EUROPEAN COMMISSION Brussels, 13.6.2018 SWD(2018) 344 final COMMISSION STAFF WORKING DOCUMENT EVALUATION Accompanying the document Report from the Commission to the European Parliament and the Council on the evaluation and implementation of the EU nuclear decommissioning assistance programmes in Bulgaria, Slovakia and Lithuania {COM(2018) 468 final}



Table of contents Summary 1 Introduction 1.1 Purpose and scope 1.2 Main issues 1.3 Evaluation criteria 2 Background to the intervention 2.1 Historical development of the NDAP 2.2 Intervention logic 2.2.1 Objectives 2.2.2 Management of the NDAP 2.3 Baseline and points of comparison 3 Implementation / state of Play 4 Method 4.1 Previous evaluations and other reports 4.2 Evidence from monitoring 4.3 Specific evaluation actions 4.4 Limitations and robustness of findings 5 Analysis and answers to the evaluation questions

5.1 Relevance 5.1.1 Evaluation Question 1 To what extent are the general and specific objectives of the NDAP still appropriate in relation to the existing needs? 5.2 Coherence 5.2.1 Evaluation Question 2 Is the NDAP coherent with the Euratom Treaty’s acquis in the area of nuclear safety and responsible management of spent fuel and radioactive waste? and with the EU acquis in other relevant areas? 5.3 Effectiveness 5.3.1 Evaluation Question 3 To what extent have the objectives of the NDAP been achieved for each of the three programmes? 5.3.2 Evaluation Question 3.1 Overall, what level of progress has been made towards the objectives of each national programme? Is the progress in line with the decommissioning baseline adopted by the Commission? If not, what is the risk that objectives will not be achieved? 5.3.3 Evaluation Question 3.2 What external and internal factors influenced (positively and negatively) the progress of the decommissioning programmes? 5.3.4 Evaluation Question 3.3 To what extent has the level of risk at each nuclear site been improved thanks to the NDAP support? 5.3.5 Evaluation Question 3.4 To what extent are Monitoring & Control systems in place to measure the progress of the decommissioning programmes? 5.3.6 Evaluation Question 3.5 Are the communication actions addressed to the stakeholders and the public effective, adequate and accurate? 5.3.7 Evaluation Question 4 Aside from the financial assistance provided, what other types of results and impacts can be attributed to the NDAP? 5.3.8 Evaluation Question 5 How effective is the governance and project management framework at EU and national levels? 5.3.9 Evaluation Question 5.1 How well are roles defined and effective at EU level in terms of planning, monitoring and reporting? 5.3.10 Evaluation Question 5.2 At national level, how well are the roles of the Programme Coordinator defined and effective in terms of: planning; monitoring; and reporting? 5.3.11 Evaluation Question 5.3 How effective is the governance system of the decommissioning programmes? 5.4 Efficiency 5.4.1 Evaluation Question 6 To what extent is the management of the decommissioning programmes cost effective and efficient? 5.4.2 Evaluation Question 6.1 To what extent has the NDAP been cost-effective when considering each activity and cost category compared against performance indicators? 5.4.3 Evaluation Question 6.2 What are the major factors impacting the efficiency of the assistance programmes? What are the root causes of these factors?

5.4.4 Evaluation Question 6.3 What factors can explain differences in costs (and possibly benefits) arising between Member States? 5.4.5 Evaluation Question 7 How does the governance and management system of the NDAP compare to other programmes managed by the Commission (or other actors)? Do these comparators provide any best practices in terms of governance or management? 5.5 EU Added Value 5.5.1 Evaluation Question 8 What would be the likely result of ending the NDAP in the three Member States concerned? 6 Conclusions 6.1 Assessment by evaluation criteria 6.1.1 Relevance 6.1.2 Coherence 6.1.3 Effectiveness 6.1.4 Efficiency 6.1.5 EU added value 6.2 Scope for modification of the detailed implementation procedures 6.2.1 Roles and responsibilities 6.2.2 Programming and Monitoring 6.2.3 Simplification 6.2.4 Co-financing 6.3 Opportunities for improvement 6.3.1 Knowledge sharing 6.3.2 Waste-led decommissioning

Glossary Term or acronym Meaning or definition 2011 IA the 2011 NDAP impact assessment - SEC(2011)1387 AWP Annual Work Programme CEF Connecting Europe Facility - a key EU funding instrument to promote growth, jobs and competitiveness through targeted infrastructure investment at European level CPI Cost Performance Index – indicator used by the Earned Value Management method CPMA Central Project Management Agency – national agency in Lithuania D&D Dismantling and Decontamination detailed implementation procedures Commission Implementing Decision C(2014)5449 of 7 August 2014 on the rules of application for the nuclear decommissioning assistance programmes for Bulgaria, Lithuania and Slovakia for the period 2014-2020 EBRD European Bank for Reconstruction and Development - an international financial institution EIA Environmental Impact Assessment EQ Evaluation Question EVM Earned Value Management - a management methodology for objectively measuring project performance and progress IAEA International Atomic Energy Agency INEA Innovation and Networks Executive Agency INPP Ignalina Nuclear Power Plant – the decommissioning operator for the Ignalina programme ISDC International Structure for Decommissioning Costing - a standard itemisation of decommissioning costs JAVYS Jadrová a vyraďovacia spoločnosť – the decommissioning operator for the Bohunice programme KNPP Kozloduy Nuclear Power Plant – the company operating the Kozloduy nuclear units 5 and 6 ESIF European Structural and Investment Funds ESIF Major Projects Large-scale infrastructure projects implemented under European Structural and Investment Funds MFF Multi-Annual Financial Framework NDAP Nuclear Decommissioning Assistance Programmes 2013 NDAP Regulations Council Regulations 1368/2013/Euratom and 1369/2013/EU on Union support for the nuclear decommissioning assistance programmes in Bulgaria, Slovakia and Lithuania NPP Nuclear Power Plant PMU Project Management Unit – temporary team, usually constituted in part by external consultants, assisting an organisation with project management competences RBMK A type of graphite-moderated nuclear power reactor designed and built by the Soviet Union SERAW Държавно предприятие „Радиоактивни отпадъци” or State Enterprise Radioactive Waste - the decommissioning operator for the Kozloduy programme SIEA Slovak Innovation and Energy Agency - national agency in Slovakia SME Small and Medium Enterprises SPI Schedule Performance Index – indicator used by the Earned Value Management method VVER A type of pressurised water reactor designs originally developed in the Soviet Union Summary The mid-term evaluation of the Nuclear Decommissioning Assistance Programme (NDAP) for the period 2014-2020 provides robust evidence, analysis and conclusions with regards to i) the results of the programmes against the NDAP objectives, as well as the irreversibility of nuclear plants’ shut-down, enhancement of nuclear safety, changes in organisational structures of decommissioning operators and management systems, ii) the efficiency of the use of resources, and iii) the EU Added Value of the programmes. Other evaluation criteria (e.g. relevance & coherence) and the indirect impacts of the NDAP were also examined. Having begun the process of decommissioning at different points in time and with each national decommissioning programme subject to unique factors and challenges (e.g. type and size of units, existence of necessary waste management infrastructure, major delays etc.), the programmes have attained different levels of advancement to date. The expected decommissioning end dates range from 2025 for Bohunice to 2030 for Kozloduy and 2038 for Ignalina. By 2020, some EUR 2 995 million in EU financial assistance is expected to have been committed within the framework of the NDAP since 1999 for nuclear decommissioning, of which EUR 671 million for Bohunice (SK), EUR 731 million for Kozloduy (BG) and EUR 1553 million for Ignalina (LT). This amount is in addition to national contributions mobilised through dedicated funds and/or programmed budgets. The total allocated amount of national contributions currently amounts to EUR 1 086 million. EU already disbursed EUR 1366 million to date. Main findings & conclusions The NDAP remains a relevant & coherent instrument The NDAP remains a relevant instrument for supporting the three decommissioning programmes and is well embedded in the wider policy and regulatory context. On the general level, the objective set out for the programmes in the Regulations remains relevant: the NDAP continues to support a stepwise reduction in the level of risk and radiological hazard at the three sites concerned. Current decommissioning strategies for the three programmes and on-going activities also remain at present fully aligned with the specific and detailed objectives set out for each programme. Coherence with the Euratom Treaty’s acquis in the area of nuclear safety and management of spent nuclear fuel and radioactive waste has been ensured through the legal base of the NDAP, even if the programme constitutes an exception to some underlying principles enshrined in the Euratom acquis. Programmes are generally on track to achieve objectives for the current MFF Programmes can generally be considered to be on track towards reasonably achieving the principal objectives set for this programming period. However, satisfactory achievement of the objectives will in some cases require proactive management or projects and programmes to recover delays and mitigate present and future risks. Actual physical dismantling of equipment is progressing relatively quickly compared to previous programming periods. Dismantling & Decontamination work in the turbine halls and auxiliary buildings is winding down at Bohunice and progressing well at Ignalina and Kozloduy. The Bohunice programme has embarked on important physical works in the Controlled Area, whereas the Ignalina and Kozloduy programmes remain at different stages of the preparatory phase. Delays and challenges during this phase will need to be managed closely to avoid longer-term delays with the beginning of major physical works. This progress reflects the nature of nuclear decommissioning programmes, which require significant upfront investment in planning and supporting infrastructure. Investments under previous programmes have thus laid the foundation for the progress being achieved today. In particular, the completion of key waste management infrastructure projects has laid the groundwork for accelerating work at Ignalina and Kozloduy. At Ignalina, for example, the commissioning of the Interim Spent Fuel Storage Facility puts the programme on track to complete the critical task of defueling. Finally, progress against waste management targets has been slow to date, although programmes should be able to recover delays. This underperformance has mainly been the result of uncertainties concerning radiological inventory and / or lack of anticipation of regulatory procedures leading to under or overestimations of target values, slower than planned progress with D&D activities, technical challenges related to specific legacy waste streams and some delays in the commissioning of waste management facilities. Reduction of radiological hazards Since reactors’ final shutdown, the level of risk at each site has been reduced in a stepwise manner, notably with the defueling of reactors and the decontamination, dismantling and disposal of contaminated and irradiated equipment and materials. At Kozloduy and Bohunice, the remaining radiological hazard concerns primarily workers inside the nuclear facility. The most significant risk reduction was achieved in the previous programming period and the level of risk to the surrounding environment and general population has been highly diminished. In comparison, a relatively significant level of risk remains at Ignalina prior to the completion of defueling activities. During the period covered by this mid-term evaluation, the NDAP has contributed to a risk reduction associated with the Ignalina site with the beginning of defueling activities. This contribution will continue to increase significantly in the coming five years as the process follows its course. Improved Monitoring & Control framework

