EUROPEAN COMMISSION 
Brussels, 24.11.2011 
SEC(2011) 1387 final 
  
COMMISSION STAFF WORKING PAPER 
Impact assessment 
Accompanying document to the 
Proposal for a Council Regulation 
on Union support for the nuclear decommissioning assistance programmes in Bulgaria, 
Lithuania and Slovakia. 
 
{COM(2011) 783 final} 
{SEC(2011) 1388 final}  
 
EN 2   EN COMMISSION STAFF WORKING PAPER 
Impact assessment 
Accompanying document to the 
Proposal for a Council Regulation 
on Union support for the nuclear decommi ssioning assistance programmes in Bulgaria, 
Lithuania and Slovakia. 
 
 
EN 3   EN TABLE OF CONTENTS 
1. Procedural issues and consulta tion of interested parties.............................................. 5 
1.1. Identification ............................................................................................................ .... 5 
1.2. Organisation and timing............................................................................................... 5 1.3. Consultation and expertise ........................................................................................... 6 1.3.1. Public consultation..................................................................................................... .. 6 
1.3.2. Direct consultation of the Member States concerned .................................................. 6 
1.3.3. Other inputs............................................................................................................ ...... 7 
2. Problem definition........................................................................................................ 7 2.1. Context ................................................................................................................... ...... 7 
2.2. What is the problem? ................................................................................................. 12 2.3. Who is affected, in what ways, and to what extent? .................................................. 14 2.4. Evolution of the problem without further EU support............................................... 15 2.5. EU right to act and EU added-value .......................................................................... 15 3. Objectives.................................................................................................................. . 16 
3.1. General policy objectives........................................................................................... 16 3.2. Specific objectives ..................................................................................................... 17  
3.3. Consistency with other EU  policies and objectives ................................................... 17 
4. Policy options............................................................................................................. 1 7 
5. Analysis of impacts.................................................................................................... 19 5.1. Economic, social and environmental impacts............................................................ 19 5.1.1. Economic impacts ...................................................................................................... 19  
5.1.2. Social impacts .......................................................................................................... .. 22 
5.1.3. Environmental impacts............................................................................................... 22 5.2. Sensitivity analysis..................................................................................................... 2 2 
6. Comparing the options ............................................................................................... 23 7. Monitoring and evaluation ......................................................................................... 29 7.1. Core indicators of progress towards meeting the objectives...................................... 29 7.2. Broad outline for possible monitoring and evaluation arrangements ........................ 29 8. Annexe 1: Overview of 3 countries basic data........................................................... 32 
 
EN 4   EN 9. Annexe 2: Full decommissioning plans for LT, SK, BG........................................... 35 
9.1. Annexe 2.1: Detailed decomm issioning plan – Lithuania ......................................... 35 
9.2. Annexe 2.2: Detailed decommissioning plan – Slovakia........................................... 36 9.3. Annexe 2.3 Detailed decommissioning plan – Bulgaria............................................ 37 10. Annexe 3: Conclusions of previous/ongoing audits................................................... 40 
Disclaimer:  This report commits only the Commission' s services involved in its preparation 
and does not prejudge the final form of any decision to be taken by the Commission. 
 
EN 5   EN 1. PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES  
1.1. Identification 
Lead DG:  DG ENER  
Other involved services:  SG, DG BUDG, DG REGIO, DG JRC, DG SJ, DG ECFIN, DG 
ENV, DG CLIMA, DG RTD, DG ENTR and DG EMPL 
Agenda planning or WP reference : 2011/ENER/050 
1.2. Organisation and timing 
This proposal has been drafte d by DG ENER and covers the assessment of the proposal for 
further financial EU support to  Lithuania, Slovakia and Bu lgaria, originating in the 
corresponding Accession Treaties. 
An impact assessment steering group has been set up on 16/02/2011. DG ENER, SG, BUDG, 
REGIO and JRC participated in the work of this IASG. DG SJ, ECFIN, ENV, CLIMA, RTD, 
ENTR and EMPL were invited to participate in the work of the IASG, but did not nominate a 
representative. 
The Impact Assessment Board has assessed the draft Impact Assessment submitted to their 
attention in September 2011 and issued its op inion on 21 October 20 11. In line with the 
opinion, the draft Impact Assessment ha s been revised, in particular to: 
– clarify the context for the proposed action and to provide a clearer problem definition (see 
section 2.1, 2.2, 3.1 and 3.2); 
– explain more clearly the choice of policy optio ns, link of options to specific objectives and 
link of options to feedback fr om stakeholders, European Cour t of Auditors and European 
Parliament (see section  2.2, 4, 5, in particular  5.1.1 and 6, in partic ular the paragraphs 
related to option 3); 
– strengthen the impact analys is (see sections 5.1, in part icular 5.1.1 and section 6 in 
particular the paragraphs  related to option 3): 
– provide a more operational evaluation and monitoring arrangement (see section 7.1 and 
7.2) 
– to take into account other commen ts related to the procedure, presentation and clarification 
of terminology (see section 1.3.1, 1.3.3, 2.2, 4 and 5.1.3). 
A proposal for a Council Regulation is fores een for November 2011. The Council Regulation 
is foreseen to come into force on 1 January 2014. 
 
EN 6   EN 1.3. Consultation and expertise 
1.3.1.  Public consultation 
A notice has been publish ed on the DG ENER website1 announcing the public consultation 
for this impact assessment on the future of  the nuclear decommi ssioning programmes for 
Bulgaria, Lithuania and Slovakia. 
The public consultation was launched on 16 March at the meetings of the Nuclear 
Decommissioning Assistance  Programme Committee (NDAP C – management committee 
under comitology) and the Decommissioning F unding Group (DFG expert group) in March 
2011. The NDAPC is composed of national Member  State representative s that assist the 
Commission in implementing th e current financial EU deco mmissioning support. The DFG is 
composed of nuclear experts from the Member  State dealing with financial aspects of 
decommissioning. Discussions within the DFG gave  the opportunity for the experts to express 
their views on the future orientation of th e successor to the 3 nuclear decommissioning 
programmes. The consultation via the website lasted 4 weeks, considered sufficient for the 
main direct stakeholders and Member State ex perts to provide furthe r comments if necessary, 
in addition to their input already prov ided at the DFG and NDAP meetings. 
No further input was received from the cons ultation process via the DG ENER website. There 
were only two requests for additional information. 
In general, all experts within  the DFG recognise the need for continued financing of these 
nuclear units that were shut down early in line  with the Accession treaties. All were of the 
opinion that there needs to be a solid a nd complete detailed decommissioning plan  behind, 
including full costing  estimates up to the completion date for decommissioning. A clear 
indication of the national co-financing  and the way to secure this  national funding in the long 
term has to be provided. Key milestones  were explicitly supported, as well as the linking of 
payments to the accomplishment of concrete milestones , with the highest EU added value . 
Compliance procedures and close cost monitoring should be considered from the outset. 
Some were strongly in favour of continuing with full support towards decommissioning and 
also for additional support for energy sector measures, however in a regressive way as off 2014. 
Most experts were of the opinion to  address only decommissioning needs
 and to refer energy 
sector needs to more specific fi nancing channels such as the structural funds. A solid case 
with convincing arguments is required in or der to ensure continuation of the nuclear 
decommissioning in a safe manner in these 3 countries. 
The results of this consultation were fully inte grated at appropriate le vels of this Impact 
Assessment (ex. problem definition, assessmen t of the policy options, monitoring, and 
evaluation). 
1.3.2.  Direct consultation of the Member States concerned 
In addition to the public consultation, the thre e Member States conc erned were directly 
consulted on their further needs for financial EU support. All three Member States had 
                                                 
