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Policy Department D: Budgetary Affairs ____________________________________________________________________________________________ 5. COUNTRY PROFILES, RISKS AND POTENTIAL IMPROVEMENTS The following derives, in a short and condensed form, the findings in chapter 4 and points to relevant risks and potential improvements. Chapters 5.1, 5.2 and 5.3 provide major evaluation results for the three countries. The overall evaluation of the risk profiles in a short form are elaborated in chapter 5.4. 5.1. BULGARIA The following applies to Bulgaria: The national framework is incomplete in respect to the funds required for decommissioning. The main reason for that is that during operation of the reactors no build-up of funds was established and that this gap was not adequately filled in the years from at least 1999 23 (IAEA 1999) on until their shutdown in 2002 resp. 2006. Further external support to assist Bulgaria in filling that gap is necessary and recommendable. The established national structures to control and steer the managing organisation are weak and need urgently to be strengthened. Bulgaria needs to understand that it is in its own interest to have strong control structures established to achieve optimal results and effectivity for its own invested funds. The full control over the management and all strategic decisions is necessary, otherwise the decommissioning process as a whole is at risk. Bulgaria and the EC should establish a common understanding on those bilateral supervision and steering structures. In respect to the managing organisation their restructuring towards decommissioning is still to be established. Dividing management and PMU into separate organisations is not an optimal solution as it diverts responsibilities. The PMU should be completely integrated into the responsible organisation, their work should be completely under control of the management so that the management can be held responsible for all its operational decisions. Management then has to be fully aware and has to evaluate all risks associated with those decisions. The same effect of inadequately and ineffectively dispersed responsibilities applies both to project and risk management. The regulatory regime should be more fitted to the needs of decommissioning. The stepwise permitting process, with time-limited licenses instead of project-adequate approvals, does not support the awareness that all relevant steps in decommissioning are more or less interconnected and require early planning to fit together. The model of a general decommissioning license regulating the whole general approach, associated with a more project-oriented approval to projects and sub-projects, is seen as more adequate for decommissioning. This also establishes the necessity to intensely communicate with regulators in early planning stages. 23 'At least' means that the final version of the document was released in 1999. Years before such a final version of such a Safety Guide is released the member states of the IAEA receive draft versions so that they can comment on it. The requirements in their draft form are well known earlier and member states can already start to prepare for their adaptation. 130
Nuclear Decommissioning: Management of Costs and Risks ____________________________________________________________________________________________ The cost estimates are based on a sufficient understanding of the whole process. An estimate for potential consequences of risks can be added to be aware of and better understand their economic influence. The role of the workforce, the psychological barriers, understanding of the tasks to be done and the self-sufficiency should be better understood and addressed. The priority to use available experience and knowledge can be better communicated. The training programs on technical experience are adequate. 5.2. LITHUANIA The following applies to Lithuania: The national framework is incomplete in respect to the funds required for decommissioning. The main reason for that is that during operation of the reactors no build-up of funds was established and that this gap was not adequately filled in the years from at least 1999 23 (IAEA 1999) on until their shutdown in 2004 resp. 2009. Further external support to assist Lithuania in filling that gap is necessary and recommendable. The established national structures to design, control and steer the managing organisation are weak and need urgently to be strengthened. The established national funding base still is very weak. It should be mandatory to bear at least a considerable portion of the total costs from own sources, so that the national interest to achieve a cost-effective decommissioning and to install a solid and functioning management- and control-system is strong enough. Lithuania needs to understand that it is in its own interest to have strong control structures established to achieve optimal results and effectiveness for its own invested funds. The full control over the management and over all its strategic decisions is necessary to be gained, otherwise the decommissioning process as a whole is at risk. Lithuania and the EC should establish a common understanding on those bilateral supervision and steering structures. In respect to the managing organisation their restructuring towards decommissioning is still underway and unfinished. Integrating the former external PMU into the managing organisation is a consistent step should be fostered by additional integration steps to achieve that the work of the PMU is completely under control of the management. The management should be held completely responsible for all its operational decisions. Management then has to be fully aware and has to evaluate all risks associated with those decisions. In respect to project and risk management establishing the necessary changes in the planning and management process, as well as the necessary tools, is still underway in Lithuania. Management is aware of the necessary changes and has initiated them, but the slow implementation process, nearly ten years after shutting down the first unit, lets expect that this requires further acceleration. All involved parties – middle management, workforce, national administration, the EC – should assist the management’s efforts to implement those changes. The final structure should be well-designed and implementation targets for the staged processes should be clearly set (e.g. less than three years). 131
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