With the current programming period, significant progress has been achieved compared with previous generations of the programme in terms of articulating clear objectives and translating those objectives into a robust monitoring framework. The introduction of Earned Value Management has also enhanced the quality of programme monitoring. New templates were developed for key monitoring and programming documents that are reviewed at new programme-level Monitoring Committees. The Commission also continues to conduct regular monitoring missions. While these developments represent an important step forward, some continued progress is desirable in terms of improving the quality of certain indicators, adjusting and streamlining the contents of Monitoring Reports and Annual Work Programmes and continuing to perfect the implementation and use of the Earned Value Management system. Programme governance & management structures The programme governance and management system is generally considered to be fit-for-purpose. It provides for a clear and logical division of roles and responsibilities and is adapted to the specific constraints of the programme. In practice, however, some divergences can be observed between the intended and actual functioning, which may impact its effectiveness and efficiency. Programme Coordinators have assumed an increasing ownership of the implementation of decommissioning programmes thanks to political and procedural efforts to strengthen their role as well as a now high level of buy-in; however, there remains further margin for continuing to strengthen their role to varying extents, in particular through stronger technical capacity. Moreover, the current detailed implementation procedures afford only limited latitude to Programme Coordinators to assume a more active role in programme governance. The national contribution levels achieved appear suitable for sustaining proper efficiency; however, they are not established in the legal basis, which creates residual uncertainties. Increasing national relative to EU contributions and defining a clear and formalised framework for ‘co-financing’ (either at programme or project level) would very likely continue to encourage greater national ownership. Cost performance has been satisfactory, but margins for improvements have been noted The cost performance of all three programmes has generally been satisfactory to date. This stands in contrasts to difficulties with some programmes faced in the previous MFFs. At the time of the study, the 2014 programme cost estimates are expected to be maintained or decrease slightly for Ignalina and Bohunice respectively. The recent revision of the Kozloduy decommissioning overall cost estimate shows an increase (+23%) which does not affect the size of the funding gap because the national contribution has been increased as well in response to the outcome of the plan's revision. Some of the largest increases in project budgets over the years are in fact a result of revised planning and cost estimation or simple uncertainty rather than cost increases per se. Following poorly made initial estimates, project cost estimates naturally increased as the technical design, planning and regulatory uncertainties became clearer. However, decommissioning operators have strengthened their planning and cost estimation methodologies, notably at Kozloduy and Ignalina. The stronger management allows for further transfer of risks (cost overruns, delays) to the respective Member States, which in turn would empower the beneficiaries to seek increased cost performance. EU Added Value The NDAP has been important to supporting the decommissioning processes in the current MFF. Continued progress of decommissioning would likely have been negatively impacted to varying degrees in absence of the NDAP during the current programming period. Nonetheless, the added value of the programme is naturally declining as implementation progresses. The EU added value of the NDAP from its beginning has been cast in terms of financial mitigation and nuclear safety. With a finite level of radioactivity on site, however, each additional euro of investment provides decreasing rates of return. The EU added value of the programme is thus naturally decreasing over time. Moreover, the funding gap for two of the three programmes (Kozloduy and Bohunice) has been closed to small amounts that do not pose risks for State finances. The question of the continued added value of the programme can thus be raised on the basis of the diminishing rate of return observed at present; however, other types of EU added value could be further leveraged to justify an adequate ‘return on investment’ for Europe for future EU assistance. Of the more than 90 nuclear reactors currently permanently shut down in Europe, only three have been completely dismantled. The level of experience in the dismantling of nuclear reactors in Europe (as well as internationally) is thus limited. The NDAP’s contribution to securing the shutdown and immediate dismantling of these reactors has led to the generation of a highly significant amount of experience that can be of benefit to other decommissioning projects. However, the large part of this added value remains confined to the companies benefiting from NDAP contracts and the decommissioning operators. While these actors are well placed to disseminate and apply this knowledge in the future, there are no mechanisms in place to ensure this knowledge is diffused into the public domain for use by relevant actors, other NPPs, decommissioning operators, national authorities, research actors, etc. 1Introduction 1.1Purpose and scope When they acceded to the EU, Bulgaria, Slovakia and Lithuania committed to shutting down eight nuclear reactors before the end of their scheduled lifetime: ·Kozloduy nuclear power plant in Bulgaria (units 1 to 4); ·Bohunice V1 nuclear power plant in Slovakia (2 units); and ·Ignalina nuclear power plant in Lithuania (2 units). The EU itself committed to providing financial assistance for decommissioning those reactors. The Nuclear Decommissioning Assistance Programmes (NDAP) as defined in the relevant Council Regulations, (the 2013 NDAP Regulations) were set up to provide support to these decommissioning programmes in the Multiannual Financial Framework (MFF) 2014-2020, continuing the assistance provided in previous periods.

This mid-term evaluation of the NDAP focuses on the current setup and refers to the period 2014-2017 unless specified otherwise. This evaluation supports the Commission's report to the European Parliament and the Council. The evaluation also addresses the scope for modification of the detailed implementation procedures. Finally, the conclusions of this evaluation have fed in the preparation of the programme proposals for the next MFF. 1.2Main issues The evaluation focuses on the following topics: ·Safety – enhancement of nuclear safety and safety standards for public health and environment. ·Governance – impact of the changes introduced in 2014 and scope for possible further improvement. ·Programmes output – the irreversibility of the plants shut-down and their decommissioning as well as overall progress and performance of the decommissioning programmes. ·Knowledge – know-how development, knowledge sharing / codification with potential for positive effects in the general EU decommissioning market. The evaluation also touches the economic, social and environmental impacts stated in the 2011 NDAP impact assessment (hereafter the "2011 IA"). 1.3Evaluation criteria In line with the requirements of the Better Regulation guidelines, the mid-term evaluation of the NDAP has assessed the effectiveness, efficiency, relevance, coherence and EU added value of the assistance programmes. The progress of the implementation has been evaluated against the specific and detailed objectives of the 2013 NDAP Regulations and more generally against the detailed decommissioning plans and the successive annual work programmes that set the basis for the monitoring of the programmes. In addition the issues of risk, sustainability, simplification, complementarity, coordination, and communication have been considered even though no specific objectives were defined in those domains. 2Background to the intervention 2.1Historical development of the NDAP The 1986 Chernobyl disaster and its cross-border impact generated broad concern in Europe and beyond with regard to the operation of some first generation nuclear reactor types. At the 1992 Munich summit, the G-7 heads of state and government committed to supporting the countries of Central and Eastern Europe with Soviet-designed nuclear power plants requiring safety upgrades. As part of these efforts the EU provided financial and technical assistance to partner countries through the TACIS and PHARE programmes.



In the framework of their EU accession negotiations, Bulgaria, Lithuania and Slovakia made a formal commitment to close eight reactors located on their territories.