1 http://ec.europa.eu/energy/nuclear/consultations/2011_04_15_nuclear_decommissioning_en.htm 
 
EN 7   EN approached the Commission in 2010 with a request to open negotiations on the extension of 
the EU support beyond 2013. 
Upon request from the Commission, the three Member States provi ded a detailed justification 
for their request (ex. decommissioning planning, updated cost estimation for 
decommissioning). 
The information provided by the Member States  were the basis to define the specific 
objectives of the programme as well as th e monitoring and evalua tion provisions (Logical 
Framework Matrix). 
1.3.3.  Other inputs 
The assistance programme has been subj ect to regular audits and evaluations . Amongst others 
a mid-term evaluation for Lithuania and Slovaki a finalised in 2007, as well as a performance 
audit currently being finalised by the Eur opean Court of Auditors. These audits and 
evaluations have highlig hted some weaknesses in the overall definition of the financial EU 
assistance and proposed a number of possible measures for improving the implementation of 
the programmes. Annex 3 provides an extract  of the conclusions from the mid-term 
evaluation as well as some preliminary recomm endations from the performance audit. The 
recommendations were taken into account. 
Also the opinion of the European Parliament a nd the feedback from broad discussions in the 
different Committees of the Pa rliament (in the context of the adoption of the Council 
Regulation for the extension of EU support to Bulgaria for the period 2010-2013) and the 
findings of the European Parliament's own initiative report from 2011 have been taken into account. The feedback from these recommendati ons has allowed a clear  definition of the 
general and specific obj ectives, performance indicators to m eet them as well as to assess the 
policy options. It was also of major guidan ce for clearly defining the scope, amount and 
duration for further EU support in order to defi ne a clear framework fo r the programme, with 
a clear statement to concentrate on decommissi oning and to no longer support projects in the 
energy sector. The Commission’s proposed implem entation mechanism is also in accordance 
with the recommendations. 
2. P
ROBLEM DEFINITION  
2.1. Context 
The three countries, Lithuania, Slovakia and Bulgaria, operated old soviet design nuclear 
reactors which the international community, in line with the G7 multilateral programme of action adopted at the Munich G7 summit in 1992, concluded could not be upgraded to meet 
the minimum required safety standards, at an  economically acceptable cost. As such these 
plants required to be clos ed earlier than their fores een end-of-lifetime dates. 
In the context of the negotiations for accession  to the European Uni on, the three candidate 
countries took the commitment to close and subsequently decommission these nuclear reactors by a commonly agreed  date. This early closure
 represented an exceptional financial 
burden  for the Member States which was not comme nsurate with the economic strength of the 
countries  concerned. In recogni tion of this fact and as act of solidarity  the European Union  
committed itself to continue to provide adequate additional financial assistance  for 
decommissioning of these reactors. The closure commitment of the three Member States as 
 
EN 8   EN well as the commitment of the EU to provide  financial EU support was foreseen in the 
corresponding Accession Treaties. 
In 2006 and 2007 the European Council adopted new Regulations for Lithuania2 and 
Slovakia3 which formed the legal basis for the con tinuation of the European Union assistance 
in these countries until the end of 2013. Since mid 2010 a new Council Regulation4 provides 
the legal basis for additional European Un ion assistance to Bulgaria for 2010 – 2013. 
The total financial assistance from the European  Union to the three Member States until the 
end of 2013 foresees €2 847.8 million (€1 367 million for Lithuania, €613 million for 
Slovakia and €867.8 million for Bulgaria). 
The European Union assistance  is designed to support Me mber States efforts in the 
decommissioning of the nuclear power plants as  well as to support meas ures in the energy 
sector to mitigate the economical conseque nces of the early closure, such as: 
– the nuclear safety in the nuclear facilities,  
– the establishment and upgrade of the waste ma nagement infrastructure required to start 
decommissioning activities,  
– measures to support the nuclear safety author ities in safe assessment and licensing of 
decommissioning projects, 
– the environmental upgrading of energy infrastr ucture and modernisation of conventional 
energy production capacity as a replacemen t for the lost nuclear energy production 
capacity in line with the legi slation of the European Union, 
– the enhancement of security of supply and energy efficiency, 
– measures to support plant personnel in maintain ing a high level of operational safety in the 
periods prior to the closur e and during the decommissioni ng of the reactor units. 
The European Union financial assistance has been made available in the form of contributions 
to three International Decommissioning Support Funds  managed by the European Bank for 
Reconstruction and Development. In addition, si nce 2004, part of the financial assistance for 
Lithuania has also been made availabl e as a direct support to the country  in order to 
implement provisions of Art. 2.45 of the Accession Protocol through a National Agency 
(Central Project Management Agency). 
All three Member States have fulfilled their accession treaty commitments to close their 
reactors in a timely manner . Ignalina Nuclear Power Plant Unit 1 was shut-down on 31 
December 2004 and Unit 2 on 31 December 2009. Bohunice V1 Nuclear Power Plant Unit 1 was shut-down on 31 December 2006 and Unit 2 on 31 December 2008. Kozloduy Nuclear 
                                                
 
2 OJ L 411, 30.12.2006, p.10 
3 OJ L 131, 23.5.2007, p.1 
4 OJ L 189, 22.7.2010, p.9 
5 "The Ignalina Programme shall include measures to support plant personnel in maintaining a high level 
of operational safety at the Ignalina Nuclear Power Pl ant in the periods prior to  the closure and during 
the decommissioning of th e said reactor units." 
 
EN 9   EN Power Plant units 1 and 2 were shut-down on 31 December 2002 and units 3 and 4 on 31 
December 2006. 
All beneficiary countries were commitment to  proceed with the implementation of their 
decommissioning plan and where technically possi ble, defueling of the reactor took place as a 
first important step towards irreversible closur e and decommissioning of the plants. Facilities 
necessary to support the decommissioning proce ss are under installation. Preparation of 
licensing documentation is under elaboration a nd preparatory works for dismantling as an 
integral part of decommissioning are ong oing. The countries` legal framework and 
management structures are in the process to be adapted to take into account the change from 
an electricity producing company to an or ganisation for safe decommissioning. First 
dismantling works of non-active f acilities have started. Major faci lities for the treatment and 
storage of radioactive waste an d spent nuclear fuel are unde r construction, where they are 
required. 
The energy sector benefited from the financing of measures fully in line with the European 
Union energy policy. Energy efficiency projec ts were successfully completed, conventional 
production capacities were environmentally  upgraded and new capacities are under 
construction and the adjustment of the electricit y grid infrastructure is under implementation. 
In none of the three Member States did the cl osure of the nuclear reactor units result in a 
black-out electricity supply. Not even the severe  gas crisis in early 2009 led to the reopening 
of the closed reactor units, although the inte ntion was expressed at political levels. 
The table below gives an overview on some majo r achievements of the current financial EU 
support.  
 
