Special Report EU nuclear 
decommissioning 
assistance programmes 
in Lithuania, Bulgaria and 
Slovakia: some progress 
made since 2011, but 
critical challenges ahead EN 2016  NO 22
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EU nuclear 
decommissioning 
assistance programmes 
in Lithuania, Bulgaria and 
Slovakia: some progress 
made since 2011, but 
critical challenges ahead
(pursuant to Article 287(4), second subparagraph, TFEU)Special ReportEN 2016  NO 22
02
 Audit team
The ECA’s special reports set out the results of its performance and compliance audits of specific budgetary areas or 
management topics. The ECA selects and designs these audit tasks to be of maximum impact by considering the risks 
to performance or compliance, the level of income or spending involved, forthcoming developments and political and 
public interest.
This performance audit was produced by Audit Chamber II – headed by ECA Member Henri Grethen – which specialised 
in structural policies, transport and energy spending areas. The audit was led by the Reporting Member Phil Wynn Owen, 
supported by an audit team of Chamber II.
03
 Contents
Paragraph
 Glossary
 Abbreviations
I-X Executive summary
1-28  Introduction
4-10  The EU’s nuclear decommissioning assistance programmes
11-17  What is nuclear decommissioning?
18-19  Radioactive waste management
20 ‘Polluter pays’ as an EU and international principle
21-27  The roles and responsibilities of actors under the EU’s nuclear decommissioning assistance 
programmes
28 Previous ECA special report on nuclear decommissioning
29-35  Audit scope and approach
36-106  Observations
36-71  Some decommissioning progress made since 2011, but critical challenges ahead
37-58  Progress made in non‑controlled areas, but decommissioning of reactor buildings yet to begin and 
radioactive waste management infrastructure only partially complete
59-71  Nearly all the key decommissioning infrastructure projects have experienced delays
72-106  Estimated cost of decommissioning will be at least 5.7  billion  euro and double this if the cost of 
final disposal is included
73-74  Total estimated decommissioning cost has increased by 40 % to 5.7  billion  euro since 2010
75-85  The Member States, and in particular Lithuania, face financial challenges
86-88 The Commission’s assessment of financing and decommissioning plans was inadequate
89-92  The EU budget finances the vast majority of costs in all three Member States
04 Contents 
93-99  The total estimated cost would double if the cost of final disposal of high‑level waste is included
100-106  Liabilities for future costs are not properly accounted for in the three Member States
107-120  Conclusions and recommendations
 Annex I  —  The nuclear reactors being decommissioned under the EU’s nuclear 
decommissioning assistance programme
 Annex II  —  Overview of the legal bases for the nuclear decommissioning assistance 
programmes
 Annex III —  Nuclear power reactors in the Member States and their status as at 
31 December 2015
 Annex IV  —  Overview of the nuclear decommissioning assistance programme actors
 Annex V —  EU financed projects examined for the audit
 Annex VI —  Delays and cost overruns affecting a sample of 18 key decommissioning 
infrastructure and supporting projects financed by the EU assistance programmes 
since 2001
 Annex VII  —  Construction of the deep geological repository for the final disposal of spent 
nuclear fuel in Olkiluoto, Finland
 Reply of the Commission
05
 Glossary
Activation : The process whereby neutron irradiation causes an unintended induction of radioactivity in 
moderators, coolants and structural and shielding materials.
Brownfield site : Although this term has no standard international definition, for the purpose of this report it should 
be understood to be an end state for a decommissioned nuclear power plant site which falls short of greenfield 
status. A brownfield site remains under regulatory control, and the land’s reuse and redevelopment is subject to 
certain restrictions.
Contamination : The unintended, unwanted presence of a radioactive substance on surfaces or within solids, or the 
process giving rise to its presence in such locations.
Contingent liability : In accounting, this is a present obligation of which payment is not probable or the amount 
cannot be measured reliably, or a  possible obligation which depends on whether some uncertain future event 
occurs.
Controlled area : A controlled‑access area subject to special rules for the purpose of protecting against ionising 
radiation and preventing the spread of radioactive contamination.
Decommissioning measures : Projects designed to help relieve some of the financial burden placed on the 
Member States as they decommission the plants.
Deep geological repository : A final disposal facility is located underground in a stable geological formation so 
as to provide the long‑term containment (for thousands of years or longer) of long‑lived radioactive waste and 
isolation of the waste from the accessible biosphere. Disposal means that there is no intention to retrieve the waste, 
although such a possibility is not ruled out. Geological disposal is a method for disposing of, in particular, high‑level 
radioactive waste.
Dry storage of spent nuclear fuel : The spent nuclear fuel is enclosed in casks in a dedicated facility. This is one of 
the two possibilities for the interim storage of spent fuel, the other option being ‘wet storage’.
Ex ante  conditionalities : These are conditions for the effective and efficient use of EU support. The ex ante  
conditionalities for the nuclear decommissioning assistance programmes are laid down in Council Regulations 
(Euratom) No 1368/20131 and No 1369/20132. Lithuania, Bulgaria and Slovakia had to have taken appropriate 
measures to meet these conditions by the time the Commission adopted its financing decision on the 2014 annual 
work programme.
Final decommissioning plan : A document drawn up by the nuclear power plant operator when a facility is shut 
down and submitted as part of the decommissioning licence application. It sets out all the necessary activities, as 
well as their scheduling and estimated costs, and includes a financing plan. The document may be amended as the 
decommissioning proceeds.
1 Council Regulation (Euratom) No 1368/2013 of 13 December 2013 on Union support for the nuclear decommissioning assistance programmes in Bulgaria 
and Slovakia, and repealing Regulations (Euratom) No 549/2007 and (Euratom) No 647/2010 (OJ L 346, 20.12.2013, p. 1).
2 Council Regulation (Euratom) No 1369/2013 of 13 December 2013 on Union support for the nuclear decommissioning assistance programme in 
Lithuania, and repealing Regulation (EC) No 1990/2006 (OJ L 346, 20.12.2013, p. 7).
06 Glossary 
Final disposal : The last step in the radioactive waste management process. There are various options available, 
including disposal in a deep geological repository for high‑level radioactive waste.
Greenfield site : Although this term has no standard international definition, for the purpose of this report it should 
be understood to be an end state for a decommissioned nuclear power plant site which allows the land to be 
released from regulatory control.
Indirect management : One of three different ways to implement the EU budget. In this management mode, the 
Commission has overall responsibility for the budget but entrusts implementing tasks to one or more partner 
countries, international organisations, Member State agencies or other bodies.
International Decommissioning Support Funds : The EBRD‑managed funds supporting the decommissioning 
process in Lithuania through the Ignalina International Decommissioning Support Fund (IIDSF), in Bulgaria 
through the Kozloduy International Decommissioning Support Fund (KIDSF) and in Slovakia through the Bohunice 
International Decommissioning Support Fund (BIDSF).
Liability : In accounting, this is a present obligation resulting from past events.
Licences : All activities performed over the life cycle of a nuclear power plant, including decommissioning, are 
regulated and require a  licence from a  national authority. A  change from operational licence to a  decommissioning 
licence is required to work in the controlled area.
Mitigation measures : Projects designed to help mitigate some of the effects of lost national energy production 
capacity due to early closure.
Multiannual financial framework (MFF) : The MFF establishes the spending priorities and maximum amounts 
that the EU may spend in particular areas over a fixed period of several years. The expenditure ceilings in the MFF 
regulation are not equivalent to those in the EU budget, which are always lower. The MFF also includes income 
sources for the EU budget and correction mechanisms for the period in question (currently 2014 ‑2020).
Nuclear decommissioning : The process whereby a nuclear power plant is dismantled and the site is cleaned up to 
a predetermined end point.
Nuclear decommissioning assistance programmes : EU programmes launched to provide financial assistance 
to Lithuania, Bulgaria and Slovakia as they shut down and decommission Soviet‑designed nuclear reactors that 
could not be economically upgraded to Western safety standards at the sites of Ignalina, Kozloduy and Bohunice 
respectively, in line with the relevant conditions laid down in their accession treaties.
Nuclear power plant : A power plant using fissionable nuclear material as fuel.
Nuclear reactor : Found on the site of a nuclear power plant, this is a system that contains and controls sustained 
nuclear chain reactions.
Polluter pays principle : A commonly accepted environmental policy practice which dictates that those responsible 
for causing pollution should bear the costs of managing it.
Provision : In accounting, this is a liability of uncertain timing or amount recorded in the balance sheet.
07 Glossary 
Radioactive waste : Material resulting from the plant operation and decommissioning processes which is affected 
by radioactive contamination or activation. This category can be further subdivided according to the level of the 
waste’s radioactivity (exempt, very short‑lived, very low, low, intermediate or high).
Reactor building : This houses the reactor and other main components and constitutes part of the controlled area.
Spent nuclear fuel : Nuclear fuel that has been irradiated in a reactor and reached the end of its useful life.
Technical decommissioning : In this report, this shall be understood to cover the methodology, technology and 
works relating to the decontamination, dismantling and fragmentation of radiologically activated/contaminated 
structures and systems and their adequate management.
Wet storage of spent nuclear fuel : The spent nuclear fuel is stored in pools. This is one of the two possibilities for 
the interim storage of spent fuel, the other option being ‘dry storage’.
08
 Abbreviations
AWP : Annual work programme
BNPP : Bohunice nuclear power plant in Slovakia
CPMA : Central Project Management Agency in Lithuania
EBRD : European Bank for Reconstruction and Development
IAEA : International Atomic Energy Agency
IAS: Internal Audit Service of the European Commission
INPP : Ignalina nuclear power plant in Lithuania
JAVYS a.s. : Slovak state enterprise responsible for decommissioning and radioactive waste management
KNPP : Kozloduy nuclear power plant in Bulgaria
KPI: Key performance indicator
NDAP : Nuclear decommissioning assistance programmes
RBMK ‑1500 : High‑power channel‑type reactor (as in Lithuania)
SERAW : Bulgarian state enterprise for radioactive waste management
VVER 440/230 : Water‑water energetic reactor (as in Bulgaria and Slovakia)
09
 Executive summary
I
When Lithuania, Bulgaria and Slovakia were candidate countries to join the European Union (EU), the closure and 
subsequent decommissioning of eight Soviet‑designed, first generation nuclear reactors at three nuclear power 
plant sites was made a condition for their accession.
II
The shutdown and subsequent decommissioning of these nuclear reactors before the end of their design lifetimes 
represented a  significant financial and economic burden for the three Member States concerned. The EU therefore 
agreed to provide financial support, starting in 1999. By 2020, EU support will have totalled 3.8 billion euro, with 
Lithuania receiving the biggest share, followed by Bulgaria and then Slovakia.
III
The aim of this audit was to determine whether progress has been made in the implementation of the EU’s nuclear 
decommissioning assistance programmes for Lithuania, Bulgaria and Slovakia since 2011, when our previous report 
on the subject was published.
IV
The dedicated EU funding programmes for nuclear decommissioning have not created the right incentives for 
timely and cost‑effective decommissioning.
V
Since 2011, some progress has been made in decommissioning the nuclear power plants of Ignalina in Lithuania, 
Kozloduy in Bulgaria and Bohunice in Slovakia. Key components in the plants’ non‑controlled areas have been dis ‑
mantled, but the critical challenges involved in working in the controlled areas, including the reactor buildings, still 
lie ahead for all three Member States. Although Member State authorities claim that the plants have been irrevers ‑
ibly closed, not all of the expected outputs used by the Commission to assess progress towards irreversible closure 
have been fully met.
VI
The three Member States have made some progress in putting in place waste management infrastructure, but many 
key infrastructure projects experienced delays in the 2011 ‑2015 period. The longest delays have been in Lithuania, 
where the decommissioning end date has, since 2011, been postponed by a further 9 years to 2038. Challenges 
remain in each of the three Member States, such as a reliance on external experts and dealing with first‑in‑kind 
technical solutions.
10 Executive summary 
Recommendation 1 : the three Member States concerned should:
(a) further improve their project management practices in order to have the necessary waste and spent fuel man ‑
agement infrastructure in place when planned;
(b) take steps to build up their own technical capacity, so as to achieve a better balance between in‑house and 
external expertise;
(c) find better ways to exchange best practices and technical knowledge, both among themselves and with the 
wider nuclear decommissioning community in the EU and beyond — the Commission should facilitate this in 
a cost‑effective way.
VII
Talks in the three Member States regarding potential final disposal solutions for high‑level waste and spent nuclear 
fuel, which may be national, regional or other EU‑based solutions, are still only at a conceptual stage, despite such 
solutions taking several decades to implement.
Recommendation 2 :
(a) The Commission should, together with all relevant EU Member States, explore options for the disposal of spent 
fuel and high‑level waste, including any regional and other EU‑based solutions, duly considering safety, security 
and the cost‑effectiveness of the alternatives. The Commission should include a review of this matter in its first 
report to the European Parliament and the Council on the implementation of the radioactive waste directive.
(b) The three Member States should, in parallel, progress with their plans for final disposal, in order to establish 
more complete cost estimates and financing plans for the disposal of spent fuel and radioactive waste, as re ‑
quired by the radioactive waste directive.
VIII
The estimated cost of decommissioning at the three plants will be at least 5.7 billion euro in total, and double that 
if the cost of final disposal is included. The decommissioning financing gap in Lithuania has increased since our last 
audit and costs now exceed financing by 1.6 billion euro. The financing gaps estimated by Bulgaria and Slovakia are 
now at 28 million euro and 92 million euro respectively. Although the three Member States are ultimately respon ‑
sible for ensuring that adequate financial resources are available for both decommissioning and final disposal, 
their co‑financing of the EU’s decommissioning programmes remains very limited. The Commission has not issued 
clear guidance on co‑financing requirements. Staff levels have declined at all three plants since they were fully 
operation  al, but some EU funds are being used to cover the cost of staff working on safe plant maintenance. In 2011 
the Commission indicated that it does ‘not foresee any further extension of financial EU support’ beyond 2020.
Recommendation 3 : the three Member States should recognise their own role in ensuring that the polluter pays 
principle is respected, and be prepared to use national funds to cover decommissioning costs, as well as the cost of 
final disposal, both in the current financing period and thereafter.
11 Executive summary 
Recommendation 4 : the Commission should seek increases in national co‑financing during the 2014 ‑2020 
financing period. It should define clearly, for example, in a  Commission decision, the ‘well‑founded exceptional’ 
conditions under which projects can be fully financed by the EU under the nuclear decommissioning assistance 
programmes.
Recommendation 5 : dedicated funding programmes for nuclear decommissioning in Lithuania, Bulgaria and Slo ‑
vakia should be discontinued after 2020. If a clear need for the use of EU funds beyond 2020 is established, in one or 
more of the three Member States, any future EU funding proposed by the Commission and agreed by the legislator 
should include the right incentives to pursue decommissioning, including by being time limited and by being based 
on appropriate levels of Member State co‑financing. One way to do this would be to consider widening access to 
the European Structural and Investment Funds to allow nuclear decommissioning activities to be covered, fulfilling 
these conditions.
Recommendation 6 : the Commission  should  allow  EU financing under the nuclear decommissioning assistance 
programmes to be used to finance only the cost of staff working fully on decommissioning activities.
IX
The Commission’s assessment as to whether the financing and decommissioning plans fulfil the ex ante  condition ‑
alities has been inadequate.
Recommendation 7 : the Commission should complete its assessment of the ex ante  conditionalities.
X
Future costs are not always recognised as provisions and/or included in the notes to the accounts. This limits trans ‑
parency and hampers the relevant authorities’ ability to plan adequately how the future costs of decommissioning 
and the disposal of spent nuclear fuel are to be met.
Recommendation 8 : the Commission should work together with all relevant Member States so that all future costs 
associated with nuclear decommissioning and the final disposal of spent fuel are accounted for properly, in a trans ‑
parent manner, consistent with relevant accounting standards.
12
 Introduction Figure 1The nuclear power plants in Lithuania, Bulgaria and 
Slovakia covered by the EU’s nuclear decommissioning 
assistance programmes01 
When Lithuania , Bulgaria  and Slovakia  were candidate countries to join the 
European Union (EU), the closure and subsequent decommissioning of eight 
Soviet‑designed, first generation nuclear reactors at three nuclear power plant 
sites3 was made a condition for their accession (see Figure 1  and Annex I ). Since 
an upgrade to Western safety standards was deemed to be uneconomical, it 
was agreed during accession negotiations that these reactors would be shut 
down before the end of their design lives4. The three sites are operated by state 
enterprises.3 The Kozloduy plant in Bulgaria 
and the Bohunice plant in 
Slovakia have reactors under 
operation adjacent to those 
being decommissioned. In this 
report, the word ‘plant’ is used 
to refer only to the reactors 
being decommissioned.
4 DOC/97/8, Strasbourg/
Brussels, 15 July 1997, Agenda 
2000 — Summary and 
conclusions of the opinions of 
Commission concerning the 
applications for membership 
to the European Union 
presented by the candidates 
countries; Western European 
Nuclear Regulators 
Association (WENRA), Nuclear 
safety in EU candidate countries , 
October 2000.
Kozloduy nuclear power plant in Bulgaria
Units 1 to 4 with one reactor eachReactor type: Water-water energetic reactor(VVER - 440/230)
Bohunice nuclear power plant V1 in SlovakiaReactor type: Water-water energetic reactor  
twin reactor (VVER 440/230)
Ignalina nuclear power plant in LithuaniaUnits 1 and 2 with one reactor eachReactor type: High-power channel-typereactor (RBMK - 1500)
Source:  ECA, based on information provided by the nuclear power plants. Photos © Bohunice nu ‑
clear power plant (BNPP), Kozloduy nuclear power plant (KNPP), Ignalina nuclear power plant (INPP).
13 Introduction 
02 
The Bohunice nuclear power plant V1 in Slovakia and the Kozloduy nuclear power 
plant in Bulgaria both have water‑water energetic reactors (VVER), a sub‑category 
of pressurised water reactors (see Figure 2 ). This type of reactor has previously 
been decommissioned elsewhere in Europe. Figure 2Illustration of a pressurised water reactor nuclear power plant (VVER ‑440/230)
Source:  ECA. Reactor
FuelPressuriser
Steam generator
Feedpump
CondenserTurbineGenerator
TransformerGridSecondary circuit in turbine hall Switchyard
The reactor and primary cooling circuit components in the reactor building form the activated and contaminated primary circuit. The turbine and condenser form the secondary 
circuit. Bohunice V1 and Kozloduy units 1-4 lack a massive steel and concrete containment structure as the ﬁnal barrier against the mass release of radiation in an accident in thereactor and primary circuit components.Cooling water 
to/from river/lake
cooling towersReactor coolant
pumpPrimary circuit in
reactor hall, part of the
controlled area
14 Introduction 
03 
The reactor at the Ignalina plant in Lithuania is a graphite‑moderated (RBMK ‑
1500) reactor, a sub‑category of boiling water reactors, also commonly referred 
to as a Chernobyl‑type reactor (see Figure 3 ). This is the first time that such 
a graphite‑moderated reactor is being decommissioned5.5 Though closed, the reactor 
units at Chernobyl have not 
been decommissioned. 