Member State Reactor unit / type Envisaged operational lifetime Closure date Bulgaria Kozloduy NPP Unit 1: VVER- 440/230 1974 - 2004 2002 Unit 2: VVER- 440/230 1975 - 2005 2002 Unit 3: VVER- 440/230 1981 - 2011 2006 Unit 4: VVER- 440/230 1982 - 2011 2006 Slovak Rep. Bohunice V1 Unit 1: VVER- 440/230 1980 - 2008 2006 Unit 2: VVER- 440/230 1981 - 2010 2008 Lithuania Ignalina NPP Unit 1: RBMK 1500 1984 - 2013 2004 Unit 2: RBMK 1500 1987 - 2017 2009 Source: 2011 IA It is to be noted that on the Kozloduy site there are also two reactors in operation (Kozloduy units 5 & 6) and on the Bohunice site there is also another reactor in decommissioning (Bohunice A1) and two reactors in operation (Bohunice V2 units 3 & 4); decommissioning of these facilities is not eligible under this assistance programme. When this document further refers to Kozloduy and Bohunice, it refers to Kozloduy units 1 to 4 and Bohunice V1 units 1 & 2 respectively. Recognising the financial burden due to the closure of these reactors on the economies of Bulgaria, Slovakia and Lithuania (hereafter the concerned Member States, unless specified otherwise), the EU committed to provide assistance, to support the decommissioning process as well as support for mitigation measures to address the consequences of early closure. In all three cases, the reactors were shutdown, as per the timescales set out in the Accession Treaties. The Union assistance, provided through the Nuclear Decommissioning Assistance Programmes can be divided into four distinct periods beginning during the pre-accession period and stretching to the current Multi-Annual Financial Framework (MFF): ·During the pre-accession period (up to 2004 for Slovakia and Lithuania and 2007 for Bulgaria), the three countries received funding through the instruments targeted at candidate and partner countries (PHARE and later the Instrument for Pre-accession Assistance). ·Financial assistance over the second period (2004 - 2006 for Slovakia and Lithuania and 2007 – 2009 for Bulgaria) was provided under the protocols to the countries’ accession acts. ·Since 2007 for Slovakia and Lithuania and 2009 for Bulgaria, Council regulations have ensured the continuation of assistance for decommissioning assistance programmes until 2013. ·Two Council Regulations were adopted on 13 December 2013 to provide support to these decommissioning programmes in the period 2014-2020, continuing the assistance but restricting its scope to decommissioning activities only and excluding mitigation measures in the energy sector that were supported in previous periods. The overall EU financing made available to the three programmes for decommissioning (and mitigation measures in the energy sector until 2013) are summarised in the table below. Programme 1999 – 2013 (M€) 2014 – 2020 (M€) Total 1999 – 2020 (M€) Kozloduy (BG) 868 293 1 161 Bohunice (SK) 612 225 837 Ignalina (LT) 1 367 451 1 818 Total 2 847 969 3 816 Source: Commission financing decisions Early political resistance in the Member States in past MFFs has given way to acceptance and greater ownership. The political commitment obtained by the EU for the early closure of the reactors in the three Member States was met with some domestic resistance in early years, with negative impacts on both the political and technical levels. Already before the end of the previous programming period, this resistance had progressively given way to widespread acceptance of the irreversible nature of the shutdown of the reactors and resulted in positive developments at technical level. Increasingly, this has also been translated into increased ownership over the decommissioning process on the part of national governments. 2.2Intervention logic The underlying need, which constitutes the starting point of the intervention logic, is to contribute to the safety of citizens by ensuring that all nuclear plants in the EU meet the high level of safety standards required in the EU. It is this need that has been at the heart of the Union action in this domain from the very beginning. The NDAP answers the need for the timely availability of funds for ensuring the safe and immediate decommissioning resulting from the decision to prematurely shutdown the nuclear reactors in question. 2.2.1Objectives The 2013 NDAP Regulations define the general objective (article 2.1) and the specific objectives (article 2.2) for each programme. The general objective is to assist Member States in implementing the steady process towards the decommissioning end state of the reactors in question in accordance with their respective decommissioning plans, whilst maintaining the highest level of safety.

The 2013 NDAP Regulations required a number of ex-ante conditionalities to be met prior to the start of the programming period. These required the set-up and agreement of the detailed decommissioning plans that would later serve as the baseline of the programmes against which progress would be measured and eligibility would be determined. In 2014, the three Member States submitted their detailed decommissioning plans. The plans describe the decommissioning end state, a schedule for all tasks required to reach this situation, and the related cost estimates. They constitute a clear and comprehensive baseline for assessing the progress of the implementation globally and at the level of each project. It should be noted that unlike in previous programming periods, the current NDAP did not include further support to mitigate the consequences of the early closure of the nuclear power plants. It restricted EU support to the tasks described in the approved detailed decommissioning plans, so focussing on safety related activities.



The specific objectives for each programme are summarised in the table below. Plant Specific Objectives (as per Article 2.2 of the 2013 NDAP Regulations) Kozloduy (BG) 1. Performing dismantling in the turbine halls of units 1 to 4 and in auxiliary buildings; 2. Dismantling of large components and equipment in the reactor buildings of units 1 to 4; and 3. Safely managing the decommissioning waste in accordance with a detailed waste management plan. Bohunice (SK) 1. Performing dismantling in the turbine hall and auxiliary buildings of reactor V1, to be measured by the number and type of systems dismantled; 2. Dismantling of large components and equipment in the V1 reactor buildings, to be measured by the number and type of systems and equipment dismantled; and 3. Safely managing the decommissioning waste in accordance with a detailed waste management plan, to be measured by the quantity and type of safely conditioned waste. Ignalina (LT) 1. Defueling of the reactor core of unit 2 and the reactor fuel ponds of units 1 and 2 into the dry spent fuel storage facility; 2. Safely maintaining the reactor units; and 3. Performing dismantling in the turbine hall and other auxiliary buildings and safely managing the decommissioning waste in accordance with a detailed waste management plan. Source: 2013 NDAP Regulations Additionally, detailed objectives, targets, milestones and performance indicators have been defined for each programme and each specific objective in annexes to the detailed implementation procedures. To achieve these objectives, inputs such as EU and national financial resources and expertise are translated into programme activities. These activities are defined in the annual work programmes prepared by the concerned Member States, and further detailed in project documentation. The results and impacts naturally mirror the objectives of the NDAP as presented above. 2.2.2Management of the NDAP Due to the high level of technical capacity and expertise necessary to implement decommissioning activities and within the historical context at that time, in 2001 implementation tasks were delegated to the European Bank for Reconstruction and Development (EBRD). The accession of the three countries to the EU has given access to additional options. In Lithuania, the Central Project Management Agency (CPMA), a national public-sector body, has been selected and approved by the Commission to act as an Implementing Body since 2003. Since 2015, Slovakia has also formally established a national implementation channel, the Slovak Innovation and Energy Agency (SIEA), which implements all new projects. The first project to be implemented by the SIEA was approved in May 2017. Thus in Lithuania and Slovakia the implementation of union budget is progressively being transferred to national bodies. Each concerned Member State appoints a Programme Coordinator (ministerial or state secretary rank) to be responsible for the overall programming, coordination and monitoring of the decommissioning programme. In Bulgaria and Slovakia, the facilities to be decommissioned were transferred from the nuclear plant operator to separate organisations; respectively State Enterprise Radioactive Waste (SERAW) and Jadrová a vyraďovacia spoločnosť (JAVYS). In Lithuania, the Ignalina Nuclear Power Plant (INPP) organisation has been maintained but with a new mission. The three decommissioning operators are the owners of the nuclear licenses and they implement the decommissioning programme under the supervision of the Programme Coordinator and of the Implementing Bodies. For each programme, a Monitoring Committee ensures a coordinated monitoring of all measures and financial assistance under the decommissioning programme. It is chaired by the Programme Coordinator and a representative of the Commission. The other members are the Financial Coordinator and representatives of the Implementing Bodies. Each of the three Member States concerned submits to the Commission an annual work programme which updates the implementation schedule of the detailed decommissioning plans, taking into account the latest developments in the implementation of the projects. The annual work programmes must however remain within the objectives and scope of the decommissioning plans as initially adopted by the Commission. The Commission reports annual progress on the NDAP to the Council, the European Parliament and the general public. This annual reporting concludes the annual planning and monitoring cycle for that year and constitutes the basis for the adoption of the following year’s annual work programmes.