EN 10   EN  
Where do we stand?  Examples of main achievements 
Lithuania 
Decommissioning – Shut down of both units and defu eling of unit 1 reactor core; 
– Finalisation of the free release measurement facility; 
– Start of dismantling works in th e building with the Emergency 
Core Cooling System; 
– Start of decontamination of  unit 1 primary circuit; 
– Start of dismantling works in the reactor turbine hall; 
– Construction works of spent fuel  and radioactive waste storage 
facilities close to completion; 
Mitigating measures – Environmental upgrade of the L ithuanian Thermal Power Plant; 
– Construction of a new 4 40 MW CCGT plant ongoing; 
1045MW production capacity was made available by those 
measures as replacement. Consider ing the date provided in annex 1 
this corresponds to approximately 57%  of the effective lost capacity. 
Slovakia 
Decommissioning – Shut down of both units and complete defueling; 
– Update of the V1 conceptual decommissioning plan; 
– Elaboration of decommissioni ng license documentation and 
decommissioning waste management strategy; 
– Decommissioning license obtained in July 2011; 
– Reconstruction of an a uxiliary boiler station; 
Mitigating measures – Reconstruction of Krizovany transformer substation; 
– Close to 400 energy efficiency pr ojects supported mainly in the 
residential sector but 10% al so in the industrial sector. 
For Slovakia the mitigating measures were focused on the upgrade 
of their electricity network infr astructures that became necessary 
following the closure of Bohunice V1 nuclear power plant. 
Bulgaria 
Decommissioning – Shut down of all 4 units and complete defueling of units 1&2. 
Complete defueling of units 3& 4 is foreseen by end of 2011; 
– Construction of a dry spent fuel storage facility; 
– Revised decommissioning strategy put in place; 
– Design, supply and implementation of projects within the first 
stages of decommissioning; 
– Environmental impact assessment; 
– Start of dismantling works in the turbine hall; 
Mitigating measures – Extension and refurbishment of national electricity distribution 
system; 
– Rehabilitation of Pernic district heating; 
– Rehabilitation of Sofia district heating network and substations; 
– Contributions to energy efficiency  and renewable energy projects 
through credit line facilities; 
 
EN 11   EN The energy efficiency measures will lead to an equivalent 
production capacity replacement of estimated 500MW. Considering the date provided in annex 1 this  corresponds to approximately 62% 
of the closed down effective lost capacity (this doe s not take into 
account financial support provided separately to the EU decommissioning support for upgrading Kozloduy units 5&6 that 
also contributed to the compensatio n for the closure of units 1&2). 
 
Apart from the listed achievements it is im portant to understand how far the three Member 
States progressed in decomm issioning. Decommissioning is a long process composed in 
general of two major phases char acterised by the type of licens e issued by the national nuclear 
regulator (see figure). 
 
Slovakia has completed the transition period by having obtained its first decommissioning 
license for Bohunice V1 nuclear power plant.  In Kozloduy units 1&2 have no more spent 
nuclear fuel in the units. Conse quently both units have been transferred to the State Enterprise 
for Radioactive Waste and are close to obt aining their decommissi oning license. By 2013 
Kozloduy units 3&4 are expected to have receiv ed their decommissioning license. In the case 
of Lithuania the transition period will extend un til 2016. This time is required to transfer all 
spent nuclear fuel from both reactor units to the dry spent fuel storage. 
It must be understood that non-safety relevant  decommissioning activities as well as the 
implementation of the required spent fuel storag e facilities and waste treatment and storage 
facilities can already be executed in the tr ansition period. Conseque ntly, although only four 
out of eight concerned nuclear  reactor units have complete d the transition phase, first 
dismantling works have started (ex. in the turbine building) also for the other units. Progress in the spent fuel and waste management are in an advanced implementation stage. Equally important activities to be performed in the tran sition period are the prep aration of all required 
licensing documents as well as environmental impact assessments, where required. 
By the end of 2010 the European Commission committed a total of €1 807 million with the 
following breakdown: 
– Lithuania: total commitment: €995.5 million; a llocation to projects: €894 million (€694 
million EBRD and €200 million CPMA); 72% on decommissioning and 28% on measures in the energy sector; 
 
EN 12   EN – Slovakia: total commitment: €423.7 million; allo cation to projects: €391 million; 53% on 
decommissioning and 47% on measures in the energy sector; 
– Bulgaria: total commitment: €642.8 million; allocation to proj ects: €575 million; 57% on 
decommissioning and 43% on measures in the energy sector; 
The rate of absorption of the financial EU support has improved substantially over the last 
years with the realisation of major investment projects (ex. waste management infrastructure 
projects) and with the start of real decomm issioning works. The absorption rate (full 
commitment to projects) is expected to be high by the end of the curren t financial perspective. 
2.2. What is the problem? 
Effects of radiological incident s can have potential consequences for the health of workers 
and citizens and for the environment as well as  wide ranging economic implications for the 
energy sector. Consequently, nuclear safety re quires the utmost attention and appropriate 
actions, also after the closure of the units durin g the transition phase where spent nuclear fuel 
is still present in the reactor units and during decommissioning. The problem is to eliminate as 
far as possible the source of radiological hazard.  In concrete terms this means that the closed 
reactor units must remain closed, that they are defueled and that they are safely dismantled. In 
the context of ‘early closure’  and considering the related ec onomical consequences for the 
three concerned Member States this closure must become irreversible6. Today this stage is not 
yet reached. 
The current financial EU support has effectivel y mitigated the economical consequences of 
the early closure and the decommissioning pr ocess is well engaged (waste management 
infrastructure, preparation for dismantling). However, as can be deducted from the figure of the previous paragraph, the impor tant safety relevant key pr ojects in the decommissioning 
process are still to be implemented. The rema ining key challenges (including tentative 
timeframe) to be addressed by the three Member States and the relevance of EU support are 
summarised in the next table: 
Lithuania 
Remaining challenges: 
– Defueling of spent nuclear fuel from Unit 2 and the reactor fuel ponds into the dry spent 
fuel storage (to be completed by end 2016); 
– Safe maintenance of the reactor units un til defueling is completed (until end 2016); 
– Further dismantling works: Unit 2 turbine hall (until 2017); gas and ventilation building 
(2014 – 2015); dismantling works in reactor building unit 1 and 2 (start in 2017); 
– Engineering design for reactor core dismantling; 
Relevance of EU support: To provide financial support due to  inadequate national resources 
(50m€ only) for seamless continuation of d ecommissioning focussed on key projects towards 
irreversibility of the closure;  
                                                 
6 Closure to become irreversible means that decommi ssioning has progressed so far on a technical level, 
that it would economically no longer be advantageous to consider the re-opening of the concerned 
reactor units. 
 
EN 13   EN Slovakia 
Remaining challenges: 
Preparation of decommissioni ng phase II from mid 2015 onwards (Preparation and execution 
of dismantling of the contaminated and activat ed equipment and systems) and completion of 
decommissioning phase I. – Decontamination of spent fuel and other contaminated tanks (until end 2015) 
– Dismantling of reactor core and r eactor building (start in 2015) 
Relevance of EU support: provide financial support to prog ress in decommissioning to be 
focussed on key projects towards i rreversibility of the closure; 
Bulgaria 
Remaining challenges: 
Dismantling activities in the reactor buildings. 
– Dismantling of large components in the re actor buildings 1 to 4 (start 2016) 
– Dismantling of equipment in reactor  buildings 1 to 3 (start 2015) 
Relevance of EU support: provide financial support due to inadequate national resources 
(180m€ only) for seamless continuation of de commissioning with focus on key projects 
towards irreversibility of the closure; 
 
In order to allow for safe decommissioning, adequate financial resources  should be available 
when required7. The updated decommissioning planning and decommissioning cost estimates 
provided by the Member States in early 20 11 provide clear eviden ce that substantial 
additional financial reso urces will be required  to complete decommissioning of the Kozloduy, 
Ignalina and Bohunice nuclear power  plants in a safe manner. 
For historical reasons, the three Member States  do not have the require d financial resources. 
The nuclear power plants were built under di fferent political and economic regimes, not 
necessitating the accumulati on of funding. Since 1995, 1999 and 2002 Slovakia, Bulgaria and 
Lithuania have respectively put in place their national funds in order to meet their national 
responsibilities for the financing of decommissioning. However, taking into account that the reactors were shut down before their initially foreseen end of design lifetime and that it takes 
about 25 years (ex. legal obliga tion for accumulation of funds in Germany) of operation to 
accumulate sufficient funds for decommissioning, it  was not possible for the three countries to 
set aside sufficient funds. Today the available resources
 are still insufficient  to ensure a 
seamless continuation and completion of safe decommissioning. In addition, early closure or 
decommissioning does not give rise  to any economic advantage, such that the market will not 
finance the decommissioning process. 
The immediate problem to be addressed is the f unding shortfall to ensure  continuation of safe 
decommissioning  of the nuclear power plants in the thr ee beneficiary countries, to ensure that 
the closure becomes irreversible and that th e beneficiary takes grad ually a stronger and 
                                                 
