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Policy Department D: Budgetary Affairs ____________________________________________________________________________________________ This, as well as the other characteristic aspects named above, is not sufficiently treated in the EIS (EWN 2013b). Neither the relevant storage space and conditions (in the section on alternatives) nor the radioactive emissions from the plant (emissions over air and water in the section on environmental impacts from operation) are described in the necessary detail to be understood correctly. 4.9.4. Conclusions Project status According to DP RAO the plasma melting facility is already 2½ years behind schedule (see ANNEX 3) and this clearly contradicts that the facility is on track (see ANNEX 8). This, and the potential further delays, result in a considerable risk that the decommissioning steps, that require and depending upon a working waste treatment and conditioning facility will also be delayed. Attribution in a dispersed responsibility environment Neither from the answers provided nor from our talks with very different persons in Bulgaria, who are or were at very different decision levels (from consultants all the way up to the Ministry level), we did not find a single person who could tell us exactly how the decision was taken to build a plasma oven for that purpose. It can be seen from this example that in an organisation and decision form with a strongly dispersed responsibility even such large portions of budget like EUR 30 million can lack any identifiable decision maker. 4.9.5. Recommendations In any future setting clear, unambiguous and transparent responsibilities have to be defined and implemented to avoid any dilution and dispersion of responsibilities over several institutions and to avoid unclear and uncommunicated attributions. The national supervising institution and the EC should be jointly attributed the full responsibility for controlling the national managing organisation’s strategic decisions. They should have the right and as well the obligation to completely oversee the whole performance of the decommissioning project and to steer and control the management. The managing organisation has to be attributed the sole, undivided and unambiguous responsibility to a) prepare the proposals and the complete background for the strategic decisions and b) for any operational decisions. This includes all overseeing, steering and supervision of internal and external processes, including procurement-, cost- and time-control. To control the due diligence of all financial transactions, the managing organisation should define, set up, implement and regularly audit an adequate internal control system. The national controlling institution or an equivalent (e.g. the Ministry for Finance) as well as the EC should have the right and the obligation to oversee and make exemplary checks on the adequacy of the management’s measures to keep control over its financial transactions. 128
Nuclear Decommissioning: Management of Costs and Risks ____________________________________________________________________________________________ If, in the case of Bulgaria and Slovakia, the interferences of the constitution of the managing organisation’s with its non-decommissioning obligations is too complicated and may reduce the effectiveness of the management level’s ability to act, an institutional separation of the decommissioning project part should be considered. 129
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