2.3Baseline and points of comparison The 2011 IA framed the Commission initiative in these terms: 'to eliminate as far as possible the source of radiological hazard, the closed reactor units must remain closed, be defueled and safely dismantled. In the context of ‘early closure’ and considering the related economic consequences for the three concerned Member States this closure must become irreversible. At present this stage is not yet reached'. By the end of the previous financing period, JAVYS, the decommissioning operator in Slovakia, had obtained its first decommissioning license for Bohunice V1. In Bulgaria, the Kozloduy units 1 and 2 were defueled and transferred from the plant operator to the decommissioning division of SERAW. In Lithuania, the defueling operations of the reactor of unit 2 in Ignalina were on hold while the construction of the Spent Fuel Safe Storage Facility had to be completed. In all three concerned Member State, the political movements demanding the restart of the reactors were losing influence. The Commission's initial proposal for a single NDAP Regulation foresaw an extension of financial support from the Union with the general objective to reach an irreversible state within the decommissioning process of Kozloduy units 1 to 4, Ignalina units 1 and 2 and Bohunice V1 units 1 and 2, in accordance with their respective decommissioning plans, while keeping the highest level of safety. During the legislative process of adopting the NDAP Regulation, the there was a broad consensus in the Council in recognising the need for continued financing of decommissioning of the nuclear reactor units. Accordingly the Legislator intervened on the initial Commission proposal, in particular by increasing the budget for all three Member States and the duration of the assistance for LT and SK. The baseline is defined by the detailed decommissioning plans submitted by each concerned Member State in 2014 and adopted by the Commission as annexes to the detailed implementation procedures. The programmes overall cost estimates were thereby included and updated with respect to previous issues; in one case the estimates were revised slightly downwards (-1% for the Kozloduy programme), whereas in the other two cases the estimates increased (+40% and +24% for the Ignalina programme and the Bohunice programme respectively). The increase of the Ignalina programme cost estimate came along with a nine-year extension of its overall duration. The Commission assessed that the detailed decommissioning plans were complete, relevant, comprehensive, and the overall cost estimations were generally appropriate, as further supported by an independent review. Thus both the limits of the scope of EU support and the baseline costs to monitor cost-effectiveness have been clearly drawn. The work breakdown structure and the schedule form the base for assessing the timeliness of the implementation. 3Implementation / state of Play The decommissioning operators are all fully working on decommissioning activities. Slovakia has advanced the most and is currently carrying out Dismantling & Decontamination (D&D) in the reactor building at the Bohunice site. D&D is well advanced in the auxiliary buildings at the Kozloduy and Ignalina sites. In addition, the key safety-related project in Lithuania to remove the spent nuclear fuel from the RBMK reactor (similar to that used in Chernobyl) is now well underway. Defueling of Unit 2 reactor core was finalised on 25 February 2018 (i.e. 15 months ahead of schedule). The programmes are generally on track to achieve the specific objectives of the Regulations with the funding provided in this MFF. A clear trend towards increased efficiency has been observed throughout the monitoring activities, as confirmed by independent experts. In some areas, the risk of delays needs further mitigation and close follow-up. At Kozloduy and Bohunice, the removal of spent fuel from the reactors and adjacent reactor pools and its transfer to an external dedicated interim storage facility (i.e. defueling) was completed during the 2007 – 2013 period. Defueling is currently underway in Lithuania at Ignalina. In February 2018, the second reactor has been completely defueled and the transfer of the remaining spent fuel from the ponds in the reactor building to the new safe storage facility is expected to be completed by July 2022. Important waste management infrastructure projects have recently been commissioned or are being commissioned at Kozloduy and Ignalina. Most of the other final key waste management infrastructure projects are approved and under procurement or implementation. This infrastructure is critical to the functioning of the ‘waste management systems’ set up for each programme and has been the object of much of the investment in the early years of the programmes. Slovakia already possessed much of the requisite infrastructure prior to decommissioning and the development of its waste management system is highly mature. Actual physical dismantling of equipment is progressing quickly at all three sites compared to the first decade of programme implementation. This reflects the nature of nuclear decommissioning programmes, which requires significant upfront investment in planning and waste management infrastructure development as explained above. Dismantling & Decontamination (D&D) work in the Turbine Halls and Auxiliary buildings outside the Controlled Area has advanced substantially and is expected to be largely completed by 2020 at Kozloduy and Ignalina and significantly sooner at Bohunice. Except for Bohunice, limited D&D work has been undertaken in the reactor buildings to date, reflecting the varying timelines of programmes. The Kozloduy & Ignalina programmes are currently preparing the technical design for the dismantling of the reactor cores / primary circuit, which will begin in the coming years. The Bohunice programme is advancing well in D&D of the primary circuit, with key projects well underway. 4Method 4.1Previous evaluations and other reports The latest Commission's evaluation report dates back to 2011. In the same period the European Court of Auditors realised a performance audit. Their recommendations were taken up in the 2014-2020 NDAP legal bases. The European Court of Auditors has conducted a follow-up audit of the NDAP in 2015. The conclusions of the Special Report issued on 20 September 2016 have been taken into account in the design of this evaluation. A complete list of reports analysing the situation of the NDAP can be found in Annex 1. 4.2Evidence from monitoring The programme benefits from an intense monitoring process leveraging the strong managerial competences of the main stakeholders (Implementing Bodies, programme coordinators and decommissioning operators). The main stakeholders report to the Commission the progress of the technical and financial implementation in detail every six-month in a comprehensive quantitative monitoring report. It presents a comprehensive overview of the implementation including a comparison of the actual performance relative to the baseline schedule and progress made in achieving the objectives of the programme. Monitoring reports are reviewed and approved by the respective Monitoring Committees.

Based on the internal assessment of the results of periodic monitoring actions and the documentation provided by stakeholders the Commission drafts an annual report. Three such reports from the Commission to the European Parliament and the Council on the implementation of the work under the nuclear decommissioning assistance programme to Bulgaria, Lithuania and Slovakia have been issued so far: in 2015, in 2016 and 2017. Besides the scheduled monitoring activities, the Commission commissioned an external study, which included an evaluation of the programmes’ global cost estimations, an overall risk assessment, an analysis of the national funds and other sources, and an analysis of the robustness of the state budgets. In addition in 2017, an auditor verified the conditions under which procurement procedures have been carried out by the Implementing Bodies under the NDAP. 4.3Specific evaluation actions In 2016, the Commission started the preparation for the mid-term evaluation by publishing the evaluation roadmap and by procuring in 2017 an external study to complement the existing body of evidence. The contractor's report addresses directly the evaluation questions and is based on in depth desk research, interviews with targeted stakeholders, field visits, analysis of the general public consultation and a targeted consultation, a benchmarking exercise with comparable instruments, and an expert panel. Annex 3 provides a detailed description of the contractor's activities. The Open Public Consultation has been accessible for an extended period of 14 weeks from 23 June to 29 September 2017 and has elicited 20 contributions from the public. The main stakeholders of the programme have been directly involved in the evaluation with regular reporting of the progress to the three Monitoring Committees and the Nuclear Decommissioning Assistance Committee. 4.4Limitations and robustness of findings Stakeholders with a deep knowledge of the programme are limited in number and generally directly involved in the programme in some way – e.g. Implementing Bodies, decommissioning operators and Programme Coordinators. This is due primarily to the technical nature of the programme and the limited circulation of detailed information outside this circle. This also likely contributed to the limited response received to the Open Public Consultation launched by the Commission or the targeted e-survey consultations launched by the evaluation contractor to external actors on the national level. Indeed, a number of stakeholders contacted for the targeted consultation responded that they did not feel adequately informed to respond to the survey. The assessment of the efficiency of the assistance programme was rendered more difficult by a lack of relevant cost data from comparable decommissioning projects. Indeed, there are real barriers to sharing cost data publicly. At the moment, numerous cost estimates are available for decommissioning projects worldwide but few actual cost reports for completed projects have been made public. Some challenges were faced in the analysis of efficiency internally within each programme and through comparison between programmes due to varying approaches for project / financial management. Each decommissioning operator has developed different work breakdown structures, cost structures and modalities for monitoring expenditure and results that are not entirely comparable between programmes, nor do they always align neatly internally within programmes. This presented challenges in analysis, in particular of efficiency, and limits comparison between programmes or with other decommissioning programmes. While it did not significantly impact the validity of findings, it limited the extent to which quantitative data from different sources could be fully integrated within and compared across programmes. The introduction of the Earned Value Management (EVM) System in the three programmes from 2014 delivered valuable results. A full implementation of the system requires modifications in the procedures and organisations involved, from the decommissioning operators to their contractors and sub-contractors. While considerable progress has been noted, the progressive adoption of the methods and tools provided by the EVM System is still relatively recent; therefore the evaluation met some limitations in measuring actions and contracts started before the EVM System introduction. The initial analysis of the intervention logic clarified that the possible social and economic impacts of the intervention, while considered explicitly in the 2011 IA, had not been associated to any objectives in the 2013 NDAP Regulations adopted by the legislator. These impacts have eventually been analysed in less detail than planned in the evaluation roadmap. 5Analysis and answers to the evaluation questions The evaluation was conducted against the five main criteria set up by the Better Regulation guidelines and toolbox: relevance, coherence, effectiveness, efficiency and EU added value. The eight evaluation questions covering the five evaluation criteria are summarised in Annex 4. Unless otherwise specified, the answers and analysis refer to the period 2014-2017 and are based on the study prepared in support of this evaluation. 5.1Relevance 5.1.1Evaluation Question 1

To what extent are the general and specific objectives of the NDAP still appropriate in relation to the existing needs? 5.1.1.1The programme objectives at general and specific levels remain relevant The general objective to assist Member States in implementing the steady process towards the decommissioning end state of the reactors in question in accordance with their respective decommissioning plans, whilst maintaining the highest level of safety and the specific objectives (see Table 3: Specific objectives of NDAP ) set out for the programmes in Bulgaria, Lithuania and Slovakia in the 2013 NDAP Regulations remain relevant. Indeed, the underlying need to safely remove or reduce radiological hazards through decommissioning remains as long as all highly radioactive materials have not been treated; as well as the need for continued assistance to provide funds at the right time ensuring the uninterrupted decommissioning of the nuclear power plants in question. Continued progress in the decommissioning at the three plants would likely have been impacted in the absence of EU support. The NDAP thus continues to support a stepwise reduction in the level of risk and radiological hazard at the three sites concerned, in particular at Ignalina where defueling operations are ongoing. Current decommissioning strategies for the three NDAP programmes remain aligned with the specific objectives set out for each programme. 5.2Coherence

5.2.1Evaluation Question 2

Is the NDAP coherent with the Euratom Treaty’s acquis in the area of nuclear safety and responsible management of spent fuel and radioactive waste?

