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Policy Department D: Budgetary Affairs ____________________________________________________________________________________________ waste stemming from decommissioning and from current operating plants. Another example is the physical protection facilities shared between operating plants and plants to be decommissioned. Such projects may qualify for co-funding from the Funds, provided that the recipient can conclusively justify which part of the costs is attributable to the decommissioning program. The Bank assesses such proposals as part of its due diligence review, to ensure that the cost-sharing logic is sound and based on an as accurate as possible a factual basis. Procurement is key in the project implementation process. It is the recipient’s responsibility to carry the process out to a high professional standard and in line with the Bank’s procurement policies and rules. The Bank follows the process closely, and the Bank’s formal 'no-objection' is required at important milestones. This means that the process foresees time for a detailed review by the Bank of, for instance, tender documents and evaluation reports. The review typically includes the Bank’s Procurement Department. The Bank may also engage external technical expertise if required. The process can only continue once the Bank confirms that it has no reason to object. This process often leads to clarifications and amendments to documents. The Bank’s procurement complaint mechanism is available to any bidders in procurement processes undertaken within the framework of the decommissioning programs. The Bank’s close involvement in project implementation is designed to give the Bank the best possible chance of picking up as early as possible on project issues which could potentially cause schedule delays and cost increases. As far as appropriate, the Bank facilitates efficient co-operation between recipient and contractors and resolution of issues, recovery of delays and joint commitment to cost efficiency. The Bank exercises very thorough financial controls over activities of the international decommissioning support funds. In addition to the controls and mechanisms provided by the Bank in line with requirements in its Banking operations, the Nuclear Safety Department keeps separate track of all contract information and disbursement data. The financial statements for each of the Funds are externally audited annually, as are all of the Bank’s accounts. The three international decommissioning support funds have all recently been the subject of financial audits by Moore Stephens approved by the Assemblies. The three audits confirm that appropriate financial controls are in place. Plasma Melting Facility in Kozloduy The Bank categorically rejects the unfounded statement that this project is an example of mismanagement. The project was developed in line with the processes described above and has been subject to thorough reviews. It has received all the necessary approvals and is on track to successful completion. The decommissioning strategy for Kozloduy Units 1-4 foresees the conditioning of solid radioactive wastes with a high volume reduction factor. The technical specification issued for tender did not prescribe any specific technology. The market response to an open competitive tender resulted in proposals using plasma melting technology – not only by the winning bidder. During project implementation, no particular risks were identified with regard to plasma melting and its associated technologies. The technical design, the detailed design and Intermediate Safety Analysis Report (ISAR) have been approved by Kozloduy NPP. The ISAR went through independent verification review and received a positive conclusion. The technical design and ISAR are currently under final review by 198
Nuclear Decommissioning: Management of Costs and Risks ____________________________________________________________________________________________ the nuclear regulator, which includes review by international experts funded from the KIDSF. The Environmental Impact Assessment Report was approved by the Ministry of Environment and Water on 30 May 2013 and public hearings are planned for July-August. Manufacturing of equipment began in May 2012 and Factory Acceptance Tests (FATs) of the main equipment (primary treatment chamber, melt collecting chamber, feeding and shredding system and exhaust gases system) were successfully completed in Spain, Belgium and the Netherlands in June 2013. Delivery of the main equipment to Kozloduy NPP is expected in August-September 2013. Court of Auditors report EBRD has contributed to and shares the comments provided by the EC as published in the annex to the Court of Auditors report. The topic of Decommissioning Plans has been addressed above. Preparation of the plans is an iterative process and all three recipients have been updating the plans since the time of the report. The plans define projects and sequences as well as cost and schedule estimates. As outlined above, there is agreement between the EC and the EBRD that there is no uncertainty about responsibilities. There will, however, be discussions on adjustments to the governance arrangements and formalization of the role that the EC de facto already holds. All three programs have had instances in which progress was slower than anticipated. Whenever delays have occurred, the reasons have been thoroughly assessed. To date, all cases have been attributable to project-specific circumstances (often legacy issues such as uncertainties in the historic data on nuclear fuel and waste) or external circumstances (such as reluctance to close the NPPs) and not to systemic failures. Testimony to that are the vast majority of projects which have been implemented efficiently in line with schedule and cost estimates. It is important to note that closure of the plants did not occur upon inception of the Funds, but over a period of time afterwards (Kozluduy 2002-2006, Ignalina 2004-2009, Bohunice 2006-2008), which had a significant impact on the course of the three decommissioning programmes. 199
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