />
As support it was proposed <strong>to</strong> contract a consultant <strong>to</strong> provide JAVYS with expertise or <strong>to</strong> cooperate<br />
with JAVYS.<br />
4.5.2. Comparison and evaluation of <strong>the</strong> project and risk management with best<br />
practice<br />
All three investigated cases point <strong>to</strong> serious deficiencies in <strong>the</strong> understanding of management,<br />
responsibilities and decision processes.<br />
A consultant group or an external PMU consultant can never take over responsibilities for failures or<br />
mal-planning of processes, because his work has principally <strong>to</strong> be independently checked by <strong>the</strong><br />
management of <strong>the</strong> managing organisation, corrected or upgraded if necessary, and finally adopted<br />
by <strong>the</strong> finally responsible management (and its control institution). It <strong>the</strong>n is <strong>the</strong> management’s (and<br />
its control institutions) failure <strong>to</strong> accept inadequate planning or consultant work. This misperception<br />
in <strong>the</strong> current understanding of management duties and responsibilities and <strong>the</strong>ir control has already<br />
been discussed in chapter 4.4.3.<br />
Project management which is performed isolated in a PMU unit instead of being integrated in<strong>to</strong> <strong>the</strong><br />
whole organisation cannot work properly. INPP has clearly recognized that and now tries <strong>to</strong> integrate<br />
this as a holistic approach. Compared <strong>to</strong> best practice this has <strong>to</strong> be evaluated as being in an 'early<br />
stage of implementation'. Bulgaria and Slovakia are on that way, <strong>to</strong>o, but 'responsibility sharing'<br />
between <strong>the</strong> management, its national administration institution, external consultants and EBRD still<br />
is an issue.<br />
4.5.3. Recommendations for project and risk management<br />
A complete and adequate project and risk management, including <strong>the</strong> respective task-tailored IT<br />
<strong>to</strong>ols (PMIS), for <strong>the</strong> decommissioning project has <strong>to</strong> be considered a state-of-<strong>the</strong>-art requirement.<br />
Improving, completing and fully implementing project and risk management should be given highest<br />
priority. Management should set up respective work methods and <strong>to</strong>ols, <strong>the</strong> controlling institutions<br />
should supervise <strong>the</strong>ir design and timely implementation in <strong>the</strong> managing process.<br />
114