and with the EU acquis in other relevant areas? The assessment focused primarily on the extent to which the 2013 NDAP Regulations are themselves coherent with EURATOM / EU acquis. 5.2.1.1The NDAP is coherent with the Euratom Treaty’s acquis in the area of nuclear safety and constitutes an exception to the financial responsibilities for the management of spent nuclear fuel and radioactive waste Coherence with the Euratom Treaty’s acquis in the area of nuclear safety and management of spent nuclear fuel and radioactive waste has been embedded in the legal base of the NDAP. The preamble of the 2013 NDAP Regulations states that the decommissioning of the nuclear power plant covered by this Regulation should be carried out in accordance with the legislation on nuclear safety, namely Council Directive 2009/71/Euratom, [and] waste management, namely Council Directive 2011/70/Euratom. The decommissioning activities have also been implemented in coherence with radiation protection law, covering basic safety and emergency preparedness and response. Reporting issued by Regulators between 2014 and 2016 has not signalled any exceeding of dose limits for staff and contractors working on site. Radiological activity surrounding sites is monitored in all countries and has shown no abnormal levels of radiological release to the surrounding environment. More generally, Regulators’ reports and company policies of decommissioning operators indicate that requirements on the health and safety of workers are fully respected. While the legal base ensures coherence, the NDAP itself constitutes an exception to some underlying principles enshrined in the Euratom acquis. On the one hand, the support provided by the NDAP has played an important role in accelerating decommissioning efforts in a safe manner and avoiding the passing on of an undue burden to future generations, a fundamental principle in international and EU law. However, the NDAP derogates to the principle, sanctioned by the Council Directive 2011/70/Euratom, that the costs for the management of spent fuel and radioactive waste is borne by those who generated those materials. The exceptional nature of this programme is due to the specific historical context recognised by the Accession Treaties. The Council adopted Directive 2011/70/Euratom on the safe and responsible management of spent fuel and radioactive waste management. Within this framework, complementary efforts are undertaken by the Commission to encourage and support all Member States in the development of solutions for long term management of spent fuel and high level radioactive waste in line with legal obligations, as communicated in its 2017 report. These actions are highly complementary to the NDAP in that they provide support to the three Member States for aspects of decommissioning not covered by the NDAP (e.g. the final disposal of spent nuclear fuel). 5.2.1.2The NDAP has also ensured coherence with other relevant EU acquis, in areas such as environmental and social protections The implementation of the NDAP has been coherent with the principles and obligations of the Environmental Impact Assessment Directive. Environmental Impact Assessments have been conducted across all programmes for both decommissioning programmes and /or individual projects in compliance with national law. The NDAP has also been implemented in compliance with relevant social protections in EU law. The decommissioning process has entailed a process of organisational transformation, creating in some cases collective redundancies. These cases have been managed in compliance with relevant EU legislation, such as the Collective Redundancies Directive concerning the situation of workers affected by decisions of employers to lay off a group of employees or the Transfer of Undertakings Directive protecting employees' rights in the event that an undertaking is transferred from one employer to another. While the NDAP was coherent with the relevant social acquis, stronger linkages could have been assured with some EU instruments, namely the European Structural and Investment Funds (ESIF). National authorities remained solely responsible for designing strategies to mitigate the socio-economic impact of plant closure. However, in none of the three Member States did the relevant authorities adopt formal strategies as is recognised as best practice. 5.3Effectiveness 5.3.1Evaluation Question 3

To what extent have the objectives of the NDAP been achieved for each of the three programmes? The aim of this question was to measure the extent to which the NDAP’s objectives, general, specific and detailed, have been achieved to date and are on track to be achieved. In the evaluation framework, this question has been addressed through five sub-questions assessing overall progress achieved and risks of non-achievement (EQ3.1), the factors influencing positively and negatively progress (EQ3.2), the extent to which the level of risk at each site has been improved (EQ3.3), the adequacy of the monitoring & control systems (EQ3.4) and the effectiveness of communications actions (EQ3.5). 5.3.2Evaluation Question 3.1

Overall, what level of progress has been made towards the objectives of each national programme? Is the progress in line with the decommissioning baseline adopted by the Commission? If not, what is the risk that objectives will not be achieved? 5.3.2.1Programmes overall are making reasonable progress towards objectives, but continued proactive efforts will be necessary Major achievements have been reached in the Ignalina and Kozloduy programmes with regards to key waste management infrastructure projects that had been hampered by serious setbacks in the past financial framework. In Lithuania, the commissioning of the Intermediate Spent Fuel Storage Facility puts the programme on track to complete the critical task of defueling. In Bulgaria, the on-going commissioning of the Plasma Melting Facility and the Size Reduction & Decontamination Workshop open the way to ramping up D&D activities and clearing out waste backlog. Programmes can generally be considered to be on track towards achieving the objectives set for this programming period – with some delays to recover. In particular, the Bohunice programme has worked proactively to optimise programme implementation in the final years in light of some technical challenges previously faced. The Kozloduy programme will also need to define a path for recovering delays, partly due to issues faced in the previous MFF, which have impacted the pace of advancement in the Controlled Area. The generally satisfactory progress, as well as the room for improvement, is reflected in the key performance indicators, including the physical progress indicators (presented in the following subsections) and the Schedule Performance Indicators. The critical path analysis shows that it remains possible to achieve the NDAP objectives and to complete the decommissioning programmes within the planned time. However, the Schedule Performance Indicators show that the programmes are accumulating delays in projects which are not on the critical path. Figure 3 shows how the Earned Value (green line), a global indicator of progress across the whole of activities making up each programme, is lagging slightly behind the Planned Value (blue line) as determined in 2014 by the decommissioning plan. The dashed blue line represents the mitigating actions for the implementation of the Bohunice programme (see section 0) confirming the programme end date by 2025. See Annex 5 for a short introduction to the main EVM indicators and to the principles of critical path analysis.

Source: Monitoring reports 2017-H2 At present, there is not an immediate risk that the status of on-going waste management infrastructure projects – e.g. the Near Surface Repository and Landfill Facility at Ignalina and the Near Surface Repository at Kozloduy – will impact wider decommissioning efforts, because temporary storage facilities are sufficient. These particular projects should continue to be monitored carefully. In addition, the capacity in treating waste streams appears adequate at this point in time, but it shall be monitored against D&D objectives. 5.3.2.2Progress against waste management targets has been slow to date, although programmes should be able to recover delays The physical performance indicators demonstrate lower than expected progress to date across all three programmes. This underperformance has mainly been the result of uncertainties concerning radiological inventory and / or lack of anticipation of regulatory procedures leading to under or overestimations of target values, slower than planned progress with D&D activities, technical challenges related to specific legacy waste streams and some delays in the commissioning of waste management facilities. These delays remain largely recoverable at present (during the current MFF). 5.3.2.3D&D works in the turbine halls and auxiliary buildings come to an end in Slovakia and are progressing well in Lithuania & Bulgaria At Bohunice, this stage of decommissioning is currently winding down with the final projects approaching completion. At Kozloduy and Ignalina, D&D work is advancing well or even ahead of schedule in the turbine halls and other auxiliary buildings. Monitoring reports show that decommissioning operators have successfully managed to identify and address inefficiencies and remove bottlenecks as they have been identified. This represents the culmination of significant efforts on the part of decommissioning operators, in particular in Lithuania by virtue of the relatively large volume of equipment to be dismantled and the fact that the equipment in the Ignalina Turbine Hall is subject to a higher degree of contamination and thus requires relatively greater effort. 5.3.2.4The Bohunice programme has embarked on major physical works in the Controlled Area, whereas the Ignalina and Kozloduy programmes remain in the preparatory phase Since the beginning of the current MFF, significant D&D work has begun in the Controlled Area in Bohunice. Some early technical challenges have been met, but the decommissioning operator has sorted them out and set out an optimised implementation strategy to avoid impact on time and minimise impacts costs. This activity will form the largest part of works during the remainder of the current MFF and drives the critical path of the overall programme in its final stages. Minor works have been conducted to date in the Reactor Buildings and other auxiliary buildings in the Controlled Area at Kozloduy and Ignalina. Both programmes remain at different stages of the preparatory phase for D&D work in this area. At Kozloduy, an important study is underway to develop the technical approach for D&D of large components in the Controlled Area. During the current MFF, early physical works have not advanced entirely as foreseen in the baseline schedule due to late delivery of the Decommissioning Licenses linked to difficulties in the previous MFF with regards to the approval of the Environmental Impact Assessment. At Ignalina, the technical design work is at a relatively earlier stage. While this work has made significant progress, some difficulties have been encountered with a potential impact on the start of large-scale physical works (in any case scheduled beyond the current MFF). In this area the Ignalina programme faces technical challenges associated with its first-in-kind nature, whereas the Kozloduy programme can draw on lessons learnt from Bohunice and Greifswald NPP in Germany. The following sub-sections provide a more detailed assessment of progress achieved for each programme, as well as the main risks identified. 5.3.2.5Bulgaria The three specific objectives for the Kozloduy Programme are: -Performing dismantling in the turbine halls of units 1 to 4 and in auxiliary buildings; -Dismantling of 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. D&D activities are progressing well outside of the Controlled Area, in particular in the Turbine Hall (Specific Objective 1) The first dismantling work of non-nuclear equipment was initiated in 2010, but dismantling only commenced at full pace at the beginning of the current MFF due to late transfer of Units 3 & 4 to SERAW management during the previous MFF. One of the key objectives of the current programming period is to finalise dismantling of the Turbine Hall for Units 1 – 4 (and other auxiliary buildings). This includes the dismantling of approximately 40 400 tonnes of metal from 160 main and auxiliary systems. SERAW is currently on track to accomplish this objective by August 2019, despite facing some early issues. By the end of 2016, 21 628 tonnes of metal had been dismantled from the equipment of the Turbine Hall. This represents 96% of the planned target to date as per the Annual Work Programmes. In addition, 7 744 tonnes of civil structure have been demolished in the turbine hall by the end of 2016 – 122% of planned progress to date. Progress has been slower than expected thus far in the Controlled Area (Specific Objective 2) Initial physical dismantling work in the Controlled Area has been undertaken in serviced and semi-serviced areas since 2014. By the end of 2016, 299 tonnes of material in the Controlled Area had been dismantled – 75% of planned target to date as per the Annual Work Programmes. In order to avoid a build-up of dismantled material in the Controlled Area awaiting subsequent decontamination, the pace of dismantling was decreased in 2016 until commissioning of the SRDW planned for 2017 in the 2017 Annual Work Programme. The delay in the commissioning of the SRDW was due to mainly to procurement delays stemming largely from the previous MFF. Recovery measures are planned to be taken to increase capacity through work in shifts once the SRDW is operational. More significant D&D works in the Controlled Area started in 2016, approximately two years later than planned. This is largely due to delays in the delivery of the Decommissioning Licenses that stem from the previous MFF.