Following the accident in 
1986, reactor unit 4 was 
encased in a ‘sarcophagus’.Figure 3Illustration of a graphite‑moderated reactor nuclear power plant (RBMK ‑1500)
Source:  ECA.SwitchyardTurbine hall
TurbineGeneratorGrid
Transformer
Condenser
Main circulation pumpFuel elements
Reactor
The reactor and the main cooling circuit components in the reactor building form the activated and contaminated circuit, which is directly connected to the turbine and 
condenser in the turbine hall. Ignalina units 1 and 2 lack a massive steel and concrete containment structure as the ﬁnal barrier against the mass release of radiation in an accident in the reactor and in main cooling circuit components.Main
circulation
pumpGraphite control
elementsCooling water 
from/back to lakeDrum form steam
separatorReactor hall/building, part
of the controlled area
15 Introduction 
The EU’s nuclear decommissioning assistance 
programmes
04 
The shutdown and subsequent decommissioning of these nuclear power plants 
before the end of their design lifetime represented a  significant financial and 
economic burden for the three Member States concerned, all the more so since 
they had not accumulated national funds to cover the full cost of decommission ‑
ing and lacked the necessary waste management infrastructure6.
05 
The EU agreed to provide financial support from 1999. This began under the 
PHARE programme, which was a pre‑accession instrument designed to chan ‑
nel financial and technical assistance to the candidate countries in central and 
eastern Europe. Once the three countries joined the EU, support continued under 
the nuclear decommissioning assistance programmes (NDAPs) on the basis of 
the provisions in the individual accession treaties and in Council regulations (see 
Annex II  for an overview)7. A separate, dedicated support programme was put in 
place for each country.
06 
Between the beginning of the support programmes in 1999 and up until 2013, 
these programmes involved:
 ο decommissioning measures to help relieve some of the financial burden 
placed on these Member States as they begin to decommission the plants;
 ο measures to help mitigate some of the effects of lost national energy produc ‑
tion capacity due to early closure.
07 
In the current 2014 ‑2020 period, only decommissioning measures8 are now eligi ‑
ble for funding under the EU’s nuclear decommissioning assistance programmes, 
which pursue the specific objectives outlined in Table 1.6 Commission staff working 
paper, ‘Nuclear 
decommissioning assistance 
programme data’ 
(SEC(2011) 914 final).
7 In addition to EU support, 
Lithuania and Bulgaria have 
also received separate grants 
from nuclear safety accounts 
managed by the European 
Bank for Reconstruction and 
Development (EBRD) for 
operational nuclear safety. 
8 Mitigation measures, 
including energy efficiency 
and renewable energy, are 
eligible for funding under the 
European Structural and 
Investment Funds, from which 
all three Member States 
benefit.
16 Introduction Table 1Specific objectives of the EU’s nuclear decommissioning assistance programmes for 
2014 ‑2020
Programme Specific objectives
Ignalina, LithuaniaDefuelling the reactor core of unit 2 and the reactor fuel ponds of units 1 and 2 into the dry spent fuel storage facility.
Safely maintaining the reactor units.
Dismantling operations in the turbine hall and other auxiliary buildings.
Safely managing the decommissioning waste in accordance with a detailed waste management plan.
Kozloduy, BulgariaDismantling operations in the turbine halls of units 1 to 4 and in auxiliary buildings.
Dismantling large components and equipment in the reactor buildings of units 1 to 4.
Safely managing the decommissioning waste in accordance with a detailed waste management plan.
Bohunice, SlovakiaDismantling operations in the turbine hall and auxiliary buildings of reactor V1.
Dismantling large components and equipment in the V1 reactor buildings.
Safely managing the decommissioning waste in accordance with a detailed waste management plan.
All Possible measures to maintain a high level of safety at the units under decommissioning, including support for the nuclear power 
plants’ personnel.
Source:  ECA, based on Council Regulations (Euratom) No 1368/2013 and No 1369/2013.
08 
By 2020, EU support will have totalled 3.8 billion euro (see Figure 4 ).Figure 4The EU’s nuclear decommissioning assistance for Lithuania, 
Bulgaria and Slovakia from 1999 to 2020
0200
100400600
500
300800
700900million euro
1999-2006
(8 years)2007-2013
(7 years)2014-2020
(7 years)Ignalina, Lithuania
Kozloduy, Bulgaria
Bohunice, Slovakia340530
201837
510
423
225293451
Source:  ECA, based on data from the European Commission.
17 Introduction 
09 
The biggest share has gone to Lithuania, followed by Bulgaria and then Slovakia 
(see Figure 5 )9.9 Throughout this report, the 
Member States are listed in 
the order of the size of their 
respective programmes as 
follows: Lithuania, Bulgaria 
and Slovakia.
10 SEC(2011) 1387 final, 
Commission staff working 
paper, ‘Impact assessment’.
11 COM(2016) 177 final of 4 April 
2016, p. 7, ‘Nuclear illustrative 
programme presented under 
Article 40 of the Euratom 
Treaty for the opinion of the 
European Economic and Social 
Committee’, in the following 
referred to as the 
Commission’s 2016 nuclear 
illustrative programme.Figure 5Share per Member State of overall EU decommissioning 
assistance from 1999 to 2020
Source:  ECA, based on data from the European Commission.Bohunice, Slovakia
849 million euro
22 %Kozloduy, Bulgaria
1 143 million euro
30 % Ignalina, Lithuania
1 818 million euro
48 %
10 
In its impact assessment prepared for the 2014 ‑2020 financial period, the Com ‑
mission stated that it did ‘not foresee any further extension of financial EU sup ‑
port’ beyond 202010.
What is nuclear decommissioning?
11 
Nuclear decommissioning is the final step in the life cycle of a nuclear power 
plant. Across Europe, a growing number of nuclear power plants are already be ‑
ing decommissioned or will be in the short/mid term. At the end of 2015 there 
were 129 nuclear reactors in operation in the EU, and a further 91 that had been 
shut down, of which three had been completely decommissioned (see Annex III ). 
It is estimated that more than 50 of the 129 reactors in operation will be shut 
down by 202511.
18 Introduction 
12 
Nuclear decommissioning involves a range of specific processes, some of which 
run in parallel. The process is complete once the site has been cleaned up to the 
point where the land can be reused or redeveloped, either without any restric ‑
tions (‘greenfield’ status) or subject to certain restrictions (‘brownfield’ status), 
according to national legislation. All three sites in Lithuania, Bulgaria and Slovakia 
are to be decommissioned to ‘brownfield’ status.
13 
All three Member States opted for the ‘immediate dismantling’ decommission ‑
ing strategy, rather than the ‘deferred dismantling’ or ‘long‑term safe enclosure’ 
strategy. With immediate dismantling, decommissioning begins shortly after the 
permanent shutdown of operation. With the alternative deferred dismantling 
strategy, once the nuclear fuel has been removed, all or part of a facility contain ‑
ing radioactive material is either processed or maintained in a safe storage state 
until it is subsequently decontaminated and/or dismantled12.
14 
Decommissioning entails both conventional industrial decommissioning work, 
such as the demolition of the turbine hall, and highly specialised activities deal ‑
ing with the radioactive material on site. Planning the correct sequence of activ ‑
ities and identifying the procedures and methodologies to be followed is key. Figure 6Status of nuclear power reactors in the EU as at 
31 December 2015
Source: ECA, based on data from the European Commission and the IAEA’s Power Reactor 
Information System (PRIS).Shut down: 
91 reactors
(of which 3 completely
decommissioned)In operation: 
129 reactorsUnder construction: 
4 reactors12 IAEA Safety Standards, 
Decommissioning of facilities 
— General safety requirements 
No. GSR part 6 , 2014.
19 Introduction 
15 
Figure 7  shows the main processes involved in decommissioning a nuclear power 
plant. Figure 7Main processes involved in decommissioning a nuclear power plant
Source:  ECA.Nuclear decommissioning processes
Ongoing tasks at the site:
 set up and maintain radiological inventory and characterisation of the facility
 set up, maintain and modify containment systems
 decontamination
Non-controlled area (mainly outside the reactor building):
 decontaminate, dismantle and remove systems, structures and machinery
 remove and contain contaminated/activated material
 remove/store low-level and intermediate-level waste
Controlled area (mainly inside the reactor building):
 decontaminate, dismantle and remove systems, structures and machinery
 remove and contain contaminated/activated material
 remove and store low-, intermediate- and high-level wasteExtract fuel 
and spent fuelfrom thereactorRelease frominstitutionalsurveillance
Leave site in
brownﬁeldor greenﬁeldstate aspre-deﬁned 
16 
Nuclear facility operators must prepare and update a final decommissioning 
plan  that contains a financing plan and sets out all the necessary activities, as 
well as their scheduling and estimated costs13. The EU support has to be imple ‑
mented in accordance with these plans, whilst, at all times, maintaining the high ‑
est level of safety14.
17 
All activities performed over the life cycle of a nuclear power plant, including 
decommissioning, are regulated and require a  licence from a  national authority.13 IAEA Safety Standards, General 
safety requirements part 6 , pp. 
15‑16.
14 Article 2(1) of Council 
Regulations (Euratom) 
No 1368/2013 and 
No 1369/2013.
20 Introduction 
Radioactive waste management
18 
All stages of the nuclear fuel cycle generate radioactive waste. The International 
Atomic Energy Agency’s (IAEA) classification scheme defines six classes of radio ‑
active waste, depending on the level of radioactivity, as shown in Table 2 .Table 2Classes of radioactive waste and their management and disposal
Class DescriptionManagement and disposal  
(underground depths indicative only)
ExemptWaste that contains such small concentrations of 
radionuclides that it does not require provisions for 
radiation protection and can be cleared from regula ‑
tory control.ground level free release, waste dump
Very short‑livedWaste that contains only radionuclides of a very 
short half‑life with activity concentrations above 
clearance levels. ground level decay storage
Very low‑levelWaste that does not necessarily meet the criteria for 
exempt waste, but that does not need a high level of 
containment and isolation.ground level landfill
Low‑levelWaste with limited amounts of long‑lived radio ‑
nuclides. Such waste requires robust isolation and 
containment for periods of up to a few hundred 
years.underground near surface (< 30 metres)
Intermediate‑levelWaste that, because of its content, particularly of 
long‑lived radionuclides, requires a  greater degree 
of containment but no, or only limited, provision for 
heat dissipation.underground intermediate depth (30 ‑100 metres)
High‑levelWaste with levels of activity concentration high 
enough to generate significant quantities of heat 
or with large amounts of long‑lived radionuclides. 
Spent nuclear fuel falls under this category.underground geological disposal (> 400 metres)
Source: ECA, based on IAEA Safety Standards, Classification of radioactive waste — General safety guide No. GSG-1 , 2009.
21 Introduction 
19 
Each class requires different technologies and methods for its safe containment 
and management. At the lowest end of the spectrum, exempt waste can simply 
be disposed of along with domestic refuse. At the other extreme, high‑level 
waste, such as spent nuclear fuel, is so highly radioactive that it requires the 
greatest degree of containment and isolation to ensure long‑term security and 
safety. Disposal in a deep geological repository, excavated several hundred 
metres below ground, is generally recognised as the preferred option for the 
final disposal of high‑level waste15. According to the IAEA Safety Standards, waste 
management is still not complete when the nuclear decommissioning process 
ends, since the high‑level waste has not yet been disposed of in a final disposal 
facility16.
‘Polluter pays’ as an EU and international principle
20 
The management of spent fuel and radioactive waste in the European Union 
is governed by the radioactive waste directive17. Its requirements are based on 
a 1997 IAEA convention to which Lithuania, Bulgaria and Slovakia are signato ‑
ries18. This convention obliges its contracting parties to apply the ‘polluter pays’ 
principle, meaning that the producers of waste should bear the costs of man ‑
aging it to prevent damage to human health and the environment19. A further 
principle underpinning the convention is that the burden of nuclear waste man ‑
agement not be unduly imposed on future generations. This is reflected in the 
radioactive waste directive, which states that ‘it should be an ethical obligation of 
each Member State to avoid any undue burden on future generations in respect 
of spent fuel and radioactive waste including any radioactive waste expected 
from decommissioning of existing nuclear installations’20.
The roles and responsibilities of actors under the EU’s 
nuclear decommissioning assistance programmes
21 
As permitted under the relevant legal provisions, the European Commission  has 
opted to manage the nuclear decommissioning assistance programmes via indir ‑
ect management21. In this management mode, the Commission entrusts budget 
implementation tasks to implementing bodies  (see Annex IV ), but retains overall 
responsibility and accountability for EU budget implementation. The Commis ‑
sion therefore has to ensure that the implementing bodies have adequate control 
and monitoring structures in place. The European Bank for Reconstruction 
and Development  (EBRD) acts as an implementing body for all three of these 
programmes.15 IAEA Safety Standards, General 
safety guide No. GSG-1 
— Classification of radioactive 
waste , 2009, p. 6.
16 IAEA Safety Standards, General 
safety guide No. GSG-1 
— Classification of radioactive 
waste , 2009, p. 3.
17 Council Directive 2011/70/
Euratom of 19 July 2011 
establishing a Community 
framework for the responsible 
and safe management of 
spent fuel and radioactive 
waste (OJ L 199, 2.8.2011, 
p. 48).
18 IAEA, Joint Convention on the 
Safety of Spent Fuel 
Management and on the 
Safety of Radioactive Waste 
Management.
19 Article 21 of the IAEA Joint 
Convention on the Safety of 
Spent Fuel Management and 
on the Safety of Radioactive 
Waste Management reads: 
‘Each Contracting Party shall 
ensure that prime 
responsibility for the safety of 
spent fuel or radioactive waste 
management rests with the 
holder of the relevant licence 
and shall take the appropriate 
steps to ensure that each such 
licence holder meets its 
responsibility.’
20 Recital 24 of Council Directive 
2011/ 70/Euratom.
21 Article 58(c) of Regulation (EU, 
Euratom) No 966/2012 of the 
European Parliament and of 
the Council of 25 October 2012 
on the financial rules 
applicable to the general 
budget of the Union and 
repealing Council Regulation 
(EC, Euratom) No 1605/2002 
(OJ L 298, 26.10.2012, p. 1), last 
amended by Regulation (EU, 
Euratom) No 2015/1929 of 
28 October 2015.
22 Introduction 
22 
In addition, in Lithuania the Central Project Management Agency , a national 
public‑sector body, acts as a second implementing body, and performs the same 
functions as the EBRD for the projects placed under its management22. At the 
time of the audit, all new projects were channelled through the Central Project 
Management Agency. The EBRD will remain in charge of the projects that were 
previously placed under its responsibility.
23 
The three Member States  are obliged to establish appropriate national struc ‑
tures for programme implementation and to take all the necessary steps to 
remove any legal or administrative obstacles to the proper functioning of their 
respective decommissioning programmes23. The Member States designate 
a programme coordinator, from the ministry responsible for energy policy, who 
assumes overall responsibility for the planning, coordination and monitoring of 
the respective decommissioning programmes at national level.
24 
Lithuania has also appointed the Ministry of Finance to act as the financial coord ‑
inator responsible for the financial oversight of the Central Project Management 
Agency.
25 
The programmes’ main beneficiaries  are the nuclear power plant operators and/
or the decommissioning licence holders, which are state enterprises. They are 
responsible for executing projects once proposals have been approved.
26 
Each year the Member States propose an annual work programme outlining the 
envisaged use of funding. The Commission then approves the financing deci ‑
sions, after consulting the Nuclear Decommissioning Assistance Programme 
Committee, composed of representatives from the 28 EU Member States. It also 
approves the documentation on the individual projects to be financed using 
EU assistance, as selected by the implementing body. Following coordination at 
national level, new project proposals are submitted by the programme coordina ‑
tor for approval to the EBRD and, in Lithuania, to the Central Project Management 
Agency. After verification, the project proposals are submitted by the implement ‑
ing bodies to the Commission.22 Slovakia has formally 
proposed setting up a second, 
national implementation 
channel, with the Slovak 
Innovation and Energy 
Agency operating alongside 
the EBRD.
23 Article 4 of the Commission 
Implementing Decision of 
7.8.2014 on the rules of 
application for the nuclear 
decommissioning assistance 
programmes for Bulgaria, 
Lithuania and Slovakia for the 
period 2014 ‑2020, 
C(2014) 5449 final.
23 Introduction 
24 Special Report No 16/2011, E‘U 
financial assistance for the 
decommissioning of nuclear 
plants in Bulgaria, Lithuania 
and Slovakia: achievements 
and future challenges’ (http://
eca.europa.eu).27 
The Commission then transfers the relevant funds to the EBRD, as well as, for 
Lithuania, to the Central Project Management Agency, according to contractual 
arrangements. These bodies then monitor project implementation.
Previous ECA special report on nuclear 
decommissioning
28 
In a 2011 special report, the European Court of Auditors previously examined the 
EU’s financial assistance for the decommissioning of nuclear plants in Bulgaria, 
Lithuania and Slovakia24.
24
 Audit scope and approach
25 Special Report No 16/2011.29 
This audit sought to determine whether progress has been made in the imple ‑
mentation of the EU’s nuclear decommissioning assistance programmes for Lithu ‑
ania, Bulgaria and Slovakia since 2011, when we published our previous report25.
30 
In particular, we examined whether the programmes had made progress in terms 
of:
— dismantling the plants, obtaining the necessary licences and putting in place 
spent fuel and waste management infrastructure;
— establishing a reliable assessment of costs and securing the necessary funds 
to complete decommissioning.
31 
In each of the three Member States we visited the sites concerned, analysed 
programme and project documentation and interviewed Member State officials, 
nuclear power plant operators, national radioactive waste management licence 
holders, regulatory authorities, and officials from the implementing bodies and 
the European Commission.
32 
To assess progress at project level, we selected 17 EU‑funded infrastructure and 
non‑infrastructure nuclear decommissioning projects across the three Member 
States (see Annex V ). We selected projects where we had made the most critical 
findings in our previous report and other projects which are crucial for decom ‑
missioning. We also gathered data on the delays and cost overruns affecting 18 
ongoing key infrastructure projects ( Annex VI ).
33 
We also identified, where possible, examples of emerging practice improvement 
in the three Member States and general forward thinking. To this end, we includ ‑
ed a visit to the construction site of the world’s first deep geological repository in 
Finland (see Annex VII ).
25 Audit scope and approach 
34 
The audit work was carried out from April 2015 to April 2016.