7 Commission recommendation on the management of financial resources for the decommissioning of 
nuclear installations, spent fuel and radioactive waste. OJ L 330, 28.11.2006, p.31 
 
EN 14   EN substantially higher own respons ibility for the decommissioning of these reactors during the 
period up to 2020. 
Findings from the mid term evaluation and the Court of Auditor's performance audit have 
contributed to the problem de finition and to developing an  appropriate policy option as 
discussed under section 6. Results from the disc ussions in the European Parliament in the 
context of the consultation presented under 1.3.3 provided additional i nput to the problem 
definition. The issues raised are summarised in the next table: 
Issues raised 
– To establish a needs assessment on progress so  far, activities still to be performed 
and overall financing plan including res ources from different  stakeholders ( ECA ) 
– To establish 'consistent strategy' with goa ls and criteria against which ongoing and 
future assistance can be judged and evaluated ( Mid-Term ); 
– Definition of objectives and meaningful pe rformance indicators for monitoring and 
reporting of programme implementation ( ECA ); 
– Ex-ante evaluation for further EU  support under the next MFF ( ECA ) 
– Identify an optimal vehicle for providing assistance in the future ( Mid-Term ); 
– Number of management levels and diffused responsibilities ( ECA ) 
– Absence of funding ceilings and pollute r pay principle should be applied ( EP) 
– Full funding not guaranteed ( ECA ) 
– High share of funds used for mitigating measures and not for the main purpose 
(decommissioning) ( EP) 
– Economical consequences sufficiently mitigated ( EP) 
– Safety is of utmost importance ( EP) 
– Simplification of rules for implementation ( EP) 
– Assess funding through Structural Funds ( ECA ) 
 
2.3. Who is affected, in what ways, and to what extent? 
EU citizens and future generations as well as the environment are the main groups affected by 
the problem of funding shortfa ll and the associated risk of  compromising nuclear safety. 
This funding shortfall  would be a major risk for the safe maintenance  of the shut down 
reactors (no salaries for the staff to perfor m safe maintenance). It  would also jeopardize  the 
seamless continuation of safe decommissioning  because of the risk that further 
decommissioning steps would be postponed to an undefined date, awaiting the availability of 
funds and transferring this  liability and responsibil ity to future generations . It also increases 
 
EN 15   EN the risk of reopening of th e unsafe nuclear power plants . At most of the reactor units no major 
irreversible dismantling steps have been impl emented. Technically it is still possible to 
consider restarting certain reactor units, in particular if it is considered to be economical advantageous. The funding shortfall
 inevitable would also affect the environment  such as 
water quality (ground-, river- and or sea-), air quality or would result in uncontrolled release 
of contaminated materials. 
2.4. Evolution of the problem without further EU support 
Discontinuing or no further EU support would l eave the three Member States facing the full 
cost of completing the decommissioning process. As previously mentioned the Member States 
have currently insufficient alternative funding sources in place for timely implementation of 
safe maintenance and safe completion of decommissioning. Adequate funding not being 
available when required would: 
– result in the interruption or dela y of the decommissioning process; 
– change the strategy (immediate to deferred dismantling); 
– increase significantly the cost due to the delay; 
– jeopardise nuclear safety; 
– be a risk for the citizens a nd the environment due to th e uncompleted decommissioning 
status; 
– lead to the commensurate loss of plant sp ecific expertise and know ledge because no funds 
would be available to cover the salaries of  the experienced staff at the three NPP's 
performing the decommissioning works; 
– shift the liability and res ponsibility for decommissioning to future generations. 
2.5. EU right to act and EU added-value 
The EU support is anchored in the Protocols No 4 for Lithuania,  No 9 for Slovakia and No 30 
for Bulgaria to the re spective Accession Treaties8,9,10. In addition, protocol No 4 on the 
Ignalina nuclear power plant in Lithuania provides further that: 
– "… the Union shall in solidarity  with Lithuania, provide adequate  additional Community 
assistance … beyond 2006. " 
– "For the period of the next Financial Persp ectives, the overall average appropriations 
under the extended Ignalina Programme shall be appropriate ." 
It provides the framework for EU support also  beyond the current financial perspective. It 
should however not to be considered as an oblig ation for the EU to cover the full costs for 
decommissioning until its completion. 
                                                 
8 OJ L 236, 23.9.2003, p.33 and p.944 
9 OJ L 236, 23.9.2003, p.33 and p.954 
10 OJ L 157, 21.6.2005, p.11 and p.38 
 
EN 16   EN Providing further financial EU assistance to Slova kia and Bulgaria is justified in the context 
of equal treatment with Lithuani a, not in terms of absolute amount of funds but related to 
supporting the Member States in addressing the current funding shortfall for seamless 
continuation of safe decommissioning. 
The necessity for intervention (subsidiarity) is due to the fact that adequate funds required for 
continuing safe decommissioning can currently  be not be made available through the 
respective national funds as explained in the prev ious sections. Unlike other Member States in 
a similar situation but without being confronted to early clos ure of their plants, it was not 
possible for them to accumulate sufficient funds from operation of the plants. 
It is therefore in the interests of the European  Union to ensure that the concerned reactors 
remain closed and that they are defueled and di smantled in order to reduce the risk of negative 
consequences for the EU citizen and for the e nvironment. The EU added value lies in the 
support of measures dedicated to achieving real  physical progress in dismantling in order to 
reach a safe and irreversible state within the decommissioning process, which is of paramount 
importance for nuclear safety. 
Article 203 of the EURATOM Treat y states that "If action by the Community should prove 
necessary to attain one of the objectives of the Community and this Treaty has not provided 
the necessary powers, the C ouncil shall, acting unanimously on a proposal from the 
Commission and after consulting the Eur opean Parliament, take the appropriate  measures." 
The need for insuring nuclear safety throughou t the decommissioning process calls thus for 
EU action under Article 203, thereby allowing  the prolongation of the decommissioning 
assistance programmes. It is proposed to have one single common Euratom Council 
Regulation to cover the financial EU support to all three beneficiary Member States. 
3. OBJECTIVES  
The general policy objectives as well as the sp ecific objectives have been defined in the 
broader methodology to establish the Logical Fram ework Matrix (full Ma trix in section 7) 
according the Commission's Project Cycle Management procedure. 
3.1. General policy objectives 
The role of the European Union is to ensure th at nuclear energy is deve loped (from cradle to 
grave) while meeting the highest level of safety . Consequently, two Council Directives on 
establishing a community framework for the safety of nuclear installations11 as well as for the 
responsible and safe management of  spent fuel and radioactive waste12 were adopted on June 
25, 2009 and on 19 July 2011 respectively. 
The general policy objective fo r providing additional EU fu nding for the period 2014 – 2020 
is to support the three Member States in th eir efforts to continue safe decommissioning 
according the revised decommissioning plans. It  provides substantial and durable support for 
the health of workers and the general public , preventing environmental degradation and 
providing for real progress in nuclear safety and security and initiates at the same time the transition towards full own Member States fina ncial coverage. The ultimate responsibility for 
                                                