Source: Monitoring reports 2017-H1 Figure 4 shows the physical progress of the dismantling activities. It illustrates the ratio between the actual quantity of dismantled materials (dark blue) to the total quantity to be dismantled (light blue) and put it in relation to the scheduled duration of those activities. Waste management infrastructure projects are on a positive trajectory, with key infrastructure expected to be commissioned in 2018 (Specific Objective 3) The construction of the National Disposal Facility will allow for disposal of low and intermediate level short lived radioactive waste. The absence of a disposal path for the waste produced would eventually block decommissioning activities. The transboundary Environmental Impact Assessment started in the previous MFF resulted in significant delays. It affected the approval of the technical design and issuance construction permits. SERAW took mitigation measures to minimise the impact of delays by restructuring the project scope. In an important milestone, the Regulator approved the National Disposal Facility technical design in March 2017 and the construction permit was issued shortly thereafter. The Plasma Melting Facility relies on an innovative technology to significantly reduce the volume of radioactive waste to be disposed of. This allows reducing by the same factor the disposal costs. In the past MFF, this project suffered from a number of difficulties and delays, which have been eventually resolved during this MFF. The commissioning of the facility is on-going. Progress in those two key projects and other projects like the construction of the Size Reduction & Decontamination Workshop is critical for removing bottlenecks, in particular for processing contaminated materials arising from the decommissioning operations, and to expand the capacity of SERAW to match future expected waste flows from decommissioning. Performance of radioactive waste management activities has also been impacted by wider delays in the decommissioning process. Technical issues faced with the removal of legacy waste from Auxiliary Buildings, for example, has impacted waste management activities. Similarly, delays in work in the Controlled Area can explain the low level of progress achieved to date. Performance gaps can also be noted with free release of materials. While the level of progress achieved against the detailed objectives in the detailed implementation procedures has been low to date, the programme has consistently performed in a satisfactory manner against annual targets set in the Annual Work Programme, suggesting that the waste management system is capable of performing when progress with dismantling allows.

5.3.2.6Slovakia The three specific objectives for the Bohunice programme are: -Performing dismantling in the turbine hall and auxiliary buildings of reactor V1, to be measured by the number and type of systems dismantled; -Dismantling of large components and equipment in the V1 reactor buildings, to be measured by the number and type of systems and equipment dismantled; -Safely managing the decommissioning waste in accordance with a detailed waste management plan, to be measured by the quantity and type of safely conditioned waste. The dismantling of the Turbine Hall is completed and the last auxiliary structures (cooling towers) are under demolition (Specific Objective 1) By 2016, the dismantling of non-active systems had been almost achieved: the Diesel Group and Electric Power Supply Systems, the Technical Equipment in the Turbine Hall and the external buildings. The last project remaining under implementation is the dismantling and demolition of the V1 NPP four cooling towers. The project is planned to be completed in 2018. Work in the Reactor Buildings has started, initially with some technical difficulties, and preparatory work on the dismantling of large components is expected to start by the end of 2017 (Specific Objective 2) JAVYS received the license for the stage 2 of decommissioning (Controlled Area) in December 2014 which gives the green light to begin the dismantling process in the Reactor Building. One project has already been completed: the dismantling of insulation in Controlled Area with the dismantling of the technological equipment and piping systems. Difficulties with the implementation of the decontamination of the primary circuit have delayed subsequent projects. The decontamination of the primary circuits is a pre-condition for the dismantling of the primary circuits of Bohunice V1 NPP. After several months of implementation, including the establishment of the decontamination circuit technology on the reactor vessel, the original contractor faced severe technical difficulties and was unable to finalise the project. The contract was terminated in 2016 in what constituted an important set-back. JAVYS however developed a full revision of the project and the technology implemented by the original contractor to learn from this experience and gain know-how. The decision was taken to select a new contractor through direct tendering and the decontamination process restarted in 2017. The project has now been successfully completed.

Most of the subsequent dismantling projects are on the programme critical path and depend on successful completion of the decontamination. In consequence, the dismantling of the reactor coolant system large components has been rescheduled for completion in 2022 (compared with 2020 in the baseline schedule). In order to optimise the final steps of the programme and ensure the completion of the activities by 2025 despite the delays incurred, JAVYS has reorganised the scope of some projects to allow their simultaneous implementation and developed a new strategy for the implementation of the three final projects concerning the Reactor and Auxiliary Building decontamination, building decommissioning, backfilling and site restoration so that they are implemented under one contract. These changes should allow to recover the incurred delay at the expense of an increased complexity in projects interfaces and tendering process. Source: Monitoring reports 2017-H1 Figure 5 shows the physical progress of the dismantling activities. It illustrates the ratio between the actual quantity of dismantled materials (dark blue) to the total quantity to be dismantled (light blue) and put it in relation to the scheduled duration of those activities. Most legacy waste and waste produced by the decommissioning of non-Controlled Areas have been safely stored and the last storage facilities are under construction (Specific Objective 3) The Bohunice programme has benefited from the availability of existing waste management infrastructure for several contextual reasons (operation of several other reactors on site, shutdown and decommissioning of the A1 reactor prior to the V1 reactors). The last two waste management projects are about to be brought to operation. The Interim Radioactive Waste Storage facility was opened in August 2017 and additional radioactive waste disposal capacity at the Mochovce disposal site will be available in 2018. The quantities of processed waste reported in the Monitoring Reports are significantly lower than the overall targets. This is however not a signal of underperformance in waste processing. It is rather mainly due to the time shift of projects concerning the primary circuit dismantling and demolition of V1 NPP cooling towers resulting in a less waste being produced up to 2017. 5.3.2.7Lithuania The three specific objectives for the Ignalina Programme are: -Defueling of 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; and -Performing dismantling in the turbine hall and other auxiliary buildings and safely managing the decommissioning waste in accordance with a detailed waste management plan.. Defueling operations are proceeding well following the commissioning of key waste management infrastructure (Specific Objective 1) With the start of operation of the Interim Spent Fuel Storage Facility in October 2016 a major milestone has been met allowing for the critical process of defueling to start. In addition, defueling of Unit 2 reactor core has been completed on 25 February 2018, 15 months ahead of schedule. The Interim Spent Fuel Storage Facility project had accumulated significant delays in previous programming periods due to a variety of factors that eventually led to a suspension of disbursements in January 2013. These delays had a direct impact and contributed significantly to the extension of the overall duration of the decommissioning programme in the latest version of the detailed decommissioning plan. In 2013, a new management of INPP started working quickly to resolve outstanding issues with the contractor. Significantly, pending commercial issues were resolved in November 2015 with no increase in the contract price. Source: Monitoring reports 2017-H2 Figure 6 shows the progress of the transfer of the spent fuel from the reactor core to the fuel ponds in the reactor building and finally to the dry storage in the Interim Spent Fuel Storage Facility, the end stage in the scope of the NDAP. Since 2011, as the pre-existing dry storage facility was fully occupied, 1134 spent fuel assemblies remained in the reactor of unit 2 and the spent fuel ponds were fully filled with 14421 assemblies.

INPP has ensured continued safe maintenance of Units 1 & 2, as well as the safety of decommissioning activities (Specific Objective 2) The continuing presence of nuclear fuel in the reactor and spent fuel ponds requires the maintenance of a high level of safety including: i) sub-criticality of spent nuclear fuel; ii) heat removal from the reactor’s core and spent nuclear fuel pools; and iii) confinement of radionuclides, installation of barriers suppressing ionising radiation and control over release of radionuclides. Since 2014, INPP staff has ensured safe maintenance of Units 1 & 2 without any incident as classified by the INES scale. The national nuclear safety authority, VATESI, carries out regular inspections and technical checks at INPP predominantly focused on safety requirements during maintenance, fire safety and ageing management of structures, systems and components important to safety. VATESI also monitors INPP's safety culture through a safety culture index evaluating the less obvious factors that could have an impact on safety. The indicator has been maintained at an acceptable level during the period under evaluation. D&D activities are progressing well in the Turbine Hall and auxiliary buildings (Specific Objective 3) Dismantling activities are currently ahead of schedule in terms of overall number of tonnes of equipment dismantled in the Turbine Hall. By the end of the first semester of 2017, 26 862 tonnes of equipment had been dismantled in INPP – 107% of the planned total to date as per the Annual Work Programmes and 66% of the 2020 target. Equipment dismantled from the Turbine Hall made up the large majority of this tonnage – approximately 85%. Work in the Turbine Hall is currently expected to be completed by June 2019 in line with the baseline schedule. Decontamination activities are progressing well, with 2 901 tonnes dismantled and decontaminated from 2014 to the end of 2016. Fragmentation and decontamination facilities in the Turbine Hall entered routine operation in 2014. Due to the higher-than-expected progress in dismantling, some challenges were initially faced with the quantity of wastes generated. In 2015, INPP formulated a plan for the more efficient use of space within the Turbine Hall as buffer storage in order to more effectively decouple dismantling/fragmentation activities from the decontamination line. In addition, the decontamination capacity is being expanded to ensure higher decontamination throughput in coming years. Source: Monitoring reports 2017-H2 As shown on Figure 7 , the total amount of material is equivalent to 16 times the weight of the Eiffel tower. At present, over 25% has been dismantled and a large part of that material could be decontaminated to a level that allowed its recycling outside of the nuclear industry (free release). Important achievements in key waste management infrastructure, but other key infrastructure projects underway should be monitored closely (Specific Objective 3) The Ignalina programme achieved important milestones with the on-going commissioning of the Solid Waste Management and Storage Facility (SWMSF). This progress represents an important achievement for the Ignalina programme having in mind the criticality of this infrastructure for the decommissioning process and the level of difficulties that had been faced in previous programming periods with these large projects. A number of other key infrastructure projects remain in early stages of implementation and have faced difficulties resulting in delays in their preparation. The award of the contract for the landfill facility for short-lived very low level waste was delayed in the tendering process for several months. The schedule for the Near Surface Repository (NSR) for low & intermediate level short-lived waste has slipped due to delays incurred during the design phase during previous programming periods and a protracted approval process under the current MFF. Finally, progress on the bituminised waste storage facility remains dependent on a number of unknown variables due to close proximity with other facilities and upgrade works. While slippage in project schedules can be noted, delays do not risk creating significant bottlenecks in waste streams in the medium-term at the time of the evaluation. Challenges faced during the preparatory design activities for D&D in the Reactor Building will not significantly impact programme performance during the current MFF, but create the risk of delays after 2020 Although not an objective included in this programming period, the start of physical D&D activities in the Reactor Buildings may be delayed due to challenges faced in the preparation of design work The Ignalina programme initially called on external expertise for the development of the technical design and safety documentation for a number of pilot D&D projects. However in 2011 INPP has made the decision to conduct much of the preparatory technical design work for D&D in house. Since, the programme has largely used internal resources to leverage expertise of former plant staff and reduce the cost of this activity. Delays in preparatory design activities for D&D in the Reactor Buildings have resulted from technical challenges and inadequate internal expertise. As a result, the programme is currently behind the projected schedule for those activities. However, these delays should be largely recovered during the current MFF once works begin given current project timelines. Preparatory work for D&D in the reactor shaft has lagged behind due to a lack of qualified personnel and overall rethinking of the general approach. INPP has also come to the conclusion that preparatory work for the dismantling of the irradiated graphite from the core cannot be completed relying only on in-house resources. Technical Specifications for the procurement of technical support to complete this work is currently underway over seven years after the procurement for the original project was cancelled. These challenges should have limited impact on the achievement of objectives for the current MFF, but may lead to a delayed start of large-scale physical works in the post-2020 period. 5.3.3Evaluation Question 3.2