35 
Our audit did not cover the compliance of project expenditure with fund‑specific 
rules. Nor did it cover public procurement procedures. We did not assess the 
radioactive security or the safety of installations, since this is the responsibility 
of the relevant national authorities. We in no way sought to make a case for or 
against nuclear energy, nor to draw conclusions on the energy supply mix in the 
EU; such matters are not discussed in this report.
26
 Observations
26 SEC(2011) 1387 final of 24 
November 2011, ‘Commission 
staff working paper — Impact 
assessment — Accompanying 
document to the proposal for 
a Council regulation on Union 
support for the nuclear 
decommissioning assistance 
programmes in Bulgaria, 
Lithuania and Slovakia’.
27 According to information 
provided by the Ignalina 
nuclear power plant, unit 1 
achieved irreversible status in 
2007, when its operational 
licence was changed and the 
conditions for implementation 
of its decommissioning were 
approved. On 16 June 2014 a 
law was rescinded which 
prohibited the irreversible 
termination of operations at 
unit 1 until the financing for all 
works pertaining to the stage 
or decommissioning of the 
facility had been assured. Unit 
2’s licence was changed in 
2012 and 2014. The Bulgarian 
Minister of Energy said during 
a plenary session of the 
Bulgarian Parliament held on 
6 February 2015 that the 
decommissioning of the four 
units concerned was 
irreversible. The Slovakian 
authorities regard the change 
to the decommissioning 
licence as achievement of the 
irreversible state.Some decommissioning progress made since 2011, but 
critical challenges ahead
36 
This section sets out our findings regarding progress made since 2011 in the de ‑
commissioning process supported by the EU’s assistance programmes, highlight ‑
ing any delays affecting key infrastructure projects.
Progress made in non‑controlled areas, but decommissioning 
of reactor buildings yet to begin and radioactive waste 
management infrastructure only partially complete
37 
For each of the three nuclear power plants, we examined:
— the extent to which the closure of the nuclear power plants is irreversible;
— the progress made in dismantling activities in the non‑controlled and con ‑
trolled areas;
— the availability of the spent fuel and waste management infrastructure re ‑
quired for decommissioning and dismantling activities.
National authorities state that closure of the plants is now 
irreversible but Commission expected outputs have not yet been 
achieved
38 
In 2011 the Commission identified four expected outputs which had to be met 
before the closure of a nuclear power plant could be deemed irreversible26. 
 Table 3  shows our assessment of the extent to which these expected outputs 
have been achieved in Lithuania, Bulgaria and Slovakia.
39 
The authorities in Lithuania, Bulgaria and Slovakia claim that  the progress 
achieved means that closure is now effectively irreversible, since it would no 
longer be technically viable or cost‑effective to resume operations27.
27 Observations 
The ECA’s assessment of achievement of expected outputs indicating irreversible 
closure of the three nuclear power plants as at 31 December 2015
Expected outputs Ignalina, Lithuania Kozloduy, Bulgaria Bohunice, Slovakia
1. The nuclear power plant 
is safely maintained in 
post‑shutdown mode until 
complete defuellingPartially achieved
Safe maintenance ongoing. Reactor 1 is 
defuelled. Reactor  2 not yet defuelled.Achieved
Reactors and fuel ponds 
defuelled.Achieved
Reactors and fuel ponds defuelled.
2. Decommissioning licence is 
in placeNot achieved
Licence not yet issued.Partially achieved
Licence issued for units 1 ‑2, 
expected for units 3 ‑4 in 2016.Achieved
Licence issued in 2015.
3. The design for the 
dismantling of the reactor core/
primary circuit is completePartially achieved
Design of the dismantling process not 
yet completed, study under way (see 
Annex V , Project 6)Partially achieved
Project to design dismantling pro ‑
cess in the procurement phase.Partially achieved
Project to design dismantling pro ‑
cess still in progress (see Annex V , 
Project 16)
4. Dismantling in the reactor 
building has startedPartially achieved
Only minor works in the reactor building 
to date.Partially achieved
Only minor works in the reactor 
building to date.Partially achieved
Only minor works in the reactor 
building to date.
Source:  ECA, based on information from national authorities.Table 3
40 
However, one expected output for assessing whether the nuclear decommission ‑
ing process has reached an irreversible state is the existence of a decommission ‑
ing licence, which is required before work can begin in the controlled area. Since 
2011, while both Bulgaria and Slovakia have progressed from an operational to 
a decommissioning licence for the plants concerned, Lithuania has not.
— Ignalina, Lithuania , has yet to obtain its decommissioning licence and is now 
not scheduled to do so until 2022, 10 years later than originally planned and 
18 years after unit 1 stopped producing electricity.
— Kozloduy,  Bulgaria , obtained a  10‑year decommissioning licence for its 
first two units on 27 November 2014, and is expecting its decommissioning 
licence for units 3 and 4 in 2016. However, additional permits might still be 
required to perform any major work dismantling the critical reactor systems 
or the reactor itself.
— Bohunice,  Slovakia , received its current decommissioning licence on 23 De ‑
cember 2014, which gives it the green light to begin the dismantling process 
in the reactor building. The decommissioning plan did not schedule the start 
of major dismantling work until the end of 2015. Major dismantling work has 
not started yet.
28 Observations 
Progress made in dismantling activities in the non‑controlled area
41 
As shown in Table 3 , none of the three plants has yet completed the designs 
for the dismantling of the reactor cores/primary circuits or performed any more 
than minor works in the reactor building. This means that the critical challenges 
involved in working in the controlled area, including the reactor building, still lie 
ahead for all three Member States.
42 
Progress has, however, been made with the dismantling activities in the non‑  
controlled area. Since our previous report, at all three locations, the dismantling 
of certain key components, like the turbine halls in the non‑controlled area, has 
advanced (see example in Figures 8 and 9 ). In Lithuania, dismantling started later 
than planned, but has been progressing since 2014. Figures 8 and 9Photos showing progress in the dismantling of key components in the turbine hall 
at Bohunice V1 nuclear power plant, Slovakia
Figure 8 — Before dismantling Figure 9 — After dismantling
2011:  Turbine hall with turbines
© Javys.2015:  Turbine hall without turbines
© Javys.
29 Observations 
Some progress in waste management infrastructure but final 
disposal facilities for spent fuel only at conceptual phase
43 
A licence to advance in the decommissioning process will only be issued if, inter 
alia, adequate waste management solutions and infrastructure are in place. Since 
the various waste types generated are handled differently (see Table 2 ), a suf ‑
ficiently complete radiological inventory and characterisation of the facility and 
radioactive waste is necessary in order to determine accurately the methodolo ‑
gies and technologies needed to decontaminate, dismantle and fragment sys ‑
tems and structures, as well as to select the most appropriate waste management 
solutions. All three Member States have made some progress in this regard since 
our last audit. However, although generally on track according to the decommis ‑
sioning plans, the radiological characterisation of the reactor buildings is not yet 
comprehensive at any of the three plants.
44 
Regarding very low ‑ to intermediate‑level waste  (see Table 4 ), all three Mem ‑
ber States have made some progress in constructing the main required waste 
management infrastructure. The infrastructure in place meets current needs at 
this stage of the decommissioning process. As a result, there is no imminent risk 
at any of the three plants of decommissioning needing to be suspended due to 
insufficient waste management infrastructure capacity. However, several projects 
for handling waste of higher radioactivity levels or future increased volumes 
are facing delays and some remain in the design phase (see Table 4  and para ‑
graphs 60 to 71).
45 
High‑level waste  principally takes one of two forms: spent nuclear fuel for 
disposal, or the waste materials which remain once spent nuclear fuel has been 
reprocessed. In general, spent nuclear fuel accounts for 95 % of the high‑level 
waste volume and holds between 95 % and 99 % of the nuclear power plant’s 
overall radioactivity. Once the spent nuclear fuel elements have been removed 
from the reactor (see Figure 10 ) they are either reprocessed or placed in interim 
storage for around 50 years.
30 Observations 
Progress in constructing infrastructure for managing very low ‑ to intermediate‑level 
waste, 2011  and  2015
2011 2015
Ignalina,  
LithuaniaWork on the ‘buffer storage’ for the landfill facility for 
very low‑level waste ongoing.Buffer storage completed and filled to 80 % of its current capacity.
Construction of the above‑surface facility not yet 
started.Construction of the above‑surface facility not yet started since tendering is 
delayed due to changes in the technical design.
Near‑surface repository for low‑ and medium ‑level, 
short‑lived, waste in design phase.Near‑surface repository is still in the design phase and delayed by 1 year.
Solid waste management and storage facility for 
long‑lived medium ‑level waste delayed by 3.5 years.Solid waste management and storage facility is delayed by 9 years. 
Operational acceptance planned for 2018. No facility available for storage of 
reactor dismantling waste, although a related project has begun.
Kozloduy, 
BulgariaUse of existing storage and treatment facilities on site, 
but additional storage and treatment capacity needed 
for future decommissioning.According to an assessment made by the decommissioning licence holder 
State Enterprise Radioactive Waste Management (SERAW), the capacity of 
the existing radioactive waste storage facilities should suffice until 2022.
National disposal facility for low‑ and intermediate‑ 
level radioactive waste to be constructed by the end 
of 2015.The national disposal facility for low‑ and intermediate‑level radioactive 
waste, the main missing element, is delayed by 6 years. Expected comple ‑
tion 2021 (see paragraph 56).
Bohunice, 
SlovakiaUse of existing storage and treatment facilities on site. 
Additional storage and treatment capacity needed for 
future decommissioning.Ongoing project to increase the capacity of the national radioactive waste 
repository for very low‑level waste to be finished in 2018.
Source:  ECA, based on information from national authorities.
Storage basket for VVER440/230 
spent nuclear fuel elementsTable 4 Figure 10
© Javys.
31 Observations 
46 
While defuelling is complete in Bulgaria  and Slovakia , in Lithuania  unit 2 is still 
partially fuelled and the storage pools in unit 1 are still filled with spent nuclear 
fuel. In Bulgaria and  Slovakia , the spent nuclear fuel elements are still classified 
as material for potential future use, although some of this material will unavoid ‑
ably require permanent disposal. Table 5  provides an overview of the classifica ‑
tion of spent nuclear fuel, its current storage location and means and the status 
of the interim spent nuclear fuel management infrastructure.
Overview of storage and classification of spent nuclear fuel
Reactor core 
defuelled?Reactor and 
storage ponds 
defuelled?Classification of 
the spent nuclear 
fuelCurrent location of 
spent nuclear fuelFinal repository for 
spent nuclear fuel 
disposal available?
Ignalina, 
LithuaniaUnit 1 Yes No High‑level wasteIn reactor ponds in unit 1 
and in interim spent fuel 
dry storage on siteNo
Unit 2 No No High‑level wasteIn unit 2 reactor core and in 
unit 2 reactor pondsNo
Kozloduy, Bulgaria Yes YesMaterial for poten ‑
tial future useInterim spent fuel wet and 
dry storage facility on site, 
partial shipment to RussiaNo
Bohunice V1, Slovakia Yes YesMaterial for poten ‑
tial future useInterim spent fuel wet 
storage facility on siteNo
Source:  ECA, based on information from national authorities.Table 5
47 
Table 6  provides an overview of the progress made with infrastructure for the 
interim storage of spent nuclear fuel  since 2011. In particular, progress in Lithu ‑
ania has been held back by delays in the construction of the interim spent fuel 
storage facility.
32 Observations 
Progress in infrastructure for the interim storage of spent nuclear fuel, 2011  and  2015
2011 2015
Ignalina, 
LithuaniaUnits could not be defuelled until the interim storage 
facility for spent fuel was operational, but this project 
was 4 years behind schedule.Construction of the interim spent fuel storage facility has been delayed 
by a further 6 years, putting it 10 years behind schedule compared with 
the 2005 final decommissioning plan. Its completion is a precondition to 
obtaining a  decommissioning licence.
Kozloduy, 
BulgariaSignificant delays and budget overruns affecting the de ‑
sign and construction of an interim spent fuel dry storage 
facility for storing spent fuel assemblies in casks.Takeover certificate was obtained in March 2013 and, by 2015, six loaded 
casks had been stored out of the 34 planned. A 10 ‑year licence to oper ‑
ate the storage facility was obtained on 29 January 2016.
Bohunice, 
SlovakiaInterim spent fuel wet storage facility available.Spent fuel from the V1 nuclear power plant is stored in the interim spent 
fuel storage facility on site. Its storage capacity will suffice until 2024 
when including spent nuclear fuel from other plants. Pending a decision 
on final disposal, there are plans to build an interim spent fuel dry 
storage facility.
Source:  ECA, based on information from national authorities.Table 6
48 
The interim storage of spent nuclear fuel is a temporary solution prior to final dis ‑
posal. Final disposal in a deep geological repository , usually several hundred 
metres or more below ground, is generally recognised as the preferred option for 
the disposal of high‑level waste (see Annex VII for an example). In principle, each 
country with a nuclear programme should devise a programme for constructing 
an adequate repository28. However, some countries may generate low radioactive 
waste volumes, have limited financial resources or lack appropriate geological 
conditions29. As shown in Table 5 , not one of the three Member States concerned 
currently has access to such a repository for final disposal. Other EU Member 
States face the same challenges.
49 
Access to a final disposal site could be ensured through multinational cooper ‑
ation. With a ‘multinational repository’, waste originating from more than one 
country is disposed of in a common repository. If all the participating countries 
are in the same neighbourhood, the repository is often referred to as a ‘regional 
repository’30.28 IAEA, ‘Developing 
multinational radioactive 
waste repositories: 
Infrastructural framework and 
scenarios for cooperation’, 
October 2004. IAEA Joint 
Convention on the Safety of 
Spent Fuel Management and 
on the Safety of Radioactive 
Waste Management.
29 IAEA, ‘Developing 
multinational radioactive 
waste repositories: 
Infrastructural framework and 
scenarios for cooperation’, 
October 2004. IAEA Joint 
Convention on the Safety of 
Spent Fuel Management and 
on the Safety of Radioactive 
Waste Management.
30 IAEA, ‘Developing 
multinational radioactive 
waste repositories: 
Infrastructural framework and 
scenarios for cooperation’, 
October 2004, p. 5.
33 Observations 
50 
The EU’s radioactive waste directive leaves room for regional cooperation in this 
area and expressly acknowledges that ‘some Member States consider that the 
sharing of facilities for spent fuel and radioactive waste management, includ ‑
ing disposal facilities, is a potentially beneficial, safe and cost‑effective option’31. 
However, some EU Member States restrict the import of nuclear waste in their 
national legislation. For example:
— Lithuania  prohibits the import of radioactive waste and spent nuclear fuel, 
except for (a) the transit of radioactive waste and spent nuclear fuel through 
Lithuania and (b) the reimport of radioactive waste and spent fuel processed 
abroad32;
— Bulgaria prohibits the import of radioactive waste, except (a) upon reimport 
of used sealed sources of ionising radiation manufactured in Bulgaria and (b) 
radioactive waste reprocessed as a service for Bulgaria33;
— Slovakia  prohibits the import of radioactive waste, except for (a) transport 
through the country and (b) imports of radioactive waste for reprocessing 
and treatment34.
51 
Throughout the EU, only one deep geological repository is currently under con ‑
struction, in Finland (see Annex VII ). From the adoption of the Finnish govern ‑
ment’s first decision on the implementation timetable and the beginning of site 
screening in 1983, nearly 40 years will have passed before disposal can begin 
(Figure 11  shows the project timeline). Disposal of spent fuel is planned to start 
in the early 2020s.31 See recital 33 of Council 
Directive 2011/70/Euratom. On 
the conditions for import and 
export, see Article 4(4) of the 
radioactive waste directive 
and Council Directive 
2006/117/Euratom of 
20 November 2006 on the 
supervision and control of 
shipments of radioactive 
waste and spent fuel (OJ L 337, 
5.12.2006, p. 21).
32 See Article 24 of Lithuanian 
Law No VIII ‑1190 of 20 May 
1999 on radioactive waste 
management.
33 See Article 17 of the Bulgarian 
Act on the Safe Use of Nuclear 
Energy (last amended on 28 
November 2014).
34 See the Slovak Act 541/2004 
Coll, the peaceful use of 
nuclear energy and its Article 
21 on ‘imports of radioactive 
waste’.
34 Observations 
Timeline of the Finnish deep geological repositoryFigure 11
 
TIME SPAN OF FINAL
DISPOSAL
Geological
screeningfor /f_inaldisposalsstarts
Governmentdecision on overall scheduleDecision-In-Principleby theGovernmentand theParliamentConstructionlicenceapplicationConstruction
licenceOperating licence
application SitecharacterisationOlkiluoto
selectedas /f_inaldisposalsiteConstructionof ONKALOand sitecon/f_irmationstudies startsin OlkiluotoConstructionof the /f_inaldisposalfacilityPreopera-tional testsand com-missioningStart ofdisposal inearly 2020 ’s
19781983200120122015
© Posiva Oy.
52 
Other Member States are also currently working on preparations for a  deep 
 geological repository, and are at different stages along the timeline.
— In Sweden , an application for the construction of a deep geological reposi ‑
tory at the chosen site of Forsmark is under review by the Swedish Radiation 
Safety Authority. Construction and commissioning are scheduled for comple ‑
tion by 202835.
— In France , an application for construction could be submitted in 2017/2018. 
The pilot operation phase is scheduled between 2025 and 2035, with com ‑
mercial exploitation starting after 203536.35 SWD(2016) 102 final of 4 April 
2016, ‘Commission staff 
working document, 
accompanying the document 
“Communication from the 
Commission — Nuclear 
illustrative programme 
presented under Article 40 of 
the Euratom Treaty for the 
opinion of the European 
Economic and Social 
Committee”’, p. 30.
36 http://www.developpement ‑
durable.gouv.fr/Calendrier ‑du‑
projet.html ‑+.
35 Observations 
— In Germany , the Commission for the Storage of High‑level Radioactive Waste 
has been tasked with drafting a report by the end of 2016 as preparation for 
the process of selecting a site. Under national law, a decision on site selection 
should be taken by 2031. At the earliest disposal could start 2045/205037.
53 
Under the EU’s 2011 radioactive waste directive, Member States had to prepare 
their national programme by August  2015, including their plans for final dispos ‑
als. The Commission is obliged to report to the Parliament and the Council on the 
implementation of this directive, but has not yet done so38.
54 
We analysed the respective national programmes of the three Member States 
and concluded that Lithuania, Bulgaria and Slovakia have only just begun dis ‑
cussing potential final disposal solutions, so talks are at a conceptual stage.
55 
In Bulgaria, the national programme lists three options for dealing with its 
high‑level waste including spent fuel, as follows.
— Reprocessing in other countries.
— Participating in regional or international final disposal solutions, without 
jeopardising the implementation of the national programme.
— Disposing of the high‑level waste in Bulgaria.
