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Policy Department D: Budgetary Affairs ____________________________________________________________________________________________ Do you see any areas of responsibilities that are currently not appropriately defined, but should be clearly defined in future so that unallocated responsibilities with adverse consequences can be avoided? Interface to the involved Countries Does the EBRD feel that the usual order- and instruction-manual based organisation form, as usually applied during the operational phase of an NPP, is an appropriate form to manage decommissioning projects? Have structural changes been initiated by EBRD? Does EBRD negotiate upon the necessary organisational structures and set requirements for the responsible decommissioning organisations? How is assured that the management level of decommissioning organisations is appropriately qualified to manage decommissioning projects? Has EBRD defined and implemented quality control measures to evaluate its own and the responsible organisation’s performance? Which national shares are required, on the general and on the project level, to qualify for a shared undertaking? Which factual shares have been reached in the decommissioning projects so far and which shares are planned for the future? How is gua ranteed that only factual contributions to decommissioning projects are counted as shares? Is the effectiveness, the factual contribution to the decommissioning projects, evaluated and included in the calculation of those shares? Decommissioning plan Have all key decisions been adequately analyzed and resolved, so that the overall path of decommission is clear? Is a decommissioning plan available for each of the facilities? Does this plan identify all necessary technical steps, does it qualify and evaluate all the risks involved, does it identify sub-projects and critical pathways, missing technical means and development necessities, time span estimates, mass/volume-related balances, inventory-related information and if-then-relations for key decisive issues (break points, etc.)? In which interval are these plans re-evaluated and updated? If not: on which basis have decisions (under #15) been established and estimates on costs, shares, disposal volumes, etc., been made? Which requirements will EBRD set to establish such decommissioning plans as a basis of its decisions? Financial control measures Is the project contribution and the project progress mirrored on the complete overall decommissioning plan (see #16) or which evaluation criteria are applied by EBRD? How does reporting towards EBRD work? How detailed are those reports (can we have an example to gain an own sight?)? 190
Nuclear Decommissioning: Management of Costs and Risks ____________________________________________________________________________________________ How is assured that project progress adequately corresponds to the spent financial resources? What reactions are established if this is not the case and indications for cost-overruns are evolving? What typical time delay between this indication and the reaction were encountered so far? Upgrade(s) addressing the concerns of the Auditors What has been changed at EBRD to address the Auditor’s critique on missing decommissioning plan (paragraphs 19 and 20), diffused responsibilities (paragraphs 35, 36 and 41), the slow progress and unclear/insufficient progress indications (paragraph 40). 191
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