 
11 OJ L 172, 2.7.2009, p.18 
12 OJ L 199, 2.8.2011; p.48 
 
EN 17   EN nuclear safety however remains with the Memb er State concerned, which also implies the 
ultimate responsibility for its financing. 
In order to achieve this objective in the given context, additional assistance of €500 million 
has been estimated for the pe riod 2014 - 2020, in support of  safe decommissioning. This 
further assistance is clearly to be understood as  an expression of solidarity towards the three 
concerned Member States. 
3.2. Specific objectives 
The three specific objectives of the a dditional EU support programme are to 
(1) To reach an irreversible state within  the decommissioning process. The main 
expected results/outputs for ach ieving this objective are: 
•  Nuclear power plants are safely ma intained in post shut-down mode until 
complete defueling; 
•  Decommissioning license is in place; 
•  Design for the dismantling of the reactor core/primary circuit is completed: 
•  Dismantling in the reactor building has started. 
(2) To safely manage the radioactive waste:  The main expected results/outputs for 
achieving this objective are: 
•  All nuclear reactor units are entirely defueled and nuclear spent fuel is safely 
stored: 
•  Decommissioning waste is part of a comprehensive waste management 
programme and safely treated and stored according to a detailed waste management plan. 
(3) To maintain the key expertise and know ledge: This is of benefit for safe 
decommissioning but equally important for a ddressing the social c onsequences of the 
early closure. The expected result for achie ving this objective is the redeployment of 
plant personal for decommissioning activities. 
3.3. Consistency with other EU policies and objectives 
The general and specific object ives for providing additional EU funding for the period 2014 – 
2020 are consistent with the Community assi stance programme provided under the current 
financial perspectives as well as the Lisbon Treaty (solidarity principle). 
4. P
OLICY OPTIONS  
The three identified policy options are:  
Option 1: Baseline option: No fu rther financial EU assistance; 
 
EN 18   EN Option 2: Business as usual: EU financ ial contribution to decommissioning and 
consequential measures in the energy sector; 
Option 3: EU partial financing of decommissioning only Under Option 1  the implementation of the provisions of the accession treaty would end in 
2013. No further financial EU assistance woul d be provided and consequently all three 
Member States would have to guarantee sa fe completion of their decommissioning 
programme with own national resources. 
Option 2  would entail a prolongation of the current funding program mes, similar in level of 
funding (current support: €258 million per year ) and in scope (decommissioning and energy 
measures to further mitigate the economical consequences of the early closure). 
Option 3  is a clear political message that the three Member States should show a higher 
degree of financial responsibil ity and ownership and therefore additional funding is proposed 
to be reduced in amount (about €71 million per year in average) and limited in time (no EU support any more beyond 2020). Under this option, no further EU assistance would be made 
available for measures in the energy sector fo r mitigating the economical consequences of the 
early closure. The EU support w ould only be focussed on key i ssues in order to progress on 
safe decommissioning. The EU support would n eed to be complemented by substantial 
additional national financial re sources to meet the remaining funding gap for the completion 
of decommissioning. 
The policy option of no EU intervention but completing decommissioning only with private 
funding was not considered. Early closure or decommissioning are not giving rise to any 
economical gain, which means that also the market will not finance the decommissioning 
process. 
Complementary to the policy options it is important to assess the possible delivery 
mechanisms in order to identify the most appropriate mechanism for achieving the general and specific objectives in the mo st effective and efficient way. This has been recommended in 
the context of the mid-term evaluation. Option 1 (no further financial EU  assistance) does not 
require any delivery mechanism. 
There are four possible delivery mechanisms that  can be considered for options 2 and 3. They 
are: 
Mechanism A:  Funding under joint management with the EBRD through the existing 
international multi-donor funds (current mechanism for all three Member States): This is the 
current system. It worked well in the period before Accession, but has since then started to 
show its limits. It is to be noted that the other donors have not pr ovided any further support 
since years, making the EU the largest and since 2004 the only remaining donor (more than 
95 % of current funds totals). 
Mechanism B : Funding under joint management with the EBRD however through dedicated 
EC funds: This system would benefit from th e EBRD's competence as financial institution 
under joint management, without the dr awbacks of the multi-donor fund system. 
Mechanism  C: Funding under centralised indirect ma nagement through the existing national 
agency CPMA (current additional mechan ism only for Lithuania) nominated by the 
Commission: With the completion of the main infrastructure investme nt projects, and the 
 
EN 19   EN advancement in the decommissioning process w ith skilled own staff at the nuclear power 
plant, a tendency to move towards complete execution of the EU budget by CPMA is the ongoing trend. 
Mechanism D : Funding integrated into the EU stru ctural funds mechanism: This delivery 
mechanism would be entirely new and woul d put the decommissioning support programme 
under the General Regulation gove rning the Structural Funds. 
The implementation of any further EU support directly by the European Commission without 
any intermediate implementing body (EBRD or  CPMA) is not cons idered as delivery 
mechanism. The Commission does not have th e required human resources to act as 
contracting authority, to ensure  the implementation of investments and the management of 
decommissioning project preparation, selection, appraisal, procurement, contracting and 
control. 
5. A
NALYSIS OF IMPACTS  
5.1. Economic, social and environmental impacts 
Effects appear mainly linked to the fields below, and are positively respectively negatively 
linked to either funding of a safe decommissi oning, or the lack of sufficiently and timely 
available funding. They are mainly cross-border. 
5.1.1.  Economic impacts 
• Electricity prices for consumers.  Although it can be argued th at up to now, the cost of 
electricity charged did not include all back -end costs (except Slovakia), there are high 
increases in electricity prices  for end consumers due to the early closures. Options 2 and 
3 would ease the effect, by offsetting partly  the decommissioning costs and spreading 
the price rise due to increased levies on electricity over time. 
• Electricity trade:  the early closure has led to dimini shed generation capacity in the three 
Member States, and hence diminished electr icity trade (Bulgaria), or switches from 
being electricity exporter to importer (Lithuani a and Slovakia). It is  to be noted that 
Lithuania and the Baltic States in general ar e not connected to the European electricity 
grid, making them vulnerable to major electricity imports from one single source, Russia. Lithuania had to close down its tw o nuclear reactor units , representing around 
70% of the energy generation. It  is still heavily dependent on one supplier (Russia 80%) 
for all energy sources (oil – gas – electricity) . Only option 2 would make a difference, as 
energy sector measures w ould then be financed. 
• Competitiveness:
  
The Accession Treaties already recognise the ex traordinary burden that is placed on the 
economies of the three concerned Member States following the early closure. The 
amounts needed for the decommissioning process, especially given the imposed early closure, might handicap the competitivene ss of the three Member States during an 
extended period of time. Therefore, EU f unding is already foreseen since the Pre-
Accession status in order to restore the co mpetitive balance with Member States who 
 
EN 20   EN have had more time to accumulate d ecommissioning funds during the operational 
lifetime of their nuclear power plants. 
Option 1 would therefore worsen the competitive status of the three concerned Member 
States. Options 2 and 3 restoring the compe titive fair grounds as far as the amounts 
needed for decommissioning are concerned. However, given the time lapse since the closure and the mitigation measures alrea dy put in place until now, care must be taken 
in order not to go too far, especially re lating to replacement capacity or equivalent 
savings. Such an action could possibly create  distortion with other Member States who 
have to replace outdated power generation themselves. 
Additionally, under option 1 and 2 in the case of Lithuania,  experience in th e "first of a 
kind" decommissioning of a graphite reactor would be build up – with all international 
expertise involved in the research and steering of the progr amme. This would 
strengthen Lithuanians competitiveness in the field of decommissioning of graphite 
reactors. 
• Impact on the GDP: 
 