 Bulgarian authorities interviewed during the audit expressed a  preference for 
the second, regional option, owing to concerns regarding the country’s small 
nuclear capacity, its geological and climatic conditions, legislation, public 
opinion, financial capabilities and the volume of the high‑activity radioactive 
waste. A final decision on which option to choose is scheduled to be reached 
by 2030. As a temporary solution, the national programme envisages the 
construction of a pre‑disposal storage facility.37 Prozesswege zu einer sicheren 
Lagerung hoch radioaktiver 
Abfälle unter Aspekten der 
Rückholbarkeit/Bergbarkeit/
Reversibilität, Papier der 
Vorsitzenden unter 
Einbeziehung von 
Kommentaren weiterer 
Mitglieder der AG 3 , online: 
http://www.endlagerbericht.
de, accessed on 11 April 2016, 
p. 4.
38 Article 14(1) of Council 
Directive 2011/70/Euratom.
36 Observations 
56 
In Lithuania , the national programme adopted in December 2015 envisages 
the construction of a final repository in Lithuania. Nevertheless, the interviewed 
Lithuanian authorities echoed the concerns cited by the Bulgarian authorities, as 
well as their preference for a  regional scheme.
57 
In Slovakia , the national programme lists two options:
— disposal in a deep geological repository in Slovakia, for which a cost estimate 
is included in the programme;
— monitoring and support for building an international repository.
58 
None of the three Member States indicated which region or countries might be 
involved in a potential regional or other EU‑based solution.
Nearly all the key decommissioning infrastructure projects 
have experienced delays
59 
To determine the decommissioning progress achieved since 2011, we gathered 
data on a sample of 18 key decommissioning infrastructure projects and support ‑
ing projects in each of the three Member States, financed by the EU assistance 
programmes (see Annex VI )39.
60 
Nearly all the sampled key decommissioning infrastructure projects experienced 
delays between 2011 and 2015. As can be seen from Annex VI , from the begin ‑
ning of their implementation until the end of 2015, they had accumulated delays 
of up to around 10 years. These delays are among the main reasons for Lithuania 
having postponed the final decommissioning end date by a  further 9  years since 
our previous report in 2011. The decommissioning end date in Lithuania is now 
2038.39 These 18 projects account for 
587 million euro of the EU 
contribution to 
decommissioning activities, or 
around 37 % of contracted EU 
financing (excluding 
mitigation measures) since 
2001.
37 Observations 
61 
Our 2011 report noted that in Lithuania , implementation of the interim spent 
fuel storage facility  project (see Figure 12 ) had fallen behind by over 4 years, as 
stated in Table 6 . Since then, a further 6 ‑year delay has built up. Project progress 
was particularly slow between 2011 and 2014. It was only at the beginning of 
2013 that decisions were taken to start to turn the project around. Delays to this 
project have held up reactor defuelling (see Project 1 in Annex V ).Figure 12Interim spent fuel storage facility at the Ignalina nuclear power plant, Lithuania
© I N PP. © INPP. 
62 
Another key project in Lithuania, the solid waste retrieval treatment and stor ‑
age facility , has fallen behind by a further 5 years since our last audit, resulting 
in a total delay of 9 years. The related commercial disputes have been settled 
with the contractor and the EU assistance programme has paid 55 million euro in 
compensation; a further 17.9 million euro has been set aside for anticipated risks.
63 
The main reasons for the delays in Lithuania included contractual disputes, 
poor information on how the plant was actually built, incomplete data on the 
facility and on spent fuel and insufficient coordination and supervision of sub‑  
contractors’ work.

38 Observations 
64 
While there have also been project delays in Bulgaria and Slovakia, these have 
not led to a  postponement of the planned decommissioning end date. In Slo ‑
vakia, the end date has remained at 2025. In Bulgaria, this date has even been 
brought forward by 5 years, from 2035 to 2030, although this is attributable to 
the 2011 national strategy for spent fuel and radioactive waste management 
formally resolving upon a brownfield end state, thus eliminating the greenfield 
option, which would require more time.
65 
In Bulgaria , examples of project delays include the following.
— The construction of a key radioactive waste management facility, the nation ‑
al disposal facility for low ‑ and intermediate‑level radioactive waste , 
was planned for completion in 2015 (See Table 4 and Figure 13 ). However, 
the process has fallen behind by 6 years, mainly due to the rejection of 
the Environment Impact Assessment, which had to be restarted and is still 
 ongoing. The deadline for completing this facility is now 2021 (see  Proje c t 11 
in Annex V ).
Site awaiting the national disposal facility for low ‑ and 
intermediate‑level radioactive waste in BulgariaFigure 13
© SERAW.
— The construction of the plasma melting facility , a facility for treating and 
conditioning solid waste with a high‑volume reduction factor, is almost 
5 years behind schedule. This has occurred because of challenges in de ‑
termining first‑in‑kind technological solutions, changes in the regulatory 
framework leading to three revisions to the facility’s design and the appeal of 
the environmental impact assessment. A  construction permit was issued on 
14 May 2015 and completion is now expected in June 2017 (see Figure 14  and  
Project  11 in  Annex V ).
39 Observations 
66 
In Slovakia , the project decontaminating the primary circuit (see  Figure 15 ), 
which needs to be completed before the heart of the reactor building can be 
dismantled, was originally scheduled for completion in 2014. Since several techni ‑
cal challenges remain unresolved, the project’s ultimate completion date was still 
unknown at the end of January 2016, as was the impact this delay would have on 
costs and the overall decommissioning schedule (see Project 16 in  Annex V ).Preparatory works for the installation of the plasma 
melting facility
A VVER440/230 ‑type reactor and the main components 
in the primary cooling circuitFigure 14 Figure 15© SERAW.
© Javys.

40 Observations 
67 
The examples above illustrate that there have been various reasons for the delays 
encountered in the three Member States, including:
— challenges in determining and implementing first‑in‑kind technological 
solutions;
— incomplete historical operational data and poor information on how the 
plant was actually built;
— incomplete inventory and/or characterisation of waste, particularly for the 
reactor buildings.
68 
In some instances, project progress was hampered by the need to substantially 
modify plans, or even terminate projects completely, despite proposals having 
already gone through several rounds of scrutiny. This suggests that there were 
difficulties in selecting and designing projects. It also points to the challenges 
that the ministries, national authorities and final beneficiaries are facing as the 
decommissioning advances to the critical stage of tackling the reactor buildings, 
where specific knowledge and experience is required to dismantle, move and 
store structures and components from the controlled area.
69 
At the same time, there has been a reliance, particularly among the decommis ‑
sioning licence holders, on external experts such as consultants, engineers and 
lawyers (see Table 7  for external expert costs). Although the use of external 
experts is required under EBRD rules and was indispensable in the planning and 
early implementation stages, the use of experts should decrease over the years, 
as knowledge is transferred to local staff.
External expert costs in 2001 ‑2015 and their proportion of the EU support allocated 
to decommissioning
Ignalina, Lithuania  
2001 ‑2016Kozloduy, Bulgaria  
2001 ‑20151Bohunice, Slovakia  
2003‑ 2016
Million euro % of EU support Million euro % of EU support Million euro % of EU support
75 9 99 20 45 9
1 Figures in Bulgaria include one contract for the project management unit which runs from 2016 ‑2019.
Source:  ECA, based on project data provided by the implementing bodies and nuclear decommissioning project monitoring reports.Table 7
41 Observations 
70 
In addition, the EU‑wide shortage of qualified, experienced engineers poses 
a risk. This is especially the case in Lithuania, which is facing a lack of internation ‑
al experience in dismantling its RBMK‑type reactor, which is the first of its kind to 
be decommissioned (see paragraph 2)40.
71 
The three Member States are seeking to build up their technical capacity and 
enhance knowledge‑sharing. For example:
— In Bulgaria , in April 2013, the two different project management units, re ‑
sponsible for decommissioning and the construction of the national disposal 
facility for low ‑ and intermediate‑level radioactive waste, were merged and 
embedded within SERAW, which is the decommissioning licence holder. The 
external consultant assisting this integrated project management unit is 
embedded within SERAW’s organisational structure. The external consult ‑
ant’s staff located on site work in pairs with their local counterparts for each 
project. Ultimate decision‑making power rests with the head of the project 
management unit, who is a local SERAW employee. This has led to increased 
responsibility and ownership.
— In Slovakia , JAVYS a.s., the Slovak state enterprise responsible for de ‑
commissioning and radioactive waste management, organised a  2‑day 
 knowledge‑sharing seminar in March 2015 with representatives from the Ign ‑
alina, Bohunice and Kozloduy nuclear power plants, the EBRD, the European 
Commission and the Slovak Ministry of the Economy.40 The shortage of qualified 
engineering resources has 
been noted in a European 
Commission report entitled 
Putting into perspective the 
supply of and demand for 
nuclear experts by 2020 within 
the EU-27 nuclear energy sector , 
2012.
42 Observations 
Estimated cost of decommissioning will be at least 
5.7 billion euro and double this if the cost of final 
disposal is included
72 
Our previous report observed that all three national decommissioning plans and 
their cost estimates were incomplete. Significant financing gaps were found. This 
audit analysed how decommissioning costs and the level of available financing 
have evolved, at both EU and national levels. We also sought to estimate the full 
cost, including final disposal, which the three Member States will face and ana ‑
lysed the ways in which liabilities for future costs are accounted for.
Total estimated decommissioning cost has increased by 40 % 
to 5.7 billion euro since 2010
73 
Our previous report recommended a  comprehensive assessment of the costs 
 arising from nuclear decommissioning. In 2014 the Member States updated the 
nuclear decommissioning cost estimates set out in the final decommissioning 
plans which they had previously submitted to the Commission. Slovakia made 
further minor changes in 2015. These updates, intended to provide a fuller pic ‑
ture, saw cost estimates increase by 40 %, from 4.1 billion euro in 2010 to 5.7 bil ‑
lion euro in 2015. The increase was most pronounced between 2010 and 2011 
(see Figure 16 ). There were significant differences between the three Member 
States. Lithuania  accounted for most of the estimated cost increase, with a 67 % 
rise between 2010 and 2015. In the same period, the cost estimate for Bohunice, 
Slovakia, has also risen, by 30 %. The cost estimate for Kozloduy, Bulgaria, has 
remained largely unchanged. After an initial increase in 2011, the cost estimate 
made after the decision to move the deadline forward saw costs decrease by 
136 million euro (see paragraph 64).
74 
Since 2011 all three Member States have improved their approach to estimating 
the cost of nuclear decommissioning activities in their final decommissioning 
plans. They now use the latest methodology known as the International Structure 
for Decommissioning Costing of Nuclear Installations41. However, uncertainty 
continues to surround the full list of activities and the associated costs involved 
in dismantling the respective reactor buildings, in particular, since a comprehen ‑
sive inventory and radiological characterisation of the controlled area has still not 
been completed at any of the sites (see paragraph 32).41 Developed jointly by the 
European Commission, the 
IAEA and the Organisation for 
Economic Cooperation and 
Development, with a view to 
creating greater 
harmonisation in costing 
nuclear decommissioning 
activities.
43 Observations 
The Member States, and in particular Lithuania, face financial 
challenges
75 
For all three Member States, we compared the cost estimates and available fund ‑
ing found during our last audit with the latest figures available at the time of this 
audit. Currently, EU financing for decommissioning activities is provided for up 
until 2020. However, the available national and EU financing of 4.0 billion euro 
falls short of covering the estimated total cost of 5.7 billion euro, excluding the 
cost of final disposal (see Table 8 and  Figure 17 ). This leaves a financing gap of 
1.7 billion euro until the completion of decommissioning. Lithuania accounts for 
93 % of this financing gap. Figure 16Estimated decommissioning costs from 2010  to 2015
Source:  2010 figures: final decommissioning plans; 2011 figures: updated estimates presented to the Nuclear Decommissioning Assistance Pro ‑
gramme Committee meeting in March 2011; 2015 figures: updated final decommissioning plans, 2015 annual work programmes and, for Slovakia 
due to update, draft 2016 annual work programme.2 930 3 376 
1 118 1 243 
1 107 950 1 239 
5001 0001 5002 0002 5003 0003 500
2010 2011 2012 2013 2014 2015Ignalina, Lithuania
Kozloduy, Bulgaria
Bohunice, Slovakiamillion euro
2 019 
1 146
44 Observations 
Estimated overall decommissioning costs and financing gap, 2011  and  2015
(million euro)
 Ignalina,  
LithuaniaKozloduy,  
BulgariaBohunice,  
SlovakiaTotal
2011 2015 2011 2015 2011 2015 2011 2015
Estimated costs 2 930 3 376 1 243 1 107 1 146 1 239 5 319 5 722
National financing, 
allocated1 83 262 171 348 231 476 485 1 086
EU financing, allocated 1 367 1 553 493 731 489 671 2 349 2 955
Financing gap 1 480 1 561 579 28 426 92 2 485 1 681
1  Allocated national financing may be made up of dedicated funds set up for decommissioning, committed public expenditure or other 
 national sources.
Source: 2011: updated estimates presented to the Nuclear Decommissioning Assistance Programme Committee meeting in March 2011;  
2015: Member State authorities, updated final decommissioning plans and 2015 annual work programmes, and, for Slovakia due to update, the 
draft 2016 annual work programme.Table 8 Figure 17Illustration of the 2011 and 2015 financing gaps in each of the three Member States
Source:  Based on Table 8 .51 %46 %
47 %3 %
37 %7 %
 01 0002 0003 000
2011 2015 2011 2015 2011 2015
Ignalina, Lithuania Kozloduy, Bulgaria Bohunice, SlovakiaNational /f_inancing
EU /f_inancing
Financing gapmillion euro
45 Observations 
Cost increases and financing gap in Lithuania are substantial
76 
Lithuania’s  2015 estimates of the overall decommissioning cost increased by 
15 % compared with 2011, but by 67 % compared with 2010, amounting to 3.4 bil ‑
lion euro. The Lithuanian authorities attributed these increases to labour costs, 
the postponement of the decommissioning end date and cost overruns in major 
decommissioning infrastructure projects. The inflation cost category accounted 
for 26 % of the remaining decommissioning cost until 2038, or 695 million euro. 
This had been calculated on the basis of a 3 % annual estimate; however, at the 
time of the Member State’s calculation, the Central Bank of the Republic of Lithu ‑
ania put the average inflation rate estimate for 2015, which takes into account 
2013 and 2014, at 1.5 %.
77 
We also consider the extent of the cost increase to be indicative of poor initial 
planning. For example, the 2014 update to the final decommissioning plan in ‑
cluded 15 previously unconsidered decommissioning activities, estimated to cost 
318 million  euro in total.
78 
Our analysis of key infrastructure projects in Lithuania, from the start of their im ‑
plementation to the end of 2015, confirmed major cost increases in such projects 
(see Annex VI ). Some of these additional costs were caused by project delays. For 
example, the delay in implementing the interim spent fuel storage facility project 
had repercussions on reactor‑defuelling progress and, by the end of 2014, had 
triggered additional maintenance costs exceeding 61.3 million euro (see para ‑
graph 61), as well as contributing to the postponement of the decommissioning 
end date.
79 
Generally speaking, staff numbers at a  plant undergoing decommissioning are 
likely to be held close to operating plant levels until the fuel has been removed 
from the reactor. Staff levels should then progressively decline as the plant transi ‑
tions from an operational status.
46 Observations 
80 
Staff levels have declined at all plants (see Table 9 ). However, at Ignalina in Lithu ‑
ania, where only one of the two reactor cores has been defuelled and which is 
still under an operational licence, staff levels, and hence costs financed by the EU, 
remain high. A third of staff continue to work on safe plant maintenance. In both 
Bulgaria and Slovakia, alternative employment elsewhere on the nuclear reactors 
still in full operation at the same site has been possible. In Lithuania, which no 
longer produces nuclear energy, this has not been possible. Table 9Staffing at the time of reactor closure and in 2015
Number of staffEU support granted  
(million euro)3 during full 
operation1 in 2015
Ignalina, Lithuania  
(two reactor units)3 517 2 1272171
Kozloduy, Bulgaria  
(four reactor units)1 400 650 130
Bohunice, Slovakia  
(two reactor units)1 060 239 45
Total 5 977 3 016 346
1  Full operation figure as at 31.12.2004 for Ignalina, as at 31.12.2002 for Kozloduy and as at 
1.4.2006 for Bohunice.
2  Of the staff at Ignalina, 1 377 were working on nuclear decommissioning and 701 on safe 
maintenance.
3  Figures for Ignalina cover EU support from first unit closure in 2005 until 2016; for Ko ‑
zloduy, from first unit closure in 2003 until 2017; for Bohunice, from first unit closure in 
2008  until  2016.
Source:  ECA, based on figures provided by Member State authorities.
81 
Since our previous report, workforce management at Ignalina has improved. For 
example, the management at the Ignalina nuclear power plant has introduced 
an outsourcing strategy. This involves analysing several activities, such as equip ‑
ment maintenance and the decontamination of unrestricted‑access buildings, 
and deciding whether it would be more cost‑effective to procure the related 
services or to staff them internally.
47 Observations 
82 
However, whether the current level of staffing is appropriate has not been valid ‑
ated externally, and there is still no detailed staffing plan covering the entire 
decommissioning process. Given the lack of co‑financing and the local economic 
and social challenges involved in decommissioning at Ignalina, Lithuania, there 
is a risk of staffing exceeding the needs of the decommissioning programme, 
and of EU dedicated decommissioning financing being used to support such 
employment.
83 
As noted in Table 8  and paragraph 76, Lithuania’s financing gap has increased 
significantly since our last report. During interviews with Lithuanian representa ‑
tives, reference was made to Protocol No 4, annexed to the country’s accession 
treaty to the EU, and to the Lithuanian interpretation that cost increases in the 
decommissioning project will continue to be financed by the EU42. The Com ‑
mission’s 2011 impact assessment argued that, based on their needs, support 
should be provided for the 2014 ‑2020 period to all three Member States, but that, 
beyond 2020, the Commission did ‘not foresee any further extension of financial 
EU support’ (see paragraph 10)43.
A small financing gap remains in Bulgaria and Slovakia although 
estimates have varied considerably over time
84 
With the allocation of EU financing for the 2014 ‑2020 period, the financing gaps 
noted in our previous report have decreased significantly in Bulgaria and Slova ‑
kia, to 28 million euro and 92 million euro respectively. However, cost and financ ‑
ing gap estimates have varied dramatically.
— The Bulgarian  authorities’ estimate for the financing gap fell significantly 
from 230 million euro in September 2014 to 28 million euro at the end of 
2015, mainly due to the inclusion of costs borne by the Kozloduy nuclear 
power plant for preparatory decommissioning activities not taken into ac ‑
count in previous calculations. Contrary to this, Commission data at the end 
of 2015 showed a gap of 150 million euro.
