Link to the study - European Parliament - Europa
Link to the study - European Parliament - Europa
Link to the study - European Parliament - Europa
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Policy Department D: Budgetary Affairs<br />
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This, as well as <strong>the</strong> o<strong>the</strong>r characteristic aspects named above, is not sufficiently treated in <strong>the</strong> EIS<br />
(EWN 2013b). Nei<strong>the</strong>r <strong>the</strong> relevant s<strong>to</strong>rage space and conditions (in <strong>the</strong> section on alternatives) nor <strong>the</strong><br />
radioactive emissions from <strong>the</strong> plant (emissions over air and water in <strong>the</strong> section on environmental<br />
impacts from operation) are described in <strong>the</strong> necessary detail <strong>to</strong> be unders<strong>to</strong>od correctly.<br />
4.9.4. Conclusions<br />
Project status<br />
According <strong>to</strong> DP RAO <strong>the</strong> plasma melting facility is already 2½ years behind schedule (see ANNEX 3)<br />
and this clearly contradicts that <strong>the</strong> facility is on track (see ANNEX 8).<br />
This, and <strong>the</strong> potential fur<strong>the</strong>r delays, result in a considerable risk that <strong>the</strong> decommissioning steps,<br />
that require and depending upon a working waste treatment and conditioning facility will also be<br />
delayed.<br />
Attribution in a dispersed responsibility environment<br />
Nei<strong>the</strong>r from <strong>the</strong> answers provided nor from our talks with very different persons in Bulgaria, who are<br />
or were at very different decision levels (from consultants all <strong>the</strong> way up <strong>to</strong> <strong>the</strong> Ministry level), we did<br />
not find a single person who could tell us exactly how <strong>the</strong> decision was taken <strong>to</strong> build a plasma oven<br />
for that purpose.<br />
It can be seen from this example that in an organisation and decision form with a strongly dispersed<br />
responsibility even such large portions of budget like EUR 30 million can lack any identifiable decision<br />
maker.<br />
4.9.5. Recommendations<br />
In any future setting clear, unambiguous and transparent responsibilities have <strong>to</strong> be defined and<br />
implemented <strong>to</strong> avoid any dilution and dispersion of responsibilities over several institutions and <strong>to</strong><br />
avoid unclear and uncommunicated attributions.<br />
The national supervising institution and <strong>the</strong> EC should be jointly attributed <strong>the</strong> full responsibility for<br />
controlling <strong>the</strong> national managing organisation’s strategic decisions. They should have <strong>the</strong> right and<br />
as well <strong>the</strong> obligation <strong>to</strong> completely oversee <strong>the</strong> whole performance of <strong>the</strong> decommissioning project<br />
and <strong>to</strong> steer and control <strong>the</strong> management.<br />
The managing organisation has <strong>to</strong> be attributed <strong>the</strong> sole, undivided and unambiguous responsibility<br />
<strong>to</strong> a) prepare <strong>the</strong> proposals and <strong>the</strong> complete background for <strong>the</strong> strategic decisions and b) for any<br />
operational decisions. This includes all overseeing, steering and supervision of internal and external<br />
processes, including procurement-, cost- and time-control.<br />
To control <strong>the</strong> due diligence of all financial transactions, <strong>the</strong> managing organisation should define,<br />
set up, implement and regularly audit an adequate internal control system. The national controlling<br />
institution or an equivalent (e.g. <strong>the</strong> Ministry for Finance) as well as <strong>the</strong> EC should have <strong>the</strong> right and<br />
<strong>the</strong> obligation <strong>to</strong> oversee and make exemplary checks on <strong>the</strong> adequacy of <strong>the</strong> management’s<br />
measures <strong>to</strong> keep control over its financial transactions.<br />
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