The seamless implementation of the current decommissioning plans (option 2 and 3) 
will stimulate growth by accelerating the p ace of decommissioning activities to be 
performed. Delaying decommissioning because of inadequate funding (option 1) would 
have a negative impact on the GDP, as invest ments would be shifted towards the future. 
• Public authorities:  
Option 1 will have a major budgetary impact for the beneficiary Member States. They 
would need to cover the full remaining funding for decommi ssioning from their 
national budget. This cannot be considered credible. At present effectively €50 million 
is available in the national fund in Lithuani a; €230 million is available in the national 
fund in Slovakia for reactors 1 and 2; and €180 million is available in the national fund 
in Bulgaria for reactors 1 to 4. Option 2 and 3 will limit the impact on the national 
budgets. Nevertheless, option 3 clearly emphasises the n eed for the three Member 
States to ensure a higher degree of fi nancial responsibility and ownership. While 
providing a reduced support beyond 2013 this allows for a smooth transition to full 
Member State funding of decommissioning until the end of the process. It provides an 
additional time reserve for Member States to  set aside national res ources to take over 
the financial liability for completion of decommissioning. 
• Administrative burden:  
For the implementation of the policy options (2 and 3 only) the burden depends on the 
selected delivery mechanism identified in section 4. 
For mechanism A  the decision systems are compli cated, giving the EU only one vote 
amongst the donors, and are lead ing to a dilution of res ponsibilities. In case of 
difficulties in the implementation of projects this mechanism has shown its limitations regarding the Commission’s possibilities to intervene. This weakness has also been identified in the context of the performan ce audit conducted by the European Court of 
 
EN 21   EN Auditors. Due to the fact that since 2004 there were no further 3rd party contributors to 
the multi-donor fund this mechanism seems no longer appropriate. 
Under mechanism B  the decision making process would be streamlined, as well as the 
monitoring flows improved, and admini strative burden decreased. The General 
Conditions applicable to the European Community contributi on agreements with 
international organisations as well as th e Commission's procedural decisions would 
then be binding and would fully apply (which is not the case for the multi-donor 
funding mechanism under A). Mechanism B would strengthen the Commissions 
management possibilities to intervene more effi ciently in case of di fficulties (delays and 
cost overruns) in the implementation of d ecommissioning project by the beneficiaries. 
At the same time it allows to reduce the numb er of management levels as recommended 
by the Court. 
Implementation of the EU support via a de dicated national ag ency under delivery 
mechanism C  has benefits for the future kind of projects of proximity for instance 
during tender processes and day to day follow up of the decommissioning works by 
local companies. Although this mechanism is operating in Lithuania, a similar 
alternative is not investigated for Slovakia and Bulgaria, as no suitable structures exist 
at present to fulfil this role. Given the time needed to set up, verify and accreditate such 
new structures, a significant ri sk for delays would occur. 
The inclusion of the decommissioning funds into the structural funds (mechanism D ) 
would appear to be contrary to the overall philosophy of the structural funds, which are 
geared to growth objectives, notably in lin e with the priorities of the EUROPE 2020 
strategy. Structural Funds operate on the ba sis of shared management. In accordance 
with this principle, it is up to Member St ates to design, select, implement and manage 
projects, in line with the priority axes la id down in operational pr ogrammes that are the 
subject of a Commission decision. The prim ary responsibility for monitoring and 
control of the project lies with Member States. The Commission participates in 
programme monitoring committees on an adviso ry basis and performs  selective audits 
on the basis of a risk analysis. The system of  regular technical inspections performed by 
the Commission as part of the monitoring mechanism for nuclear decommissioning is 
not readily compatible with the shared management mode l. International cooperation 
would also be less straight forward under shared management . Specificities in the field 
of nuclear decommissioning such as active in volvement of specialis ed nuclear services 
and inspections to assure nuclear safety  throughout the decommissioning process are 
not readily compatible with the shared mana gement mode of the Structural Funds. The 
Structural Funds operate on a co-financing ba sis, i.e. national publ ic or private co-
financing is required, with the EU contribu tion being determined by the various limits 
set out in the General Regulation governing th e Structural Funds. The actual level of the 
EU contribution to a given priority axis is additionally modulated on the basis of a number of criteria, including the full app lication of the "pollu ter pays" principle. 
• Impacts on third countries:
 
Option 1 would lead to an immediate funding shortfall. This could have a potential 
major impact in and outside the EU as highlighted in the problem definition under section 2. Options 2 and 3 address the fundi ng shortfall and will have a positive impact 
on citizens and environment in and outside the EU. 
 
EN 22   EN 5.1.2.  Social impacts 
• Employment:  Currently a significant number of skilled people are employed at the 
concerned power plants (4200 in BG (715 in  decommissioning of units 1-4), 2000 in LT 
and 1000 in SK(240 in V1)). These skilled labour forces are needed for the safe 
maintenance of the closed down reactors, fo r the radiological char acterisation and for 
some pre-decommissioning activities requiring their existing historic al knowledge of the 
plant's operational life time. If no funding w ould be available (op tions 1), this would 
pose a serious threat to the payment of their salaries13. It would also affect whole towns, 
where the NPP is generally the main employe r. Therefore many more people than only 
the direct staff would be affected in their future. In case of continued EU financing for 
decommissioning (options 2 and 3), the ke y staff with their expertise would be 
maintained as well as the historical memory, with the highest value for the decommissioning project. Their historical knowledge would be used optimally, and the 
risk of additional cost overruns due to "unf oreseen discoveries" w ould be significantly 
lower. Additional skilled labour would be need ed in the operation of the waste facilities. 
• Security (accidents / terrorism / security of energy supply):
 without funding (options 1), 
less strict control and less maintenance are likely, leading to a higher risk of misuse. 
With the acceleration of the decommissioning pro cess (options 2 and especially 3), this 
risk diminishes. 
• Health:  radiological risks for workers as well as  for the general public are possible in 
case of accidents or lower safe maintenance.  Safe treatment, stor age and disposal of 
spent fuel and radioactive waste should be acc ording to the highest safety standards but 
they require appropriate funding (options 2 and 3). The relevance of safety has been 
underlined by the European Parliament. 
5.1.3.  Environmental impacts 
• Environment:  in case of delaying the decommis sioning, the waste management, in case 
of insufficient safe maintena nce or accidents, or even simply as a result of ageing 
monitoring equipment, impacts would include areas as drinki ng water, rivers and lakes, 
the food chain, flora and fauna, radiological effects on land, wate r and air. It is important 
to ensure transparent monitori ng, especially for possible EU wide effects. The risk for 
accidents, contamination, leaks etc increas es with the lack of funding for safe 
maintenance and decommissioning (option 1 en tail a significant risk, which is much 
lower under options 2 and 3). 
5.2. Sensitivity analysis 
The decommissioning process is a complex pro cess which extends over a significant time. 
There are several uncertainties. Some are of a technical nature (e.g. the first-in-a-kind decommissioning of a graphite reactor, differe nces between building plans and actual built 
dating back to the soviet era). Others are the availability of sufficient national funding, price 
evolutions, changing safety regulations or additional safety requirements imposed at the 
licensing stage. 
                                                