— In Slovakia , the financing gap at the end of June 2015 was 193 million euro 
according to Commission data, while the draft 2016 annual work programme 
put it at 92 million euro.42 Article 3, Protocol No 4 on the 
Ignalina nuclear power plant 
in Lithuania (OJ L 236, 
23.9.2003) states that ‘the 
decommissioning of the 
Ignalina Nuclear Power Plant 
… is of a long ‑term nature and 
represents for Lithuania an 
exceptional financial burden 
not commensurate with the 
size and economic strength of 
the country’, and ‘that Union 
shall, in solidarity with 
Lithuania, provide adequate 
additional Community 
assistance to the 
decommissioning effort 
beyond 2006’. The Protocol 
also states that ‘for the period 
of the next Financial 
Perspectives, the overall 
average appropriations under 
the extended Ignalina 
Programme shall be 
appropriate’.
43 SEC(2011) 1387 final of 
24 November 2011, 
‘Commission staff working 
paper — Impact assessment 
— Accompanying document 
to the Proposal for a Council 
Regulation on Union support 
for the nuclear 
decommissioning assistance 
programmes in Bulgaria, 
Lithuania and Slovakia’.
48 Observations 
85 
Such variations between the national and Commission figures raise questions 
regarding the reliability and robustness of the calculation methodologies used. 
Furthermore, the significant revisions made to figures indicate that the estimates 
presented in the final decommissioning plans had, at the time of our audit, 
not yet been scrutinised thoroughly by either the national stakeholders or the 
Commission.
The Commission’s assessment of financing and 
decommissioning plans was inadequate
86 
Partly in response to the recommendations in our previous report, the legislative 
framework for the 2014 ‑2020 financing period introduced three ‘ ex ante  condi ‑
tionalities’44 (see Box 1 ). These are prerequisites for the disbursement of any new 
financing for decommissioning under the current multiannual financial frame ‑
work, intended to ensure the effective and efficient use of EU funds.44 See COM(2011) 783 final, 
Council Regulations (Euratom) 
No 1368/2013 and 
No 1369/2013 and Commission 
Implementing Decision 
C(2014)  5449.Box 1Ex ante  conditionalities
By 1 January 2014, the three Member States shall take the appropriate measures to fulfil the following ex ante  
conditionalities:
1. comply with the Euratom Treaty’s acquis  in the area of nuclear safety, in particular regarding the transpo ‑
sition into national law of Directive 2009/71/Euratom and Directive 2011/70/Euratom;
2. establish, in a national framework, a financing plan identifying the full costs and the envisaged funding 
sources required for the safe completion of decommissioning of the nuclear reactor units, including man ‑
agement of spent fuel and radioactive waste;
3. submit to the Commission a revised detailed decommissioning plan, broken down to detail the level of 
decommissioning activities, including a  schedule and corresponding costs structure based on interna ‑
tionally recognised standards for the estimation of decommissioning costs.
Source:  Articles 4 of Council Regulations (Euratom) No 1368/2013 and No 1369/2013.
49 Observations 
87 
By the time the Commission took its financing decision on the 2014 annual work 
programme in October 2014, it should have assessed whether the Member States 
had taken appropriate measures to fulfil these conditions45. However, we found 
the Commission’s assessment of the respective financing plans and detailed 
decommissioning plans, i.e. of the second and third ex ante  conditionalities 
respectively, to be inadequate. A September 2015 report from the Commission’s 
Internal Audit Service corroborated our assessment. For example, we found that 
there were considerable revisions to total cost estimates and financing figures 
(see paragraph 84) and, in some instances, no detailed plans for certain costs or 
activities (see, for example, paragraph 79 on staff costs). A reservation related to 
the adequacy of the Directorate‑General for Energy’s assessment in 2014 of the 
ex ante  conditionalities is included in its 2015 annual activity report46.
88 
The Commission’s Directorate‑General for Energy devised an action plan target ‑
ing the weaknesses identified by the Commission’s Internal Audit Service, setting 
the end of October  2016 as the deadline for completing the assessment of the 
ex ante  conditionalities. It is crucial that the Commission complete this assess ‑
ment and analyse thoroughly both the financing and decommissioning plans for 
each Member State, since these documents form the basis for future funding.
The EU budget finances the vast majority of costs in all three 
Member States
89 
All three Member States have set up dedicated national funds to finance their na ‑
tional policies for the safe management and disposal of radioactive waste and for 
the decommissioning of nuclear installations. However, resources in these funds 
remain limited, particularly in Lithuania.
— In Lithuania  the Lithuanian National Decommissioning Support Fund, first 
established in 1995, received revenue contributions from the operation of 
the nuclear power plant until the plant was shut down at the end of 2009. It 
now depends on revenue from the sale of redundant assets, and on external 
funds and the interest generated thereon. In the past it was also used to fund 
non‑decommissioning activities such as preferential electricity and heating 
tariffs, or additional social guarantees for ex‑employees. According to an 
estimate provided by the Ministry of Energy, the fund held 4 million euro on 
1 January  201647.45 See Article 4 of Council 
Regulations (Euratom) No 
1368/2013 and 1369/2013.
46 Directorate ‑General for 
Energy, 2015 annual activity 
report , ref. Ares(2016)1667891, 
8.4.2016.
47 SWD(2016) 102 final, p. 38, 
does not mention this fund 
but gives a figure of 0.5 billion 
euro as the total available 
funds. It is not clear what this 
figure refers to.
50 Observations 
— In 1999,  Bulgaria  set up a national radioactive waste fund and a decom ‑
missioning of nuclear facilities fund. Both funds concern all nuclear facil ‑
ities in Bulgaria. The first fund is funded mainly through contributions from 
radioactive waste producers, the main contributor, at a rate of 92 %, being 
the Kozloduy nuclear power plant. The fund had spent 34.8 million euro on 
units 1 ‑4 as radioactive waste management facilities and held 61 million euro 
at the end of 2015. The second fund is financed with contributions from 
nuclear facility operators. Cumulated funds for the Kozloduy units 1 ‑4 were 
156 million euro at the end of 2015.
— In 2010, Slovakia introduced a levy on end‑user electricity consumption to 
compensate for the ‘historical deficit’ and the fact that the mandatory contri ‑
butions from nuclear power plant operators since 1995 had raised insufficient 
funds to cover nuclear decommissioning and the final disposal of spent fuel. 
The amount earmarked in the national decommissioning fund for decommis ‑
sioning the Bohunice V 1 nuclear power plant was 290 million euro at the end 
of 2014.
90 
The total available national resources, made up of the dedicated funds and 
other national sources, will not cover the full decommissioning costs (see para ‑
graph 67 and Table 8 ). National resources would cover just 31 % of estimated 
costs in Bulgaria and 38 % in Slovakia, while the national funds in the EU’s nuclear 
decommissioning programme in Lithuania would cover less than 8 % of the total 
decommissioning cost. To date, the EU budget has financed the shortfall through 
the nuclear decommissioning assistance programmes.
91 
There is currently no legal requirement for Member States to co‑finance the de ‑
commissioning assistance, whether at programme or individual project level. In 
contrast, the European Structural and Investment Funds48 oblige Member States 
to contribute — from their own resources — a set percentage of the funding for 
co‑financed programmes or projects. Our previous report recommended that the 
Commission, if proposing funding for the 2014 ‑2020 financial framework, take 
into account other EU funds, such as the Structural Funds, and the conditions 
for fund disbursement. The Commission followed up this recommendation by 
continuing support for mitigation measures under the European Structural and 
Investment Funds (ESIF) but decided to keep dedicated decommissioning sup ‑
port separate, with no access to the ESIF for actual decommissioning.48 The European Structural and 
Investment Funds include, 
inter alia, the European 
Regional Development Fund, 
the Cohesion Fund and the 
European Social Fund. Before 
2014, these were referred to as 
the ‘Structural Funds’.
51 Observations 
92 
The obligation to provide co‑financing is important because it gives the re ‑
cipients of EU funding more of a financial incentive to seek value for money 
in managing a project and to make progress with programmes. The relevant 
Council regulations for these nuclear decommissioning assistance programmes 
do acknowledge the importance of co‑financing and state that full EU finan ‑
cing of projects should only be authorised in ‘well‑founded exceptional cases’49. 
However, the Commission has not yet laid down clear guidelines on what would 
constitute such a case. This is corroborated by the Commission’s September 2015 
Internal Audit Service report. The Commission has thereby so far missed out on 
the opportunity to incentivise and maximise co financing.
The total estimated cost would double if the cost of final 
disposal of high‑level waste is included
93 
None of the financing gap estimates given in the final decommissioning plans 
gives the full picture of the costs involved once a plant is closed, since they each 
fail to include the cost of the final disposal of spent fuel.
94 
According to the internationally recognised ‘polluter pays’ principle, it is the re ‑
sponsibility of the Member State to ensure that the operator fulfils its obligations 
as the polluter and sets aside sufficient financial resources to cover the full cost 
of decommissioning, including the final disposal of spent fuel (see paragraph 20).
95 
The 2011 radioactive waste directive reflects this principle. The directive requires 
Member States to ensure that all radioactive waste and spent nuclear fuel man ‑
agement activities, including final disposal, are identified and fully costed, and 
that adequate financial resources will be available when required50.
96 
Furthermore, one of the preconditions for financing under the nuclear decom ‑
missioning assistance programmes (see paragraphs 86 to 88) is that Member 
States ‘establish, in a national framework, a financing plan identifying the full 
costs and the envisaged funding resources required for the safe completion of 
the decommissioning of the nuclear reactor units, including management of the 
spent fuel and radioactive waste’51.49 Recital 17 of Council 
Regulation (Euratom) No 
1368/2013 and Recital 15 of 
Council Regulation (Euratom) 
No 1369/2013.
50 See, in particular, Article 12 of 
Council Directive 2011/70/
Euratom.
51 See Articles 4 of Council 
Regulations (Euratom) No 
1368/2013 and 1369/2013.
52 Observations 
97 
We calculated an estimate for the cost of final disposal to provide a fuller picture 
of the costs involved in decommissioning the respective plants.
98 
As shown in Table 10 , we calculated that if the costs associated with final dis ‑
posal are taken into account, the estimated total cost of decommissioning could 
double, amounting to 11.4 billion euro in total for all three Member States. Table 10Decommissioning cost estimation including high‑level waste and spent nuclear fuel 
disposal
(million euro)
Ignalina, Lithuania Kozloduy, Bulgaria Bohunice, Slovakia Total
2015 cost estimate, excluding high‑level waste and spent 
nuclear fuel disposal3 376 1 107 1 239 5 722
Cost estimate for final disposal of high‑level waste and 
spent nuclear fuel from these eight reactors1 2 610 1 590 1 466 5 666
Cost estimate, including high‑level waste and spent 
nuclear fuel disposal5 986 2 697 2 705 11 388
National financing 262 348 476 1 086
EU financing 1 553 731 671 2 955
Financing gap 4 171 1 618 1 558 7 347
1 Note on estimates of final disposal costs
For Ignalina, Lithuania , our estimate of 2 610 million euro is based on the figure provided in the national programme and quoted in the 
Commission’s 2016 nuclear illustrative programme.
For Kozloduy, Bulgaria , the Bulgarian national programme does not provide a figure. Our estimate of 1.59 billion euro is based on the 3 bil ‑
lion euro estimate of the total cost of a national disposal facility, based on discussions with the Bulgarian national authorities regarding the 
Finnish case during the audit. We divided the 3 billion euro in half to reflect the share of units 1 ‑4 and the other operating units 5 and 6. We 
did not take into account any plans for future units or plants, since these were not yet concrete.
For Bohunice, Slovakia , our estimate of 1.46 billion euro is based on the Slovak authorities’ 4.4 billion euro estimate of national final disposal 
costs, using the more conservative scenario in which the remaining nuclear power plants in Slovakia have an operational life of 60 years. We 
divided 4.4 billion euro by three, to split the cost equally between the two units under decommissioning and the four currently operating 
units. Contrary to the Slovak national programme, we did not take into account the two units planned in Mohovce, due to the delays in their 
construction. Had we done so, the units under decommissioning would have accounted for a 16.3 % share of the 4.4 billion euro, equal to 
717 million euro. The Commission’s 2016 nuclear illustrative programme quotes a figure of 3.7 billion euro, which appears to refer to the less 
conservative scenario regarding the operational plant life of 40 years.
Source:  ECA, based on Commission, AWPs 2015 and 2016, national stakeholders.
53 Observations 
99 
When taking into account both decommissioning and final disposal, Lithuania 
accounts for the largest share of the overall shortfall of 7.4 billion euro. However, 
sizeable shortfalls would also emerge for Bulgaria and Slovakia (see Figure 18 ).Figure 18Financing gaps when taking into account both 
decommissioning and final disposal
Source:  ECA, based on Table 10. 01 0002 0003 0004 0005 0006 000
Ignalina, Lithuania Kozloduy, Bulgaria Bohunice, SlovakiaNational /f_inancing
EU /f_inancing
Financing gap58 %70 %
60 %million euro52 IAS 37, ‘Provisions, contingent 
liabilities and contingent 
assets’ and IPSAS 19. There is 
no specific international 
accounting standard 
concerning nuclear 
decommissioning. There is a 
standard on how statistical 
information on 
decommissioning costs is 
calculated within the 
European System of Accounts 
(ESA) and this does not require 
liabilities to be recorded for 
future costs.
53 According to IAS 37.10, an 
obligating event is an event 
which creates a legal or 
constructive obligation (e.g. 
construction of nuclear power 
plant, creating an obligation 
for nuclear decommissioning) 
and which, therefore, results in 
an entity having no realistic 
alternative but to settle that 
obligation.
54 According to IAS 37.40, 
provisions for one ‑off events 
(restructuring, environmental 
clean ‑up, settlement of a 
lawsuit) are measured at the 
most likely amount.
Liabilities for future costs are not properly accounted for in 
the three Member States
100  
In accordance with international accounting standards52, liabilities that are ex ‑
pected to arise in the future should be identified as provisions and recognised on 
the balance sheet of the organisation which has the obligation to pay them if:
— a present legal or constructive obligation has arisen as a result of a past 
event53;
— payment is probable, i.e. more likely than not;
— the amount can be estimated reliably54.
54 Observations 
101  
If these three conditions are not met, the liabilities are termed ‘contingent liabil ‑
ities’ and disclosed off balance sheet, for example in the notes to the accounts, 
unless payment is considered remote, in which case no disclosure is necessary55.
102  
Accordingly, nuclear decommissioning costs and the costs for the final disposal 
of spent fuel should therefore, when such payment is probable and the amount 
can be estimated reliably, be recognised as liabilities by the organisation which 
has the obligation to pay them. Cost estimates might, for example, be based on 
a nuclear decommissioning plan. The precise accounting treatment depends on 
the legal situation as regards liability for payment and on the accounting prac ‑
tices adopted by the Member State or organisation56.
103  
We asked the relevant authorities in the Member States to provide information 
on how the liabilities for costs associated with decommissioning and the final 
disposal of spent nuclear fuel are accounted for.
104  
As shown in Table 11 , the accounting treatment varies among the three Member 
States and depending on whether the costs are associated with nuclear decom ‑
missioning or final disposal. Nuclear decommissioning costs are not recognised 
as provisions on any balance sheet in Lithuania and only minor contingent liabil ‑
ities are disclosed. Decommissioning costs are not recognised in the accounts of 
the Kozloduy nuclear power plant, Bulgaria, and are only partially recognised in 
the Bohunice nuclear power plant, Slovakia.
105  
Regarding the costs of final disposal, the relevant organisations in Lithuania and 
Bulgaria have neither recognised provisions for such costs on balance sheet nor 
disclosed any information in the notes to account. Only in Slovakia have relevant 
organisations recognised a provision in respect of the costs of final disposal, in 
a national nuclear fund sub‑account.55 Under IAS 37, disclosure is not 
obligatory if payment is 
remote.
56 Some organisations are 
required to use International 
Accounting Standards, 
whereas other organisations 
may use accounting standards 
at national level.
55 Observations 
106  
The fact that future costs are not systematically recognised as provisions and/
or included in the notes to the accounts limits transparency and hampers the 
relevant authorities’ ability to plan adequately how to meet future decommis ‑
sioning and disposal costs. Table 11Accounting treatment of liabilities relating to nuclear decommissioning and final 
disposal of spent fuel
Nuclear power plant accounts (excluding final disposal of 
spent nuclear fuel)Fund/ministry/government accounts  
(including final disposal of spent nuclear fuel)
Ignalina, 
LithuaniaNo recognised provisions.
Explanatory note explains that no reliable estimate is available 
for dismantling. Therefore, no contingent liabilities disclosed.No recognised provisions.
Minor contingent liabilities related to nuclear decommissioning are 
disclosed off balance sheet (13 million euro), concerning additional 
social guarantees for former NPP employees.
Kozloduy, 
BulgariaNo recognition of either provisions for decommissioning, or of 
spent fuel storage and management costs. The 2014 accounts 
were therefore qualified by an independent auditor.Revenues and expenditure of the national decommissioning and 
radioactive waste funds are included in the Ministry of Energy’s an ‑
nual budget accounts. Any unused portions of the accrued financial 
resources, including resources from previous years, are disclosed off 
balance sheet.
Bohunice, 
SlovakiaPartially recognised, but not earmarked for Bohunice  V1.Preliminary information regarding final disposal included in a na ‑
tional nuclear fund sub‑account.
Source:  ECA, based on information from the national authorities.
56
 Conclusions and 
recommendations
107  
The dedicated EU funding programmes for nuclear decommissioning have not 
created the right incentives for timely and cost‑effective decommissioning. 
Since we published our previous report in 2011, some progress has been made in 
decommissioning the nuclear power plants of Ignalina in Lithuania, Kozloduy in 
Bulgaria and Bohunice in Slovakia. Key components in the plants’ non‑  controlled 
areas have been dismantled. However, nearly all the key decommissioning infra ‑
structure projects have experienced delays, and the critical challenges involved 
in working in the controlled areas still lie ahead for all three Member States. 
Member State authorities claim that the plants have been irreversibly closed; 
however, not all of the expected outputs used by the Commission to assess 
progress towards irreversible closure have been fully met. The financing gap in 
Lithuania has increased since our last audit and now stands at 1.6 billion euro. 
The estimated cost of decommissioning at the three plants will be at least 5.7 bil ‑
lion euro in total, and 11.4 billion if the cost of final disposal is included.
Some decommissioning progress made since 2011 but critical 
challenges ahead
108  
Since 2011, the three Member States have dismantled certain key components in 
the non‑controlled area and, except in the case of Lithuania, advanced in obtain ‑
ing the relevant licences for starting work in the controlled area. Lithuania has 
yet to obtain such a licence, the granting of which is now scheduled for 2022, 
10 years later than originally planned (see paragraphs 40 and 42).
109  
According to all of the national authorities, the progress achieved means that 
closure is now effectively irreversible. However, the expected outputs by which 
the Commission assesses progress towards irreversible closure have not yet been 
fully met at any of the three plants. The designs for the dismantling of the reactor 
cores/primary circuits are not yet complete and only minor works in the reactor 
building have been carried out to date. This means that the critical challenges 
involved in working in the controlled areas, including the reactor buildings, still 
lie ahead for all three Member States (see paragraphs 38 to 42).