What external and internal factors influenced (positively and negatively) the progress of the decommissioning programmes?

5.3.3.1The (on-going) commissioning of key waste management infrastructure projects is supporting a ramping up in decommissioning activities The construction of waste management infrastructure is often not thought of as being part of the decommissioning process itself. However, this infrastructure is a necessary pre-condition for decommissioning to begin. As such, it is included in the detailed decommissioning plan where existing infrastructure is not adequate or available. The three Member States had varying level of pre-existing infrastructure in place. Slovakia, where decommissioning of Bohunice A1 had begun before Bohunice V1 decommissioning started, had a well-developed infrastructure already in place, whereas Bulgaria had some existing waste treatment and disposal facilities, and, for historical reasons, Lithuania had almost none of the required infrastructure on its territory. For this reason, the three programmes started in radically different conditions, with new infrastructure requiring years for design, construction and commissioning. Adding to this, major infrastructure projects in Bulgaria and in particular Lithuania were delayed for years in past programming periods. Notably the lack of Interim Spent Fuel Storage Facilities contributed to slowing down the overall decommissioning process at Ignalina. Consequently, the start of operations of key waste management infrastructure in these two countries since 2014 has had and will have a significant positive impact on the pace of decommissioning work. 5.3.3.2Recent years have seen an acceleration of organisational transformation, providing a strong support framework for decommissioning programmes The transition from operation to shut-down and finally decommissioning requires that the necessary organisational support systems be put in place to manage these complex processes. This transition, as with all organisational transitions requires time, clear objectives and the deployment of effective change management efforts. Previous audits and assessments have underlined the importance of organisational issues in effectively supporting the decommissioning programmes and found that organisational changes in some cases had been too slow. This is issue is over at this point in time. The transition process at Kozloduy has been successfully completed with the handover of ownership of Units 1 – 4 from the power plant operator (KNPP) to the decommissioning operator (SERAW) in 2013. The hand-over of responsibility, including the transfer of project ownership and some plant personnel, was a complex and time-consuming process that diverted energies away from the overall programme management duties. At Ignalina, a new leadership team was put in place at INPP in 2013 bringing positive changes. In addition to quickly addressing commercial disputes that affected the construction of the Interim Spent Fuel Storage Facility, the new management team has embarked upon a number of important organisational reforms. A Project Management Department was re-established in 2014 in order to concentrate decommissioning project management functions and improve planning, execution and control of activities. At Bohunice, the share of internalised expertise had strongly increased over years. Indeed, the support by external consultant was progressively reduced; having successfully transferred mainly the project management know-how. This was reinforced by experience gained from the decommissioning of the Bohunice A1 reactor also implemented by JAVYS but without EU support. 5.3.3.3International experience in the decommissioning process remains low, in particular for the final stages of decommissioning As underlined in the Nuclear Illustrative Programme of the European Commission, only three of more than 90 shut-down reactors in the European Union are completely decommissioned. Hence decommissioning is not considered a fully mature industry. If decommissioning has been proven to be entirely feasible, R&D efforts are continually leading to improvements in methods and technologies and hold significant potential to reduce the cost and uncertainty. Yet, many of these technologies are starting to be implemented on an industrial scale. In this context, the possibility of unexpected technical difficulties or project failure remains an inherent part of the decommissioning process. As programmes progress towards the critical step of dismantling in and around the reactors, the technical challenges become more complex. The experiences in the Bohunice programme, as well as experiences at similar facilities such as Greifswald, have illustrated that decommissioning operators must be prepared to rethink or reorganise their approach when confronted with unexpected challenges. In the Kozloduy and the Ignalina programmes the design for this stage of decommissioning is being formulated, thus important open questions remain. While the Kozloduy programme can rely on existing experience (in particular Bohunice), in the case of Ignalina these challenges are further compounded by the first-in-kind nature of this undertaking: no reactor of the RBMK design has yet been dismantled and open questions remain amongst international experts concerning processing solutions for irradiated graphite. 5.3.3.4Administrative issues have also impacted programme effectiveness The effectiveness of programme implementation has also been impacted by risks in the administrative realm that could have been completely or at least partially avoided. For example in Bulgaria, the delay in ratification of the Nuclear Indemnity Agreement for the Plasma Melting Facility created a significant risk for the project. More generally the decommissioning operators have also had difficulties correctly anticipating some regulatory issues. These challenges reflect in part the limited experience with the regulatory and administrative aspects of decommissioning at the national level. This has entailed a strong learning curve for decommissioning operators and national authorities. This capacity building aspect constitutes an asset especially for Slovakia and Bulgaria which will be faced in the future with other decommissioning projects. 5.3.4Evaluation Question 3.3

To what extent has the level of risk at each nuclear site been improved thanks to the NDAP support? 5.3.4.1Since reactors final shutdown, the level of risk for the general public at each site has been reduced in a stepwise manner. The radiological hazard has been reduced notably with the defueling of reactors and the decontamination, dismantling and disposal of contaminated and irradiated equipment and materials. The choice of an immediate dismantling strategy, made possible by the EU financial support, implies that the radiological hazard are being reduced without undue delay, along with the risks related to aging facilities after shut-down and loss of expertise at the facility. More than 99% of the overall level of radioactivity in nuclear reactors is associated with the spent nuclear fuel; removal of the spent fuel from the reactor buildings and storage into an interim storage facility drastically reduces the potential impact of radiological hazards. Under the previous programming period, the NDAP supported the construction of interim spent fuel storage facilities in Kozloduy and Ignalina (operational since 2016) utilising the best available technology on the market to ensure long-term safe storage until final disposal. The NDAP supported the defueling activity in Kozloduy and Bohunice which resulted in a significant risk reduction. The remaining radiological hazard concerns primarily workers inside the nuclear facility. In comparison, a higher level of risk remains at Ignalina until the completion of defueling activities planned for 2022. Current defueling work, financed by the NDAP, will bring the overall risk levels for Ignalina in line with those that can be observed presently in Bulgaria and Slovakia.

5.3.4.2Monitoring of safety-related issues at EU level can be strengthened to better reflect the overall purpose of the programme The driving factor behind the NDAP from its beginning has been the reduction of the risk to the general population posed by these facilities. It has also sought to ensure that decommissioning is conducted in a safe manner. It can be noted that these aspects have not been well captured in the high level monitoring framework that is the basis for communication of the results to external parties. High level safety indicators could include for example, the evolution of the inventory of radiological material on site. 5.3.5Evaluation Question 3.4