 
13 To be noted that not for all staff, sala ries should be paid under decommissioning. 
 
EN 23   EN RISK MATRIX 
 High impact Medium impact Low impact 
High probability Non-availability of national 
funding Price evolutions  
Medium probability Technical changes due to 
"the first-of-a-kind" 
decommissioning of a 
graphite reactor; changing safety regulations; additional safety requirements imposed at lincensing Differences between 
building plans and 
actual built dating 
back to the soviet era  
Low probability    
The above risk matrix concerns the overall decommissioning process independent from where 
the financing is provided. Howeve r, the risk for the EU budget should be limited by setting 
clear priorities in the tasks to be performed (h ighest EU added value), give the overall ceiling 
for the EU funding solidarity (cost overruns ar e born by the beneficiary Member States), as 
well as creating the optimal funding contribu tions on for instance an "earned value" 
management control concept. 
To complete the above considerations the Logi cal Framework Matrix in section 7 identifies 
additional external factors that have the potential to influence (or even determine) the success of the EU support programme, but lie outside the direct contro l of the European Commission. 
6. C
OMPARING THE OPTIONS  
The overriding principle and main weighing fact or is the contributi on to improving nuclear 
safety and security while progressing with nuc lear decommissioning. A ll impacts have been 
treated in a qualitative way, within the need to contribute to the general and specific objectives. Option 1 does not address any of th e objectives. It excludes the EU from any 
influence on safe decommissioning reaching an irreversible stage in the process. 
Consequently this option must therefore to be  excluded. Business as us ual option 2 and option 
3 contribute to the overriding prin ciple of nuclear safety. Option 2 is however far more costly 
without justified EU added value (high time laps e since closure and significant measures put 
in place to deal with the early closure consequences). 
Option 1: Baseline option: No further financial EU assistance 
In the case funding has to come entirely fr om the already stretched national budget, the 
"immediate decommissioning" strategy will not be pursued, especially given the current 
economical context, the energy needs and the original reluct ance to close down early the 
"profitable" nuclear reactors. Talks about re-opening have already been held. The potentially 
re-opening of these nuclear reactors poses a seriou s threat to the citizens and the environment. 
 
EN 24   EN Strengths: 
– national responsibilities taken 
– polluter pays principle would be fully 
endorsed  Opportunities: 
– less costs on the EU budget  
– no programme administration (delivery 
mechanisms) required  
Weaknesses: 
– insufficient funding available in the national 
fund 
– economical context of weak national budgets 
– no "direct" international view on the 
decommissioning process  Threats: 
– compromise nuclear safety 
– postponement of decommissioning and related 
higher inflated costs 
– restart of the reactors 
– prolonged duration of and additional costs for 
safe maintenance 
– unemployment of staff and loss of necessary 
skills for nuclear decommissioning 
– radiological exposure 
– environmental degradation  
Option 2: Business as usual: EU financial contribution to decommissioning and 
consequential measures in the energy sector 
Further financial support beyond 2013 at the cu rrent support level will allow to swiftly 
progress with the actual dismantling operatio ns and waste treatment. Further energy 
efficiency measures and installation of new el ectricity generation capacity can continue, as 
well as the restructuring of the electricity networks. 
However so far most of the ener gy sector objectives, consequentia l to the closure, have been 
met. It has allowed for the concerned Member  States to have sufficient additional EU 
financed capacity at peak load conditions , allowing for coping with the normal network 
operations. Moreover it seems that, given the period since the early closures as well as the risk 
of distortion of competition in the field of en ergy efficiency measures, network upgrading and 
building of new electricity ge neration capacity, this funding window should not be further 
considered. The business as us ual option has to be excluded also for the following reasons; 
– further EU support to projects in the en ergy sector would lead  to distortion of 
competition and 
– a continuing high level of financial suppo rt to decommissioning would not be a 
sufficient incentive for the concerned Member States to gradually take over full financial responsibility and ownershi p of the decommissioning project. 
The position to terminate funding for energy projects was clearly supported by the European 
Parliament. 
Strengths: 
– supports continuation of immediate 
decommissioning 
– make it impossible to restart the reactors 
– use of available expertise and historical 
memory 
– more economic approach 
– reduce unemployment by using own skilled Opportunities: 
– contribution to increased nuclear safety 
– actual progress with de-fuelling and 
dismantling works 
– better check on the optimal advancement of 
the decommissioning  
– further support of measures in the energy 
sector  
 
EN 25   EN staff when immediate dismantling  
– international expertise coming in through the 
EU funding approval process  
Weaknesses: 
– EU rather than national funding 
– further EU support at a high funding level 
– polluter pays principle less applied  Threats: 
– continuous request for full funding 
– sub-optimal allocation of resources (energy 
sector) 
– double funding in the energy sector 
– distortion of competition and preferential 
treatment (EU financing of 20-20-20 targets)  
Option 3: EU partial financ ing of decommissioning only 
Option 3 reflects a clear political will of the Commission to gradually ph ase out the financial 
EU assistance for decommissioning  in the three Member Stat es. Limited support only to 
decommissioning also excludes the threats iden tified for option 2. Meeting the programme 
objectives with option 3 requires however a full commitment of th e Member States to provide 
the required additional financial resources to met the costs to completion of safe 
decommissioning. 
Under option 3 €50014 million would become fully available for decommissioning. This 
would support the continuation of safe  decommissioning beyond 2013, bring the 
decommissioning process to an irreversible stag e and at the same time stimulate a stronger 
own financial effort by the bene ficiary Member State itself. 
The main funding data related to the decommissi oning of the nuclear power  plants in the three 
Member States is summarised in the table below. The data is based on the updated estimations of total costs for decommissioning and of remaining funding needs beyond 2013 to complete 
the decommissioning as provi ded by the Member States. 
[€ million] Lithuania Slovakia Bulgaria Total 
Decommissioning cost estimation (including 
waste management, MS data) 2 800 1 146 1 858 5 804 
EU support for decommissioning (by end 2013) 1 107 429 510 2 046  
Other financial support (national resources and 
other donors) 343 291 495 1 129 
Additional needs (beyond 2013, MS data) 1 350 426 853 2 629 
Proposed additional EU support 
At 2011 prices 210 105 185 500 
                                                 
14 Financial amounts are given in 2011 prices. 
 
EN 26   EN Remaining funding gap 1 140 321 668 2 129 
The total amount required for decommissioning of  the eight nuclear power plant units is 
estimated at €5 804 million. By the end of 2013  €3 175 million will have been put in place. 
Out of this amount, €2 046 million (64%) will be covered by the financial EU support. 
Member States and other donors will have  contributed by 2013 with additional €1 129 
million. 
The additional funds required beyond 2013 is estimated at €2 629 million. The proposed 
extension of the EU financial support by €500 million represents approximately 20% of the remaining funds to be provided. The reduction in the amount of the financial EU support for 
the next financial perspective takes due accoun t of the evolution si nce the three Member 
States have joined the EU. 
At the time of accession (2004 and 2007) the Me mber States were in a difficult economic 
situation. To allow for the early closure of the concerned nuclear power plants and to address 
the urgent needs of the Member States to address the economic consequences of closure as well as for starting preparation of decommissioning it was justif ied that the EU covers the 
major part of the funding needs. 
In the meantime, Member States  have established legal provis ions that should address the 
funding needs for decommissioning (ex. special levy on electricity prices).  Member States are 
also committed to bear their responsibil ity for the completion of decommissioning. 
Nevertheless, it cannot reasonably be expected (due to the reduced time of accumulation as 
explained above) that by 2013 the three Member St ates would be in a position to complete the 
decommissioning only by their own financial mean s. Therefore, the reduced amount of €500 
million of further EU support is considered to be reasonable to support the seamless continuation of the decommissioning  process and the transition to the full remaining financing 
by the Member States. 
The €500 million additional EU support shall be dedicated to support safety relevant 
activities. It is expected from the Member Stat es that they are ready to provide the required 
additional financing to cover the remaining funding gap (see table above) and to safely 
complete decommissioning in order to ensure e fficient and effective use of the additional EU 
support of €500 million. Slovakia and Bulgaria alr eady expressed their readiness to meet this 
expectation. 
Lithuania will have to make significant larger efforts to accumulate the needed funds. Not 
only that Lithuania started much later with making financial provisions for decommissioning 
but also the electricity prices in the past were extremely low and even after having increased 
the prices since two years, they  are currently still low (0.0955€/ kWh) as compared to Slovakia 
for example (0.1277€/kWh ). In addition prioritie s in the energy sector are more focused on 
security of supply and interconnections. Under the Commission proposals for the next financial framework Lithuania wi ll, at the same time, remain a major beneficiary of the 
Structural and Cohesion Funds, which will allow for continued support for catering for the economic and social consequences of decomm issioning. In addition, the Connecting Europe 
Facility proposed by the Commission will crea te major opportunities fo r Lithuania to upgrade 
and modernise its energy, tran sport and telecommunications in frastructure. This could free 
some national resources that could be re-d irected for providing the balancing funding of 
decommissioning. 
 