110  
There has been some progress in putting in place waste management infra ‑
structure, but many key infrastructure projects in the three Member States 
experienced delays in the 2011 ‑2015 period (see paragraphs 43 and 59 to 71). The 
longest delays have been in Lithuania, where the decommissioning end date has, 
since 2011, been postponed by a further 9 years to 2038 (see paragraphs 59 to 
63).
57 Conclusions and recommendations 
111 
Challenges remain in each of the three Member States, such as a reliance on 
external experts (see paragraph 69) and dealing with first‑in‑kind technical solu ‑
tions (see paragraphs 67 to 68). The EU‑wide shortage of qualified, experienced 
engineers poses a risk, particularly in Lithuania (see paragraph 70).
Recommendation 1 — Ensure progress in decommissioning
The three Member States concerned should:
(a) further improve their project management practices in order to have the 
necessary waste and spent fuel management infrastructure in place when 
planned;
(b) take steps to build up their own technical capacity, so as to achieve a better 
balance between in‑house and external expertise;
(c) find better ways to exchange best practices and technical knowledge, both 
among themselves and with the wider nuclear decommissioning community 
in the EU and beyond. The Commission  should facilitate this in a cost‑effec ‑
tive way.
Target implementation date: By end 2017.
112  
The projects funded under the EU’s nuclear decommissioning assistance pro ‑
grammes do not relate to final disposal, but only to the interim storage of spent 
nuclear fuel. It can take several decades and high levels of financial commitment 
to develop a final disposal site for spent nuclear fuel. Doing so might be diffi ‑
cult for some countries which generate low volumes of radioactive waste, have 
limited financial resources or lack appropriate geological conditions. Talks in the 
three Member States regarding potential final disposal solutions for high‑level 
waste and spent nuclear fuel, which may be national or regional solutions, are 
still only at a conceptual stage (see paragraphs 48 to 58). The Commission is 
required to report on Member States’ plans in this area, but has not yet done so 
(see paragraph 53).
58 Conclusions and recommendations 
Recommendation 2 — Solutions for the final disposal of 
spent nuclear fuel
(a) The Commission should, together with all relevant EU Member States, 
explore options for the disposal of spent fuel and high‑level waste, including 
any regional and other EU‑based solutions, duly considering safety, security 
and the cost‑effectiveness of the alternatives. The Commission should in ‑
clude a review of this matter in its first report to the European Parliament and 
the Council on the implementation of the radioactive waste directive.
Target implementation date: to start immediately; publication of report by 
mid 2017 at the latest.
(b) The three Member States  should, in parallel, progress with their plans for 
final disposal, in order to establish more complete cost estimates and finan ‑
cing plans for the disposal of spent fuel and radioactive waste, as required by 
the radioactive waste directive.
Target implementation date: by mid 2017.
Estimated cost of decommissioning will be at least 
5.7 billion euro and double that if the cost of final 
disposal is included
113  
Estimates of the total cost of decommissioning across the three programmes 
increased by 40 % between 2010 and 2015, from 4.1 billion euro to 5.7 billion euro 
(see paragraphs 73 to 74). If costs associated with the final disposal of spent nu ‑
clear fuel are included, the full cost could double, reaching 11.4 billion euro (see 
paragraphs 93 to 99).
114  
The currently available national and EU financing of 4.0 billion euro falls short 
of covering the estimated total cost of 5.7 billion euro, not including the cost 
of final disposal. There is, therefore, a financing gap of 1.7 billion euro until the 
completion of decommissioning. Lithuania accounts for 93 % of this overall finan ‑
cing gap, with a shortfall of 1.6 billion (see paragraphs 73 to 85). The financing 
gaps estimated by Bulgaria and Slovakia now amount to 28 and 92 million euro 
respect  ively (see paragraph 84).
59 Conclusions and recommendations 
115  
According to the internationally recognised ‘polluter pays’ principle, it is the 
responsibility of the Member State to ensure that nuclear power plant operators 
fulfil their obligations as the polluter, and set aside sufficient financial resources 
to cover the full cost of decommissioning and final disposal (see paragraphs 20 
and 93). The three sites are operated by state enterprises. All three Member States 
have set up dedicated national funds to finance their national policies for the safe 
management and disposal of radioactive waste and for the decommissioning of 
nuclear installations. However, to date, little use has been made of national funds 
in the three nuclear decommissioning programmes, and resources in these funds 
remain limited, particularly in Lithuania (see paragraphs 89 to 92).
116  
As a result, the co‑financing of projects with national funds has been the rare 
exception rather than the norm. Although, in contrast to other EU funds, there 
is no legal requirement in these programmes to co‑finance projects, the legal 
base recognises that full EU financing of projects should only be authorised in 
‘well‑founded exceptional cases’57. However, the Commission has not yet laid 
down clear guidelines on what would constitute such a case. Had it done so, it 
could have been more effective in creating the right incentives for higher levels 
of national co‑financing to be invested in decommissioning (see paragraph 92).
117  
The three Member States are ultimately responsible for ensuring that adequate 
financial resources are available for both decommissioning and final disposal (see 
paragraphs 20 and 95). In its 2011 impact assessment, the Commission concluded, 
based on an assessment of the Member States’ needs, that EU financial support 
should not be extended beyond 2020 (see paragraph 10). In this regard, Lithu ‑
anian representatives drew our attention, in particular, to their accession treaty 
protocols (see paragraph 83 and footnote 43).
Recommendation 3 — Respecting the polluter pays principle 
by increasing national financing for 2014 ‑2020 and beyond
The three Member States  should recognise their own role in ensuring that the 
polluter pays principle is respected, and be prepared to use national funds to 
cover decommissioning costs, as well as the cost of final disposal, both in the 
 current financing period and thereafter.
Target implementation date: starting with an increase in national co -financing 
from the 2017 annual work programmes.57 Recital 17 of Council 
Regulation (Euratom) 
No 1368/2013 and recital 15 of 
Council Regulation (Euratom) 
No 1369/2013.
60 Conclusions and recommendations 
Recommendation 4 — Increase in national co‑financing in the 
2014 ‑2020 financing period
The Commission should seek increases in national co‑financing during the 2014 ‑
2020 financing period. It should define clearly, for example in a  Commission deci ‑
sion, the ‘well‑founded exceptional’ conditions under which projects can be fully 
financed by the EU under the nuclear decommissioning assistance programmes.
Target implementation date: by the end of December 2017.
Recommendation 5 — Discontinue dedicated funding 
programmes for nuclear decommissioning in Lithuania, 
Bulgaria and Slovakia after 2020
Dedicated funding programmes for nuclear decommissioning in Lithuania, Bul ‑
garia and Slovakia should be discontinued after 2020. If a clear need for the use 
of EU funds beyond 2020 is established, in one or more of these three Member 
States, any future EU funding proposed by the Commission and agreed by the 
legislator should include the right incentives to pursue decommissioning, includ ‑
ing by being time limited and by being based on appropriate levels of Member 
State co‑financing. One way to do this would be to consider widening access to 
the European Structural and Investment Funds to allow nuclear decommissioning 
activities to be covered, fulfilling these conditions.
Target implementation date: by the end of 2018, if necessary.
118  
Staff levels have declined at all three plants. However, at Ignalina in Lithuania, 
where only one of the two reactor cores has been defuelled, and which still oper ‑
ates under an operational licence, staff levels, and hence costs funded by the EU, 
remain high. A third of the staff continues to work on safe plant maintenance. 
Given the lack of co‑financing and the local economic and social challenges 
involved in decommissioning at Ignalina, Lithuania, there is a risk of staffing 
exceeding the needs of the decommissioning programme, and of EU dedicated 
decommissioning financing being used to support such employment (see para ‑
graphs 80 to 81).
61 Conclusions and recommendations 
Recommendation 6 — EU funding only for cost of 
decommissioning
The Commission should  allow  EU financing under the nuclear decommissioning 
assistance programmes to be used to finance only the costs of staff working fully 
on decommissioning activities.
Target implementation date: from the 2017 annual work programmes and 
beyond.
119  
The Commission’s assessment as to whether the financing and decommissioning 
plans fulfil the ex ante  conditionalities has been inadequate (see paragraphs 86 to 
88).
Recommendation 7 — Improving Commission oversight
The Commission should complete its assessment of the ex ante  conditionalities.
Target implementation date: by the end of October 2016.
120  
The accounting treatment of liabilities and contingent liabilities for future costs 
associated with nuclear decommissioning and the final disposal of spent nuclear 
fuel varies among the three Member States. The fact that future costs are not al ‑
ways recognised as provisions and/or included in the notes to the accounts limits 
transparency and hampers the relevant authorities’ ability to plan adequately 
how to meet future decommissioning and disposal costs (see paragraphs 100 to 
103).
62 Conclusions and recommendations 
Recommendation 8 — Accounting treatment
The Commission  should work together with all relevant Member States so that 
all future costs associated with nuclear decommissioning and the final disposal 
of spent fuel are accounted for properly, in a transparent manner, consistent with 
relevant accounting standards.
Target implementation date: by the end of December 2017.
This Report was adopted by Chamber II, headed by Mr Henri GRETHEN, Member 
of the Court of Auditors, in Luxembourg at its meeting of 14 July 2016.
 For the Court of Auditors
 Vítor Manuel da SILVA CALDEIRA
 President

63
 Annexes
The nuclear reactors being decommissioned under the EU’s nuclear 
decommissioning assistance programme
TWhCommercial operationPlanned 
decommissioning 
completion date
Start Shutdown YearsAs % of  
30‑year lifePer ECA 2011 
reportAs at Dec. 
2015
LithuaniaIgnalina 1 86 May 1985 Dec 2004 20 652029 2038Ignalina 2 155 Dec 1987 Dec 2009 22 73
BulgariaKozloduy 1 61 Oct 1974 Dec 2002 28 94
2035 2030Kozloduy 2 63 Nov 1975 Dec 2002 27 90
Kozloduy 3 63 Jan 1981 Dec 2006 26 86
Kozloduy 4 61 Jun 1982 Dec 2006 25 82
SlovakiaBohunice‑V1, 
reactor 172 Apr 1980 Dec 2006 27 89
2025 2025Bohunice‑V1, 
reactor 277 Jan 1981 Dec 2008 28 93
Source:  IAEA, Pris Database.Annex I
64 Annexes 
Overview of the legal bases for the nuclear decommissioning assistance 
programmes
Ignalina, Lithuania Kozloduy, Bulgaria Bohunice, Slovakia
Pre‑accessionCouncil Regulation 
(EEC) No  3906/1989 of 
18 December  1989Council Regulation (EC) No 1266/1999 of 21 June 1999 (PHARE programme)
Accession treatiesProtocol No 4 on the Ignalina 
Nuclear Power Plant in Lithuania, 
attached to the Act concerning 
the conditions of accession of the 
Republic of Lithuania and the ad ‑
justments to the Treaties on which 
the European Union is founded (OJ 
L 236, 23.9.2003, p.944 ‑945Act concerning the conditions of accession 
of the Republic of Bulgaria and Romania 
(OJ L 157 , 21.6.2005, p. 203)Protocol No 9 of the Act concerning the condi ‑
tions of accession of the Slovak Republic and 
the adjustments to the Treaties on which the 
European Union is founded.
(Bohunice V1 NPP) (OJ L 236, 23.9.2003, p.954)
Post‑accessionCouncil Regulation (EC) 
No 1990/2006 of 21  December  
2006 on the implementation of 
Protocol No  4 on the Ignalina NPPCouncil Regulation (Euratom) No 647/2010 
of 13 July 2010Council Regulation (Euratom) No 549/2007 of 
14 May 2007 on the implementation of Protocol 
No 9 on Unit 1 and Unit 2 of the Bohunice V1 
nuclear power plant in Slovakia to the Act 
concerning the conditions of accession to the 
European Union of the Czech Republic, Estonia, 
Cyprus, Latvia, Lithuania, Hungary, Malta, 
Poland, Slovenia and Slovakia
Council Regulation (Euratom) 
No 1369/2013 of 13  December  
2013 on Union support for the 
nuclear decommissioning as ‑
sistance programme in Lithuania, 
and repealing Regulation (EC) 
No 1990/2006Council Regulation (Euratom) No 1368/2013 of 13 December 2013 on Union support for the 
nuclear decommissioning assistance programmes in Bulgaria and Slovakia and repealing 
Regulation (Euratom) No 549/2007 and (Euratom) No 647/2010Annex II
65 Annexes 
Nuclear power reactors in the Member States and their status as at 
31 December 2015Annex IIIStatus
Shut downOperationalUnder construction
Total91
129
2244United Kingdom
Shut down
Operational
Under construction
Total3015
45-
Netherlands
Shut down
Operational
Under construction
Total1
1
2-
Belgium
Shut downOperationalUnder construction
Total17
8-
Germany
Shut downOperationalUnder construction
Total28
8
36-
FranceShut downOperationalUnder construction
Total1258
711
SpainShut downOperationalUnder construction
Total37
10-
ItalyShut downOperationalUnder construction
Total4-
4-Finland
Shut down
Operational
Under construction
Total-
4
51
Sweden
Shut down
Operational
Under construction
Total3
10
13-
Lithuania
Shut downOperationalUnder construction
Total2
-
2-
Czech RepublicShut downOperationalUnder construction
Total-
6
6-
RomaniaShut downOperationalUnder construction
Total-
2
2-
BulgariaShut downOperationalUnder construction
Total4
2
6-SlovakiaShut downOperationalUnder construction
Total3
4
92
HungaryShut downOperationalUnder construction
Total-
4
4-Slovenia (shared with Croatia)Shut downOperationalUnder construction
Total-
1
1-
Note: The two reactor units in Ignalina, Lithuania, are still under operational licence (see paragraph 40).
Source:  ECA, based on data from the European Commission and the IAEA’s Power Reactor Information System (PRIS).
66 Annexes 
Overview of the nuclear decommissioning assistance programme actors
Nuclear decommissioning assistance programme, two implementing bodies in 
LithuaniaAnnex IV
EBRD Channel National Agency Channel
Programme
Monitoring
CommitteeLithuania
BeneﬁciaryBeneﬁciary
Contractor
ProjectContractor
ProjectFramework Agreement
Annual Delegation AgreementFramework Agreement
Annual Delegation Agreement
Transfer of Funds Agreement
Monitoring MonitoringMonitoring Framework Agreement
Approval of Grant Agreements
ContractDisbursementDisbursementContractFinancing Agreement
Supervising SupervisingLithuania
DesignationMonitoring
Ministry of
Finance
Financial
coordinationEnsure audit
and ﬁnancialoversightIgnalina International
Decommissioning
Support Fund
- Governed by the
Assembly of Contributors
- Administered by the EBRD
(Implementing Body)National Agency
(CPMA)
Programme
coordinationEuropean Commission
assisted by Nuclear
Decommissioning
Assistance Programme
Committee
In 2015 the EBRD was responsible for the following 
ongoing decommissioning projects:EU financing 
(million euro)
Interim storage for INPP’s spend fuel 205.97
Solid waste management and storage facilities 184.02
Project Management Unit ‑ Phases 1 ‑5 (2001 ‑2015) 51.81
Near ‑surface repository for low ‑ and intermediate ‑level 
short ‑lived radioactive waste (design)10.63
Total for 2015 452.43
Total completed and ongoing EBRD decommissioning
projects from 1999 to end 2015522.91In 2015 the CPMA was responsible for the following
ongoing decommissioning projects:EU financing 
(million euro)
Annual Decommissioning Activities of INPP with associated 
Costs in 201550.50
Construction of Landfill Facility for Very Low Level  
Radioactive Waste (Landfill Facility Phase 3)8.42
Technical Assistance to VATESI (Phase 6) 1.80
Waste cement containers 1.00
RMTF Establishment 0.96
Total for 2015 62.68
Total completed and ongoing CPMA decommissioning  pro‑
jects from 1999 to end 2015465.97
67 Annexes 
Nuclear decommissioning assistance programmes, with one implementing body in 
Bulgaria and SlovakiaAnnex IV
EBRD Channel
BeneﬁciaryMonitoringMonitoring
Monitoring
Supervising
DisbursementContractFramework Agreement
Annual Delegation Agreement
Approval of Grant
Agreements
Contractor
ProjectKozloduy and Bohunice International
Decommissioning Support Fund
- Governed by the Assembly of 
Contributors
- Administered by the EBRD
(Implementing Body)Bulgaria
Slovakia
Kozloduy and Bohunice
Programme Monitoring
CommitteesEuropean Commission
assisted by Nuclear
Decommissioning
Assistance Programme
Committee
68 Annexes 
EU‑financed projects examined for the audit
Ignalina, Lithuania
Project ECA assessment
1. Interim storage for spent fuel 
assemblies
Initial budget: 165 million euro
Latest budget: 206 million euro
Initial deadline: Aug. 2008
Latest deadline: Oct. 2017ECA 2011 
reportSignificant delays will have a major impact on nuclear safety until all the spent fuel elements 
have been put into casks, as well as on the plant’s operational costs.
As at  
Dec. 2015Construction of the storage facility has been delayed by a further 6 years, meaning that it is 
10 years behind schedule compared to the 2005 final decommissioning plan. The facility’s 
 additional maintenance costs relating to the B1 project exceeded 61 million euro.
2. Solid waste management and 
storage facility
Initial budget: 120 million euro
Latest budget: 184 million euro
Initial deadline: Nov. 2009
Latest deadline: Nov. 2018ECA 2011 
reportSignificant project delays which are critical because waste management routes are needed for 
progress in dismantling and decontamination projects. Additional IIDSF funding is likely to be 
required.
As at  
Dec. 2015The project is delayed by 9 years, 5 years of which were built up in the 2011 ‑2014 period. The 
INPP and the Lithuanian Ministry of Energy settled related commercial disputes with the con ‑
tractor by paying 55 million euro in compensation, and have set aside a further 17.9 million euro 
for anticipated risks.
3. Engineering, planning and licens ‑
ing of dismantling and decontami ‑
nation activities
Initial project budget 8 million euro
No budget or schedule currently set for 
the project.ECA 2011 
reportThe decision to outsource project activities was not based on an adequate assessment of either 
the on‑site availability of the required technical resources or the cost‑effectiveness of this 
option.
As at  
Dec. 2015Document preparation has been delayed by 30 months due to overestimation of contractor 
resources and to the time required for document approval by the plant and regulating institu ‑
tions. Three years of delay due to transfer of tool procurement projects from IIDSF channel to 
CPMA channel.
4. Management and engineering 
support to the Project Management 
Unit (PMU)
Initial budget: 45 million euro
Latest budget: 54 million euroECA 2011 
reportPMU consultant has significantly contributed to progress, but management and administrative 
costs are high and there has been insufficient development of the organisational structure at 
the plant.