To what extent are Monitoring & Control systems in place to measure the progress of the decommissioning programmes? 5.3.5.1The NDAP follows clearly defined objectives, with detailed work breakdown structures, schedules and costs In 2011 the ECA observed that, ‘the Commission did not ensure that the broad priorities…were translated into a coherent set of detailed targets and indicators….None of the [stakeholders] has established a system to monitor and assess the progress towards the achievement of the overall objectives...Monitoring and reporting on programme achievements at all levels were therefore difficult’. The Commission responded to these findings by strengthening the clarity of the general and specific objectives for each programme in the 2013 NDAP Regulations. These were further elaborated in detailed objectives in the detailed implementation procedures. On the operational level, all Member States have developed robust detailed decommissioning plans – which also form part of the legal base of the programme. These plans are broken down to the level of decommissioning activities, including a schedule and corresponding costs structure based on internationally recognised standards for the estimation of decommissioning costs. The decommissioning plans were reviewed by the Commission at the outset of the programme and then by an independent consortium of consultants. The critical review found that the detailed decommissioning plans were complete, relevant and comprehensive - i.e. include all necessary activities to reach the defined decommissioning end-state. 5.3.5.2An adequate monitoring framework has been developed The programme's objectives and decommissioning plans provide a clear baseline and framework for the monitoring and control of programme implementation. The monitoring framework further includes performance indicators, targets and milestones for each of the detailed objectives. In total, 37 indicators are set out in the detailed implementation procedures of Kozloduy (10), Ignalina (13) and Bohunice V1 (14). Besides they are complemented by 18 other common indicators. All beneficiaries maintain detailed, activity and project-level schedule performance milestones and report twice per year (to the Commission) against this framework. This framework has been further enhanced since 2014 through the roll out of the EVM. Schedule Performance Indicators (SPI) are now reported systematically at the project level and at the global programme level. This provides for a simplified analysis of schedule performance, and provides useful aggregate-level indicators for strategic decision-making. The performance monitoring framework for the NDAP is generally in line with best practice observed in other EU programmes. Result indicators are directly relevant to the detailed and specific objectives for each programme. Their limited number focuses on the most relevant results sought by the programme. The quality and relevance of some NDAP specific indicators, including the use of targets and milestones, could be further improved. While no evolution in the context or decommissioning strategies would merit changes to the specific objectives, some of the targets, milestones and performance indicators as they are presently formulated for the programmes should be adapted or updated to ensure effective monitoring until 2020 and for several years after. This follows from the evolution of the activities organisation within the scope of the detailed decommissioning plan; from the opportunity to take full advantage of the improvements introduced in the reporting framework and from the fact that funds committed up to 2020 will continue to be disbursed over a period of several years following the last commitment due to the multi-annual nature of decommissioning projects. Additionally, further simplification in the comparability of the indicators throughout the three programmes is desirable. 5.3.5.3Adequate mechanisms have been put in place to produce monitoring data but reporting and programming documents can be further streamlined Decommissioning operators for all three programmes have continued efforts to enhance monitoring and control systems. Beneficiaries have put in place mechanisms to produce internal monitoring reports for the use of managers covering schedule and cost performance. They have also ensured adequate capacity to produce mandated EU-level monitoring reports and provide necessary monitoring information to the Implementing Bodies, even if reporting procedures could be further streamlined to improve efficiency according to some stakeholders. Programmes have generally defined adequate performance frameworks and are capable of producing the requisite monitoring data; better structuring and filtering of information in monitoring reports would provide additional strength in a simplified manner. In particular, the evaluation assessed the quality of the bi-annual monitoring reports and the annual work programmes. Overall, these documents are very comprehensive and allow assessing the programme implementation. Nonetheless, a number of areas for improvement were identified, including the heterogeneity of the reports and their length. 5.3.5.4The rollout of EVM has contributed to strengthening programme monitoring, but continued efforts can be made to perfect its use in practice. The use of EVM represents a significant progress towards strengthening the monitoring framework and creating a common progress measurement framework. It provides for a greater degree of objective comparison of the performance of the three programmes and supports strategic oversight at EU. The implementation has been gradual from 2014 and driven top-down by the Commission. Whilst all programmes are now systematically reporting using EVM, the implementation process has been and continues to be a learning experience and fine-tuning has been on-going. At the time of evaluation, EVM schedule and cost performance indicators were provided by all programmes for most projects and activities. Indicators are computed both against the annual work programmes and the detailed decommissioning plan baseline. It is thus possible in most cases to assess progress against annual targets, but more importantly identify any longer-term slippages against the decommissioning baseline and in this way take appropriate and timely action. More generally, the EVM system is not designed to function as an additional layer of reporting. Rather, best practice is to fully embed EVM in the management system – e.g. the processes, tools, practices and culture – of an organisation. This is necessary to ensure the robustness of performance indicators, but also the impact of EVM as a management tool. In general, INPP appears to have in place the most mature level of implementation of EVM within the three decommissioning operators. This is due largely to the fact that the organisation made the decision to implement the tool independently of and previous to the Commission’s decision to adopt this tool. Decommissioning operators would derive long-lasting benefits from fully embedding this cutting-edge tool into their management systems. The use of EVM in the decommissioning programmes and the lessons learned from its application will thus have return on investment beyond the scope of the NDAP. 5.3.6Evaluation Question 3.5

Are the communication actions addressed to the stakeholders and the public effective, adequate and accurate?

The adequacy of communication activities was assessed primarily in so far as they contributed to the effectiveness of the decommissioning process. The extent communication activities may have fulfilled other objectives was secondary. Communication activities are primarily undertaken by decommissioning operators as the primary stakeholders involved in decommissioning activities. These activities are focused on both local and national audiences. They include communication on safety and environmental aspects of interest by local populations, as well as general awareness-raising about decommissioning activities. All sites have close ties with local communities and other relevant stakeholders. Local communities had very close ties to the plants by virtue of many (generations of) residents being employed by the plants. They are thus generally aware of safety aspects of nuclear power and used to living in the vicinity of a nuclear facility. Communication activities respected EU visibility rules. Local populations are highly knowledgeable of the EU assistance provided to decommissioning. The power plants have traditionally been the main employer in the surrounding areas and the population is thus well aware of developments with regards to decommissioning. This was also supported by the politically sensitive nature of the closure of the reactors and the attention received in the national press. Communication activities within the framework of the NDAP at EU level related to the statutory reporting required by the legal base (e.g. reporting to the Council and the Parliament and to the Member States through the NDAP Committee). The Commission’s website provides the statutory reporting documents and a brief description of the programme with little information beyond this. The publicly available annual reporting informs the European public on the progress and the state of play in the implementation of the programmes. 5.3.7Evaluation Question 4

Aside from the financial assistance provided, what other types of results and impacts can be attributed to the NDAP? Going beyond the effectiveness of the NDAP in terms of making progress against the decommissioning plans, this evaluation question seeks to measure other types of positive and negative effects and impacts that have been generated by the NDAP in each country. 5.3.7.1Economic impact is mainly related to the direct impact of NDAP-funded contracts As of 2017, approximately 350 procurement contracts have been signed in execution of NDAP financed projects, representing approximately EUR 1.1 billion injected into the decommissioning market. An indicative repartition of contract value has been made based on the simplistic assumptions that the contract value is equally divided amongst consortia partners, shares going to subcontractors are ignored and that the nationality of the contracting entity is counted rather than that of the ultimate parent company. The largest beneficiaries were large nuclear consultancy / engineering firms, such as NUKEM Technologies (Germany), GNS (Germany), Iberdrola (Spain), Empresarios Agrupados (Spain) or NNC (UK) amongst others. These firms provided extensive project management and engineering support to programmes, in particular through external project management assistance contracts for EBRD-financed projects. Source: EBRD, CPMA contract data Local industry in Bulgaria, Lithuania and Slovakia has benefited significantly from contracts funded through NDAP. These are generally smaller companies providing works and services, as well as engineering and consultancy services to a smaller extent. Significant amounts of contracts awarded to foreign companies can actually remain in the country. Data provided by decommissioning operators provides a picture of the significant amount of benefit sub-contracting represents. For the Bohunice programme, a total for EUR 54 million from recent contracts awarded to foreign companies remained in the country – benefiting 62 Slovak consortia partners. This represents approximately 28% of the total value of these contracts. A similar trend can be noted with some examples in Bulgaria. In Lithuania, the decommissioning operator conducted analysis for EUR 404 million in projects (including the ISFSF and the SWTST) and found that approximately 35% (EUR 136,8 million) likely benefited local contracts. However, few local companies in Bulgaria, Lithuania or Slovakia took part in business opportunities in other programmes. If Slovakia had the highest level of national participation in its programme, only one Slovak company has won work in Bulgaria or Lithuania so far. The Lithuanian firm Specialus montažas-NTP was the only local companies in Lithuania to implement work in the other two NDAP countries to date. Finally, it can be noted that significant business opportunities were captured by leading EU nuclear consultancy and engineering firms, which have the potential to serve as repositories and transfer mechanisms for knowledge and experience developed during these projects as they assist other decommissioning projects in the future. While it is important that knowledge be retained and transferred in the public sphere (as an EU-financed project), private companies can also play a role in this process. 5.3.7.2Innovation gain The programmes have allowed showcasing advanced or new technologies, providing EU companies with valuable references. At Kozloduy, for example, the plasma melting facility represents only the second application of this technology in the domain of nuclear waste management in the world. Demand for such cost-effective technologies can be expected to grow in coming years with the expected growth of the wider decommissioning market. The process of decommissioning is also an opportunity to collect knowledge and experience. There is a significant need for reliable data about decommissioning process to improve the accuracy of plans and properly assess the cost of it. Valuable information includes: the evaluation and optimization of decommissioning options, the modelling of dismantling techniques, the evaluation of safety in decommissioning; and waste management scenarios. It allows for further development of specific codes for decision making process and planning in decommissioning, which can be considered as an additional important impact of the NDAP with economic dimension.

Apart from the above, no other examples were found of truly innovative technology developed by companies or decommissioning operators as part of NDAP; nor do decommissioning operators conduct extensive R&D. The Ignalina programme holds the highest potential for the development of innovative technologies as the conditioning and storage of irradiated graphite is subject to extensive R&D in the world and no clear solutions are yet available. 5.3.7.3Experience gain All three decommissioning operators are considering leveraging the experience gained into future commercial opportunities. For example, JAVYS has made concrete steps in this direction at present. The experience and credential gained through the NDAP may thus contribute to an additional return on investment for the European economy through the emergence of new decommissioning companies active on the European and international market, in the same way that it has contributed to developing the expertise and experience of large engineering firms as previously described. 5.3.7.4Social impact The process of decommissioning