As at  
Dec. 2015PMU consultant staff decreased since 2010. They are more involved in decommissioning activ‑
ities, managed major infrastructure projects and supported staff development at the plant. 
However, much of the consultant’s activities still focus on general project management and 
procurement activities, rather than on nuclear decommissioning tasks.
5. Projects related to direct support 
of the INPP workforce activities, 
external supplies
Budget: 198  million  euro
Deadline: ongoing annual projectECA 2011 
reportNot examined.
As at  
Dec. 2015Problems with the workforce included difficulties in justifying staffing levels, unclear manage ‑
ment accounting and attributing staff costs to tasks. The INPP introduced a new calculation 
model for INPP staff, developed a cost structure for works and introduced earned value man ‑
agement. However, there was limited progress in justifying staffing levels and in implementing 
an outsourcing strategy.
6. Reactor dismantling study
Initial budget: 5 million euro  
(feasibility study only)
Latest budget: 70 million euro  
(design and technical engineering)ECA 2011 
reportNot examined.
As at  
Dec. 2015A feasibility study for reactor dismantling started under the IIDSF in 2009, but was cancelled 
and transferred to the CPMA in 2010. A new CPMA‑led project has since experienced delays. 
There is a lack of experience in dismantling this type of reactor, which may further hamper pro ‑
gress. There remains, therefore, uncertainty about whether the 2038 deadline for dismantling 
the reactor is feasible.Annex V
69 Annexes Annex VKozloduy, Bulgaria
Project ECA assessment
7. Project Management Unit Consul ‑
tancy Services — general
Period 2006-2013
Initial budget: 8 million euro
Latest budget:45 million euro
Initial deadline: Dec. 2006
Latest deadline: Jul. 2013
Period 2014-2016
Initial budget: 14 million euro
Latest budget: 32 million euro
Initial deadline: Jan. 2016
Latest deadline: Jan. 2019ECA 2011 
reportThe consultant helped modify the decommissioning strategy, but there were problems with 
project delays, cost estimates, identification of necessary decommissioning works and waste 
inventories. The consultant focused more on management than on decommissioning.
As at  
Dec. 2015In 2013, the PMU became the sole entity responsible for the management of both the 
decommissioning and the construction of the national disposal facility. The consultant is now 
embedded in the organisational structure, which places decision‑making power with SERAW. 
Consultants’ involvement in the work has been increasing, and there is no indication of their 
involvement being phased out.
8. Design and construction of 
a spent fuel dry storage facility
Initial budget: 49 million euro
Latest budget: 73 million euro
Initial deadline: Dec. 2008
Latest deadline: Mar. 2013ECA 2011 
reportThe completion of the facility is delayed by 2.5 years. Revisions to the initial requirements 
resulted in cost increases and an amended price basis for the contract, leading to a 19 % budget 
overrun.
As at  
Dec. 2015The project was divided into two stages: the construction of the facility and storage of fuel as ‑
semblies in 34 casks; and the extension of the facility for up to 72 casks. Not all of the planned 
storage capacity will be used for spent nuclear fuel from units 1 ‑4. The use of the facility to 
store other material would require approval by the regulator.
9. Plasma melting facility for the 
treatment and conditioning of solid 
waste
Initial budget: 21 million euro
Latest budget: 21 million euro
Initial deadline: Mar. 2013
Latest deadline: Jun. 2017ECA 2011 
reportNovel technology was selected without proper demonstration of its effectiveness and due 
consideration of costs. There is a risk of cost overrun.
As at  
Dec. 2015Regulatory changes required revisions to the design. Construction of the facility is behind 
schedule mainly due to an appeal relating to the environmental impact assessment and 
a number of commercial and administrative issues, including the lack of a nuclear indemnity 
agreement. The facility has not been tested, so system operation has not yet been demon ‑
strated. Completion now scheduled for June  2017 .
10. Promotion of the efficient use of 
human resources
Period to 2009
Initial budget: 20  million  euro
Latest budget: 84  million  euro
Initial deadline: Sep. 2009
Latest deadline: Mar. 2014
Period to 2015
Initial budget: 35 million euro
Latest budget: 46 million euro
Initial deadline: Dec. 2015
Latest deadline: Dec. 2017ECA 2011 
reportOrganisational changes allowing for a clear demarcation of staff working on the transition from 
an operational organisation to a decommissioning organisation have not taken place. Adequate 
monitoring of the pre‑decommissioning activities has been lacking.
As at  
Dec. 2015Reliance on the KIDSF to finance personnel involved in decommissioning activities has contin ‑
ued. In a positive development since 2011, all the 650 staff employed by SERAW are working 
exclusively on decommissioning activities.
11. Construction of the national dis ‑
posal facility for low ‑ and interme ‑
diate‑level radioactive waste
Initial budget: 66 million euro
Initial deadline: Dec. 2015
Latest deadline: Jan. 2021ECA 2011 
reportNot examined.
As at  
Dec. 2015The construction of the facility was originally scheduled for completion by 2015. However, the 
process has fallen 6 years behind, mainly due to the environmental impact assessment being 
rejected and having to be restarted. The current deadline is 2021.
70 Annexes Annex VBohunice, Slovakia
Project ECA assessment
12. Project Management Unit 
Consultancy Services  — project 
implementation
Period 2003-2007
Initial budget: 11 million euro
Period 2015-2016
Latest budget: 45 million euroECA 2011 
reportThe consultant helped modify the decommissioning strategy, but insufficient progress was 
achieved in formulating and implementing the decommissioning strategy.
As at  
Dec. 2015Although consultants have been used extensively, there have been project delays which 
in turn have caused cost overruns. Since 2015, the scope of work of the new consultant has 
decreased.
13. Design and erection of new 
disposal facilities for very low‑level 
and low‑level waste from V1 NPP at 
NRR Mochovce
Budget: 22  million  euro
Deadline: Jun. 2018ECA 2011 
reportThere was a delay in the feasibility study because the NPP did not provide necessary 
information.
As at  
Dec. 2015The repository is under construction, co‑financed by national funds. A third double row will be 
added, fully financed by BIDSF. The allocation of costs between disposal of waste from the V1 
NPP and disposal of waste from other facilities is not clear.
14. Implementation of the decom ‑
missioning programme using human 
resources available
Budget for Phase 1: 1.5 million euro
Budget for Phase 9: 50 million euroECA 2011 
reportOrganisational changes allowing for a clear demarcation of staff working on the transition 
from an operational organisation to a decommissioning organisation have not taken place. 
Adequate monitoring of the pre‑decommissioning activities has been lacking.
As at  
Dec. 2015The project finances 246 full‑time equivalent JAVYS staff working on decommissioning. JAVYS 
has evolved from an operational to a decommissioning organisation.
15. Interim storage of radioactive 
waste at the Bohunice site
Budget: 11  million  euro
Initial deadline: Mar. 2016
Latest deadline: Aug. 2017ECA 2011 
reportNot examined.
As at  
Dec. 2015This project was originally scheduled for implementation from March 2013 to March 2016. 
Construction works began in 2015. The expected completion date is now August 2017. A new 
environment impact assessment and an amendment to the grant agreement were required 
following a decision to change the location. Delays to this project will no longer lead to delays 
in dismantling projects because the latter will be managed such that intermediate‑level 
waste will be produced only after the interim storage facility is complete.
16. Decontamination of the primary 
circuit
Initial budget: 6 million euro
Latest budget: 5 million euro
Initial deadline: Sep. 2014
Latest deadline: Sep. 2016
(radioactive waste management share 
transferred to JAVYS)ECA 2011 
reportNot examined.
As at  
Dec. 2015Works were planned to start in 2013 and to be completed by the end of 2014. Delays and 
unresolved technical challenges have led to the project being put on hold. The contract with 
the current supplier has been terminated. This project needs to be finished before dismantling 
in the controlled area can start, and therefore delays in this project may have an impact on the 
decommissioning end date.
17 . Decommissioning database, 
including inventory and radiological 
characterisation
Initial budget: 2.48 million euro
Latest budget: 3.5 million euro
Initial deadline: May 2012
Latest deadline: Dec. 2012ECA 2011 
reportNot examined.
As at  
Dec. 2015Although the project was finalised in 2012, the characterisation and inventory still needs to be 
regularly updated. Several sub‑projects were delayed and experienced cost overruns due to 
incomplete information about the inventory and/or characterisation of waste.
71 Annexes Annex VIDelays and cost overruns affecting a sample of 18 key decommissioning infrastruc ‑
ture and supporting projects financed by the EU assistance programmes since 2001
ProjectProject 
cost  
(million 
euro)Contracted financing Total 
delay to 
date  
(years)Cost 
increase to 
date  
(%)EU  
(million 
euro)National  
(million 
euro)
Ignalina, 
LithuaniaInterim storage for spent fuel assemblies
(see Annex IV, Project 1)211 206 5 9.2 25 %
Solid waste management and storage facilities
(See Annex IV, Project 2)184 184 9.0 53 %
Landfill facility for very low radioactive waste (Phase 1 buffer 
storage)7 6 1 2.8 0 %
Construction of landfill facility for very low‑level radioactive 
waste (Phase 3)8 8 1.0 12 %
Near‑surface repository of low‑ and intermediate‑level 
short‑lived radioactive waste (design)11 11 1.0 3 %
Total for these five projects 421 415 6
Total contracted EU financing for decommissioning 
2001 ‑2014/2015989
Kozluduy, 
BulgariaSupply, installation and commissioning of retrieval and condi ‑
tioning equipment for ion‑exchange resins
(initial scope extended)6 5 1 10.9 132 %
Design and construction of a spent fuel dry storage facility (see 
Annex IV, Project 8)73 73 4.3 50 %
Facility for the retrieval and processing of the solidified phase 
from evaporator concentrate tanks (Phase 1 completed, Phase 2 
terminated)10 10 4.6 none
Plasma melting facility (see Annex IV, Project 9) 30 21 9 4.2 0 %
Size reduction and decontamination workshops 19 19 2.8 0 %
Evaluation of the radiological inventory 1 1 1.3 none
Total for these six projects 139 129 9
Total contracted EU financing for decommissioning 
2001 ‑2014360
72 Annexes Annex VIProjectProject 
cost  
(million 
euro)Contracted financing Total 
delay to 
date  
(years)Cost 
increase to 
date  
(%)EU  
(million 
euro)National  
(million 
euro)
Bohunice, 
SlovakiaTreatment of historical waste‑sludges and sorbents (completed) 11 11 3.0 38 %
Decontamination of the primary circuit
(see Annex IV, Project 16) (suspended)4 4 2.0 0 %
Modification of the JAVYS power supply scheme after V1 final 
shutdown11 11 1.5 21 %
Increasing capacity of existing fragmentation and decontamina ‑
tion facilities2 2 1.2 13 %
Treatment of historical waste 6 4 2 0.4 7 %
Dismantling of technical equipment in V1 turbine hall 8 8 ‑ 6 %
Free release of decommissioning materials 3 3 ‑ 20 %
Total for these seven projects 45 43 2
Total contracted EU financing for decommissioning 
2001 ‑2014228
TotalTotal for these 18 projects 605 587 17
Total contracted EU financing for decommissioning 
2001 ‑20141 577
Source:  Commission, draft AWPs 2016, draft monitoring reports 2016. Data provided by the EBRD and Central Project Management Agency.
73 Annexes Annex VIIConstruction of the deep geological repository for the final disposal of spent nuclear 
fuel in Olkiluoto, Finland
Olkiluoto, on the west coast of Finland, near an existing nuclear power plant, is to be the site of the world’s first 
deep geological repository for the final disposal of spent nuclear fuel following civil utilisation. It is designed to 
accommodate waste from the two Finnish nuclear power plants.
Its development process illustrates the long timescales involved in such an undertaking. In 1983, the Finnish 
government took a  decision in principle on the overall schedule and strategy for nuclear waste management, 
and the geological screening process searching for potential sites began. The Olkiluoto site was selected as 
the site of final disposal in 2000. Intense excavation and research work followed to enable the disposal of spent 
 nuclear fuel at a depth of 400 ‑450 metres down in the bedrock. Around 150 million euro was spent on this work. 
Disposal of spent fuel is planned to start in the early 2020s.
Total expenditure will be approximately 3.5 billion euro, of which around 1 billion euro during the construction 
phase and around 2.5 billion euro on operation over a period of 100 around years. Funds are being accumulated 
in the State Nuclear Waste Management Fund from charges on generated electricity.
© Posiva Oy.
74 Reply of the Commission
Executive summary
I
In the context of the negotiations for accession to the European Union, Bulgaria, Lithuania and Slovakia undertook 
to close and subsequently decommission eight Soviet ‑designed, first ‑generation nuclear reactors which could not 
be economically upgraded to Western safety standards. 
II
The EU had committed itself to assisting those countries in addressing the exceptional financial burden imposed by 
the decommissioning process. 
IV
The Commission considers that the EU financial support has effectively mitigated the economic consequences of 
the early closure and the decommissioning process is well engaged. However, it notes that decommissioning is 
a complex and lengthy process going beyond the 7 ‑year multiannual financial framework (MFF) — in most cases 
exceeding two decades. 
The updated decommissioning plans and associated cost estimates approved under the 2014 ‑2020 MFF are the 
basis for programming in the three Member States. Under these arrangements, the Commission is closely monitor ‑
ing progress towards the decommissioning end state whilst maintaining the highest level of safety.
V
Decommissioning is generally composed of two major phases: (i) post ‑closure (i.e. still under operational licence 
due to the presence of spent fuel) and (ii) decommissioning/ dismantling. 
Slovakia and Bulgaria are in the second phase while Lithuania, due to the presence of spent fuel in one of the reac ‑
tors, is still in the post ‑closure phase. 
The Commission considers, in line with the Member States, that no plants subject to the NDAP can be economically 
restarted. It acknowledges that, as observed in other comparable decommissioning activities, the critical technical 
challenges of dismantling the reactors lie ahead.
VI
In the three Member States, the decommissioning programmes are at different level of advancement and maturity.
The Bohunice (SK) and Kozloduy (BG) programmes are the most advanced and scheduled for completion in 
2025 and 2030 respectively. The latter programme was shortened by 5 years when it was revised in 2011.
In Ignalina (LT), the decommissioning of the Chernobyl ‑type reactors is a first ‑of‑a‑kind process which actually 
entails the greatest challenges.
Notwithstanding the progress already achieved, the Commission recognises the need for continuous improvement 
in the decommissioning programmes.
Reply of the Commission 75
Recommendation 1
The Commission notes that recommendations 1(a) and 1(b) are addressed to the Member States. 
The Commission accepts recommendation 1(c), insofar as it is concerned by it. It supports the idea of an improved 
exchange of best practices and technical knowledge, and will encourage the three Member States to do so. 
(a) The Commission has already introduced improvements in the current MFF, establishing a comprehensive frame ‑
work for programming, project management and monitoring under which the Member States operate.
(b) It sees the need to continuously build up know ‑how and competences but notes that the use of external experts 
is beneficial in certain specialist areas. 
(c) The Commission has already taken action to promote an open and transparent environment, facilitate the ex ‑
change of best practices and knowledge and foster standardisation processes with the aim, inter alia, of increas ‑
ing competitiveness and enhancing safety. 
VII
The Commission recognises the importance of the responsible and safe management of spent fuel and radioactive 
waste. The Commission will provide opinions on the national programmes and report during 2016 to the Parliament 
and the Council on the implementation of Directive 2011/70.
The Commission furthermore notes that the issues related to the final disposal of high ‑level waste and spent fuel 
management go beyond the scope of the nuclear decommissioning assistance programme. 
Recommendation 2
(a) The Commission accepts the recommendation. The Commission will already set the direction in the opinions 
that it will issue during 2016/2017 on the national programmes under Directive 2011/70. This will launch the 
debate that will take place in 2017 on options for disposal, including regional and other EU‑based solutions. Fol ‑
lowing on from this, the Commission will be in a better position to formulate policy options and a roadmap by 
2018. 
(b) The Commission notes that this recommendation is addressed to Member States and is already being addressed 
through the assessment of the national programmes and the opinion the Commission will address to the Mem ‑
ber States.
VIII
The Commission acknowledges that co ‑financing is not systematically achieved at individual project level. It notes 
that the current legal base does not provide a clear definition of co ‑financing, or a minimum percentage to be 
achieved. The Commission notes, as reported by the Court, that the total contribution of Lithuania, Bulgaria and 
Slovakia to their respective decommissioning programmes amounts to 1.09 billion euro. 
Recommendation 3
The Commission notes that this recommendation is addressed to Member States. It will support the action rec ‑
ommended by the Court through its effort to introduce a well ‑defined level of co ‑financing in the context of the 
nuclear decommissioning assistance programme, thus supporting the polluter pays principle. In this respect, it will 
lead discussions with the Member States and examine critically the level of co ‑financing proposed by the Member 
States in the 2017 annual work programmes.
Reply of the Commission 76
Recommendation 4
The Commission accepts the recommendation. 
It recognises that co ‑financing contributes to the efficient and effective implementation of the programme and 
increases ownership by Member States. It will undertake actions to clarify the meaning of the ‘well ‑founded excep ‑
tional circumstances’ that are currently referred to in the regulations and critically examine the level of co ‑financing 
proposed by the Member States in the 2017 annual work programmes 
Recommendation 5
The Commission partially accepts the recommendation. The Commission will carry out an impact assessment in line 
with the requirements of the financial regulation and better regulation agenda with regard to proposals of new 
initiatives. This impact assessment will explore whether funding should be continued and if so the most suitable 
financing mechanisms. Should this assessment conclude that funding need to be continued for the next, post ‑2020, 
MFF, the Commission will take into account the Court’s recommendation and ensure that the funding mechanism 
includes incentives to pursue decommissioning, including by being time limited and based on appropriate levels of 
Member States’ co ‑financing.
Recommendation 6
The Commission partially accepts the recommendation. 
The Commission is in the process of identifying non ‑decommissioning ‑related costs. This process will be finalised in 
the mid ‑term evaluation and possible actions will be proposed for the phasing out of such costs in 2018. 
However, the Commission considers that some essential functions, such as safety, should not be excluded from EU 
funding.
Recommendation 7
The Commission accepts the recommendation and notes that action has already been taken. The assessment is 
ongoing and will be completed by October 2016.
Recommendation 8
The Commission accepts the recommendation. The Commission acknowledges the importance of this issue.
It has started addressing this recommendation through the implementation of the waste directive. The Commission 
is currently reviewing the national programmes submitted under the waste directive and has scheduled a number 
of studies in order to collect information and further engage in the validation. 
Reply of the Commission 77
Introduction
20
The EU nuclear landscape has undergone significant changes in the last decade with the adoption of landmark 
legis  lation at European level on nuclear safety, radioactive waste and spent fuel management and radiation pro ‑
tection. In addition, the Commission has adopted a new PINC in 2016, which for the first time covers the finan  cing 
needs related to the decommissioning of nuclear power plants and to the management of radioactive waste and 
spent fuel, including for the financing of long ‑term solutions such as the construction of deep geological disposal 
facilities. 
The radioactive waste directive (Council Directive 2011/70/Euratom) establishes a Community framework for ensur ‑
ing responsible and safe management of spent fuel and radioactive waste to avoid imposing undue burdens on 
future generations. The directive goes further than the joint convention in that Member States must have a national 
programme for the implementation of spent fuel and radioactive waste management policy.
The Commission through the PINC and the waste directive aims to compile for the first time a comprehensive pic ‑
ture of the full costs linked to decommissioning and waste management and how Member States ensure that these 
are financed according to the polluter pays principle. 
Observations
Common Commission reply to paragraphs 38 ‑40
The Commission considers, in line with the Member States, that no plants subject to the NDAP can be economically 
restarted.
40 First indent
While the Commission acknowledges that the licence ‑related expected output has not been met for the Ignalina 
plant, due to the presence of spent fuel in the installation, it also notes that the dismantling of the turbine hall in 
INPP effectively ensures the irreversibility of the process. 
40 Second indent
Regarding the Kozloduy (BG) plant, the Commission notes that the additional permits that might still be required 
are related to works that would occur past the point of reversibility. 
40 Third indent
Regarding the Bohunice (SK) plant, the current status is in line with the decommissioning plan and the scheduled 
end date of 2025.
Common Commission reply to paragraphs 41 ‑42
Whereas the Commission acknowledges that the main challenges still lie ahead, it also notes that the state of play 
illustrated by Table 3 is in line with the decommissioning plans and the scheduled end dates for all three Member 
States. The key dismantling operations in the reactor building are only possible towards the end of the decommis ‑
sioning process. 
Reply of the Commission 78
Common Commission reply to paragraphs 43 ‑46
The NDAP covers the decommissioning process and waste management infrastructure including the safe long ‑
term storage of waste and disposal of low ‑level waste. Low ‑level waste typically comprises over 90 % of the waste 
volume and mature solutions for disposal are available. Disposal of spent fuel and high ‑level waste is part of the 
Member States’ responsibility under the radioactive waste directive, and covers all such waste produced in the 
Member State.
48
Under Directive 2011/70/Euratom, each Member State shall ensure the implementation of its national programme 
for the management of spent fuel and radioactive waste, covering all types of spent fuel and radioactive waste 
under its jurisdiction and all stages of spent fuel and radioactive waste management from generation to disposal.
The Commission, for the first time, is compiling a comprehensive picture of the Member States’ plans with regard to 
disposal and associated costs.
Common Commission reply to paragraphs 49 ‑52
The Commission will investigate the economic, legal and social impacts of shared repositories, considering that the 
sharing of facilities for spent fuel and radioactive waste management, including disposal facilities, may be a poten ‑
tially beneficial, safe and cost ‑effective option.
53
Member States shall, for the first time, notify the Commission of the content of their national programme no later 
than August 2015. Within 6 months of the date of notification, the Commission may request clarification and/or 
express its opinion on whether the content of the national programme is in accordance with the directive. Member 
States shall provide the requested clarification and/or inform the Commission of any revision of the national pro ‑
grammes within 6 months of the Commission’s request.
Member States shall also submit a report to the Commission on the implementation of this directive for the first 
time by August 2015, and every 3 years thereafter.
On the basis of the Member States’ reports, the Commission shall submit to the European Parliament and the Coun ‑
cil the following: 
(a) a report on progress made with the implementation of this directive;
(b) an inventory of radioactive waste and spent fuel present in the Community’s territory and the future prospects.
This exercise is the first of its kind and the Commission intends to draw lessons from this process to try to improve 
and harmonise future reporting. For this particular exercise the Commission had to take into account the national 
programmes of all 28 Member States, as well as the national reports. In view of this, and in order to have a complete 
picture, the Commission took into account the assessment process of the national programmes in its timetable for 
the report to the Parliament and the Council. The report is expected in quarter 4 of 2016.
Reply of the Commission 79
Common Commission reply to paragraphs 60 ‑68
The Commission acknowledges that a  number of decommissioning projects experienced delays particularly in the 
previous MFF. The Commission has introduced increased planning, monitoring and reporting requirements for 
2014 ‑2020 and closely follows project implementation through desk and on ‑the ‑spot reviews.
It should be noted that the delays experienced in Bulgaria and Slovakia do not currently impact the end date. 
69
The Commission considers that it is of utmost importance that nuclear operators/licence holders for decommission ‑
ing build up know ‑how and competences, especially in project management. However, the use of external experts 
is beneficial in certain specialist areas.
Common Commission reply to paragraphs 73 ‑74
During the last decade, the outlook in terms of nuclear decommissioning has evolved considerably. The Commis ‑
sion has contributed to the improvement of cost estimation for decommissioning programmes and participated in 
the drawing up of the International Structure for Decommissioning Costing of Nuclear Installations (ISDC) in 2012 
together with OECD/NEA. Further developments of decommissioning cost estimation are still necessary; this is an 
issue of high interest worldwide, as the OECD/NEA and IAEA are still quite active in addressing cost estimation and 
uncertainties. The Commission fully supports these activities.
The Commission notes that the main costs increased by 2011 as also demonstrated in Figure 16. The change of 
momentum reflects the improvements made in the programme management resulting from the previous audit, in 
particular in the Bulgarian and Slovak programmes.
75
No financial gap is expected for the 2014 ‑2020 period while the Commission has increased its monitoring and scru ‑
tiny of the programmes. The Commission has also started an in ‑depth assessment of the robustness of the financing 
plans, which is expected to be finalised at the end of October 2016.
Furthermore, the Commission has used the QUEST model for macroeconomic policy analysis and research (which 
is used by the Commission for its forecasting) to run different scenarios for the programmes post ‑2020. The main 
result was that even in the worst case scenario the Member States can finance the decommissioning programmes 
with negligible or little impact on their macroeconomics parameters.
When considering the post ‑2020 financial framework, the Commission will carry out an impact assessment in line 
with the requirements of the financial regulation and better regulation agenda with regard to proposals for new 
initiatives, while making no commitment to any post ‑2020 funding at this point in time. This impact assessment will 
explore whether funding should be continued and, if so, the most suitable financing mechanisms. See the Commis ‑
sion’s reply to recommendation 5.
77
In addition, the Commission has strengthened programming under the 2014 ‑2020 MFF, introducing as a prerequisite 
the submission of decommissioning and financing plans. The completeness and robustness of these plans is cur ‑
rently being assessed by an external independent expert.
Reply of the Commission 80
80
The Commission has requested a thorough analysis of the staffing at Ignalina power plant, bearing in mind the 
need not to endanger the safety of the site given the presence of spent fuel in the reactor and the relatively greater 
hazard currently remaining. 
82
The Commission recognises the risk that insufficient incentives to keep the staffing level to the level strictly neces ‑
sary might result in increased cost. For several years various measures are have been taken to mitigate this risk, 
including a systematic assessment of the advantages of outsourcing activities and a yearly quantitative staffing plan 
based on the planned activities. Discussions are ongoing on practical ways to further use co ‑financing schemes to 
align the interests of local stakeholders with those of the Commission.
84
The Commission notes that the funding gaps are closing for both BG and SK. The Commission assessments are 
based on the decommissioning plan and the available resources. They will be reassessed following the results of the 
mid ‑term evaluation. 
85
The Commission is aware that further work is needed in relation to decommissioning cost estimation. This is also 
acknowledged by other international organisations such as OECD/NEA and IAEA. The Commission closely follows 
developments in this area and has an expert group on decommissioning funding through which it will focus its 
efforts in this area. 
With regard to the programmes in question, the Commission uses a more conservative, prudent approach than the 
Member States. However, in the case of Bulgaria and Slovakia the general trend being observed for the financing 
gap is downwards. 
See also the Commission’s replies to paragraph 75 and recommendation 5.
87
The Commission’s Internal Audit Service had already identified these weaknesses in the management and control 
system. Consequently an action plan has been in place since 2015 and is currently being implemented. The key 
actions addressing the issue underlined by the Court will be completed by the end of October 2016 and a further 
set of agreed actions is due by end of the year. 
Common reply to paragraphs 89 ‑90
Taking into account that these plants faced premature closure due to a political decision, it is logical that the funds 
cannot cover the entire costs of decommissioning. One of the triggers for EU financial support was to mitigate the 
resulting financial burden to the given Member States.
Reply of the Commission 81
91
The legal basis does not set any level of national co ‑financing. It only refers to the need to continue the previously 
established co ‑financing practice. Although not generally achieved at the individual project level, there will be co ‑
financing at the overall programme level. 
The total contribution of Lithuania, Bulgaria and Slovakia to their respective decommissioning programmes 
amounts to 1.09 billion euro. 
92
The Commission considers the objective of strengthening national co ‑financing important. However, at this stage 
the Commission is not in the position to make a firm commitment on the Court’s recommendation to increase co ‑
financing by Member States by end of 2016. The possible options will be examined during the mid ‑term evaluation 
of the programme to be carried out in 2017.
93
The decommissioning plans and cost estimates approved under the 2014 ‑2020 MFF are the basis for programming 
in the three Member States. Disposal of spent fuel and high ‑level waste is part of the Member States responsibility 
under the radioactive waste directive and for this reason it was not included in the NDAP . 
94
Directive 2011/70/Euratom states that the costs for the management of spent fuel and radioactive waste shall be 
borne by those who generated those materials (Article 4(3)(e)), as well as the clear allocation of responsibilities to 
the bodies involved in the different steps of spent fuel and radioactive waste management (Article 5(1)(f)), and 
that Member States shall ensure that the national framework require that adequate financial resources be avail ‑
able when needed, especially for the management of spent fuel and radioactive waste, taking due account of the 
responsibility of spent fuel and radioactive waste generators (Article 9).
95
The implementation of the waste directive by the Member States is a  priority for the Commission. Currently the 
review of the Member States national programmes is ongoing and it will address all these issues. 
96
The decommissioning plans include the cost of the management of the spent fuel and radioactive waste, as 
required by the NDAP regulations. They do not include the cost of disposal projects to be started in the long term. 
They do include the cost of the storage facilities needed to bridge this gap.
Reply of the Commission 82
Conclusions and recommendations
107
Since the 2011 audit, the Commission has introduced a number of important improvements in programming and 
project management. The 2014 ‑2020 legal basis has introduced specific objectives measured by key performance 
indicators and a  new monitoring and reporting framework.
The Commission considers that, as a result, the EU financial support has effectively mitigated the economic conse ‑
quences of the early closure and the decommissioning process is well engaged. However, it notes that decommis ‑
sioning is a complex and lengthy process going beyond the 7 ‑year MFF — in most cases exceeding two decades. 
The updated decommissioning plans and associated cost estimates approved under the 2014 ‑2020 MFF are the 
basis for programming in the three Member States. Under these arrangements, the Commission is closely monitor ‑
ing progress towards the decommissioning end state whilst maintaining the highest level of safety.
Common Commission reply to paragraphs 108 ‑111
The Commission monitors in a  proactive manner implementation towards the achievement of the objectives set out 
in the Council regulations and reports annually to the Parliament and the Council.
Decommissioning is generally composed of two major phases: (i) post ‑closure (i.e. still under operational licence 
due to the presence of spent fuel) and (ii) decommissioning/ dismantling.
Slovakia and Bulgaria are in the second phase while Lithuania, due to the presence of spent fuel in one of the 
re actors, is still under the post ‑closure phase. 
The Commission considers, in line with the Member States, that no plants subject to the NDAP can be economically 
restarted. It acknowledges that, as observed in other comparable decommissioning activities, the critical technical 
challenges of dismantling the reactors lie ahead.
Recommendation 1 — Ensure progress in decommissioning 
The Commission notes that recommendations 1(a) and 1(b) are addressed to the Member States.
The Commission accepts recommendation 1(c), insofar as it is concerned by it. It supports the idea of an improved 
exchange of best practices and technical knowledge, and will encourage the three Member States to do so.
(a) Under the current MFF the Commission has prioritised the establishment of an overall framework for program ‑
ming, project management and monitoring for the Member States to work within. In addition, the Commission 
has introduced an earned value management (EVM) system to measure project performance and progress in an 
objective manner. The full impact of these changes is expected in the coming years.
(b) The Commission considers that it is of utmost importance that nuclear operators/licence holders for decommis ‑
sioning build up know ‑how and competences, especially in project management, and identify the areas where 
outsourcing of services adds value. Use of external experts is beneficial in certain specialist areas.
(c) The Commission tries to promote an open and transparent environment, facilitate exchange of best practices 
and knowledge and foster standardisation processes with the aim, inter alia, of increasing competitiveness and 
enhancing safety. 
Reply of the Commission 83
To support this aim, the Commission has reactivated in 2015 the Decommissioning Funding Group that consists of 
national experts that provide up ‑to‑date knowledge on decommissioning costs and the management of funding. 
In addition, the Commission will use its participation in international fora and working groups to share the experi ‑
ence gained through the management of the decommissioning programmes. In particular, the activities in collabor ‑
ation with IAEA and OCED/NEA will be pursued. 
112
Regarding the report on Member State plans, see the Commission’s reply to paragraph 53.
The Commission is currently assessing the national programmes of all 28 Member States. This exercise is the first 
of its kind and the Commission intends to draw lessons from this process to try to improve and harmonise future 
reporting. For this particular exercise the Commission had to take into account the national programmes of all 28 
Member States as well as the national reports. In view of this, and in order to have a complete picture, the Com ‑
mission took into account the assessment process of the national programmes in its timetable for the report to the 
Parliament and the Council. The report is expected in quarter 4 of 2016. 
Recommendation 2 — Solutions for the final disposal of spent nuclear fuel
(a) The Commission accepts the recommendation. The Commission attaches significant importance to the safe 
and responsible management of spent fuel and radioactive waste to avoid imposing undue burdens on future 
gener  ations. In this regard, the Commission will already set the direction in the opinions that it will issue during 
2016/2017 on the national programmes under Directive 2011/70. This will launch the debate that will take place 
in 2017 on options for disposal, including the possibility of regional and other EU‑based solutions. Following on 
from this, the Commission will be in a better position to formulate policy options and a roadmap by 2018. 
(b) The Commission notes that this recommendation is addressed to Member States. It also notes that this is 
already being addressed through the assessment of the national programmes and the opinion the Commis ‑
sion will address to the Member States. The Commission intends to launch a study in 2017 in order to assess the 
Member States’ waste management cost estimates.
113
The decommissioning plans approved under the 2014 ‑2020 MFF are the basis for programming in the three Member 
States. The cost of final disposal of spent fuel and high ‑level waste is not considered eligible under the NDAP and 
it is not part of the baseline. Disposal of spent fuel and high ‑level waste is part of the Member States’ responsibility 
under the radioactive waste directive. The NDAP should ensure complementarity and consistency of relevant Union 
intervention, to respect the principle of proportionality. 
114
The Commission stresses that, under the 2014 ‑2020 MFF, there is no shortfall in the funding of the agreed 
objectives. 
Recommendation 3 — Respecting the polluter pays principle by increasing national 
financing for 2014 ‑2020 and beyond 
The Commission notes that this recommendation is addressed to Member States. 
Reply of the Commission 84
The Commission will support the action recommended by the Court through its effort to introduce a well ‑defined 
level of co ‑financing, thus supporting the polluter pays principle. In this respect, it will lead discussion with the 
Member States and examine critically the level of co ‑financing proposed by the Member States in the 2017 annual 
work programmes.
Recommendation 4 — Increase in national co ‑financing in the 2014 ‑2020 financing 
period 
The Commission accepts the recommendation. 
The Commission recognises that co ‑financing contributes to the efficient and effective implementation of the 
programmes and increases ownership by the Member State. However, the current legal base does not set a specific 
level for such co ‑financing. The Commission will therefore, as a  first step, undertake actions to clarify the meaning 
of the ‘well ‑founded exceptional circumstances’ that are currently referred to in the regulations and critically exam ‑
ine the level of co ‑financing proposed by the Member States in the 2017 annual work programmes. 
Recommendation 5 — Discontinue dedicated funding programmes for nuclear 
decommissioning in Lithuania, Bulgaria and Slovakia after 2020
The Commission partially accepts the recommendation. The Commission will carry out an impact assessment in line 
with the requirements of the financial regulation and better regulation agenda with regard to proposals of new 
initiatives. This impact assessment will explore whether funding should be continued and, if so, the most suitable 
financing mechanisms. Should this assessment conclude that funding needs to be continued for the next post ‑2020 
MFF, the Commission will take into account the Court’s recommendation and ensure that the funding mechanism 
includes incentives to pursue decommissioning, including by being time limited and based on appropriate levels of 
Member States’ co ‑financing.
118
The Commission has requested a thorough analysis of the staffing at the Ignalina power plant, bearing in mind the 
need not to endanger the safety of the site, given the presence of the remaining spent fuel in the reactor buildings, 
the associated hazards and the resulting need to maintain essential safety functions.
Recommendation 6 — EU funding only for cost of decommissioning 
The Commission partially accepts the recommendation.
The Commission is in the process of identifying non ‑decommissioning related costs. This process will be finalised in 
the mid ‑term evaluation and possible actions will be proposed for the phasing out of such costs in 2018.
However, the Commission considers that some essential functions, such as safety, should not be excluded from EU 
funding. 
Recommendation 7 — Improving Commission oversight
The Commission accepts the recommendation and action has already been taken. The assessment of the ex ante  
conditionalities will be completed by October 2016.
Recommendation 8 — Accounting treatment
The Commission accepts the recommendation. The Commission acknowledges the importance of this issue.
It has started addressing this recommendation through the implementation of the waste directive. The Commission 
is currently reviewing the national programmes submitted under the waste directive and has scheduled a number 
of studies in order to collect information and further engage in the validation. 
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Event Date
Adoption of the audit planning memorandum/start of audit 25.3.2015
Official sending of draft report to Commission (or other auditee) 2.5.2016
Adoption of the final report after the adversarial procedure 14.7. 2016
Commission’s (or other auditee’s) official replies received in all languages 15.7.2016
The decommissioning of eight Soviet-designed nuclear 
reactors in Lithuania, Bulgaria and Slovakia was a  condition 
for the countries’ EU accession. We found that the EU 
funding programmes set up to assist with meeting this 
requirement have not created the right incentives for timely 
and cost-effective decommissioning. While some progress 
has been made, key infrastructure projects have 
experienced delays, and the critical challenges involved in 
working in the controlled areas still lie ahead. By 2020, EU 
support should have reached 3.8 billion euro. The estimated 
total cost of decommissioning will be at least 5.7 billion 
euro. If the cost of final disposal of high-level waste is 
included, this total could double.
EUROPEAN
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