EN 27   EN With the additional €500 million the EU support dedicated to decommissioning as percentage 
of total estimated costs for decommissioni ng reaches around 44% (€2 546 million out of 
€5 804 million). 
Taking into account the overall total EU funds  committed to the three Member States until 
2013 (€2 848 million) plus the additional €500 million up to 2020, the total EU support as a 
percentage of total estimated costs for decommissioning approaches 58% . 
It has to be noted that the EU will have allocated by the end of 2013 around €802 million for 
mitigating measures in the energy sector, conseque ntial to the early closure out of the total EU 
support of €2 848 million. 
Beyond 2020 the Commission does not foresee any fu rther extension of financial EU support. 
 
Strengths: 
– reduced EU support (in amount and time) 
– provides time to establish more national 
financial means 
– supports continuation of immediate 
decommissioning 
– make it impossible to restart the reactors 
– use of available expertise and historical 
memory 
– more economic approach 
– reduce unemployment by using own skilled 
staff when immediate dismantling 
– international expertise coming in through the 
EU funding approval process  Opportunities: 
– contribution to increased nuclear safety 
– transition to full financial responsibility and 
ownership of the Member State 
– actual progress with de-fuelling and 
dismantling works 
– better check on the optimal advancement of 
the decommissioning  
Weaknesses: 
– still some EU support 
– polluter pays principle not fully applied  Threats: 
– Member States unable to provide the 
balancing funding to met the cost to completion of decommissioning 
– continuous request for full funding if no 
concrete milestones a nd boundary conditions 
for the EU funding would be set  
In summary, the impacts would be a contribution to the improvement of nuclear safety 
(options 2 and 3) with an accelerated defueling and decomm issioning under international co-
operation; versus a highly increa sed safety risk (under option 1), with EU wide effects in case 
of a possible accident, and possibly re-ope ning of potentially unsafe reactors. 
Option 3 would indeed have a hi gh added value as it would allow to advance significantly the 
decommissioning process in a safe  way, to improve sign ificantly nuclear safety and to provide 
at the same time a transition period for the Me mber States to gradually take over full 
ownership and financ ial responsibility. 
Delivery mechanisms 
 
EN 28   EN The administrative burden should be less than at present for all the three considered policy 
options.  Options 1  would not require any delivery mech anism, however the EU would then 
lack information on the continuation of  safe maintenance and decommissioning. 
In option 2 and 3 , there will be only a single legal base, and only one set of rules that apply to 
all three decommissioning funds. It is proposed  to have a national channel for Lithuania 
(mechanism C) , as the CPMA  is in place and have successfu lly managed several EU funding 
programmes over the past years. CPMA is lo cated in Lithuania and has therefore less 
overhead and administrative costs in the mon itoring process. For Bulgaria and Slovakia , 
where such a national implementing body does not ex ist, it is proposed to continue to use 
exclusively the EBRD . However given the absence of  continued funding from other 
international donors, and in order to streamline and to simplify, it is proposed to go through a 
dedicated decommissioning fund (mechanism B) . This would increase the decision making 
power and the influence of the Commission over the EU funding to attain objectives, and 
increase responsibility by suppressing a layer of decision making and approval procedures 
(the Assembly of Contributo rs – fund rules – specific rule s for tendering etc.). Both 
mechanisms B and C will strengthen the Commissi ons management role, in particular also 
when dealing with difficulties in project impl ementation. The combination of options B and C 
represent a natural evolution of the curr ent Commission Decision on Procedures and will 
improve the overall management of the programme regarding efficiency and effectiveness as recommended by the Europ ean Court of Auditors. 
The preferred option 
Option 2 (business as usual) has high costs an d only reduced added EU value. Option 1 (no 
further EU support) jeopardizes nuclear safety  with potential high negative impact on EU 
citizens and the environment. 
The main concern is that the financi ng for the continuous safe-maintenance and 
decommissioning needs to be available in a time ly manner. This is the crucial element for 
improving nuclear safety and the protection of all EU citizens. Whether the financing comes 
from EU or other funding sources, it is important to realise that all further impacts of safe 
maintenance and decommissioning itself are eq ual (impact on nuclear safety, radiological 
risks, other environmental risks, employment et c). In case no funding woul d be available, safe 
maintenance would be compromised. Loss of  unique expertise w ould render the whole 
decommissioning process, more difficult and costl y. It is equally important to have sufficient 
resources available to allow the conti nuation of the decommissioning process.  
EU partial financing for decommissioning only
 (option 3) is considered the most appropriate 
solution following a clear expressed political will . This option maximises the EU added value  
and supports the transition towards full Member State funding  of the safe completion of 
decommissioning beyond the next multiannual fi nancial framework. Option 3 provides for 
real improvement in nuclear safety  and will help to achieve timely real physical progress  in 
defueling and decommissioning and ensure  that the closure is irreversible . 
Option 3 combined with the implementation mechanisms  B (for Bulgaria and Slovakia) and C 
(for Lithuania) will provide for a continue d strengthening of the Commission’s management  
for the effective, efficient and economical us e of EU funds. The iden tified weaknesses under 
the current implementation mechanism (A) wo uld be overcome and it would reinforce the 
Commissions management possibilitie s to intervene more efficiently  in case of difficulties 
(delays and cost overruns) in the implem entation of decommissioning project by the 
 
EN 29   EN beneficiaries. The specific objectives being aligned with the propos ed budget and based on 
revised/updated decommissioning plans (needs expressed by the Member States) together 
with the meaningful performance indicators are the basis for achieving the expected benefits 
from the further financial EU support after 2013. This approach is in full accordance with the 
recommendations from the European Court of Auditors. 
7. MONITORING AND EVALUATION  
7.1. Core indicators of progress towards meeting the objectives 
In order to be able to verify the success of  the programme (meeting the general and specific 
objectives) SMART Objectively Verifiable Indicators  have been identified. Those 
indicators can also serv e to target the funding to wards tasks with the highest EU added value. 
At the same time, they allow to give a clear signal and incentive to the beneficiary Member 
States for them to advance efficiently a nd effectively on the vital parts of the 
decommissioning process. 
The Logical Framework Matrix (presented be low) provides an overview of the main 
programme parameters in terms of  objectives, outputs (re sults), activities, pertinent indicators, 
source of verifications and basic assumptions. 
At the current stage those indicators are gene ric to all three individual Programmes (Ignalina, 
Bohunice and Kozloduy Programme). For the implem entation it is foreseen to adopt one 
annual work programme for all three indi vidual Programmes specifying the objectives, 
expected results, related indicators and tim eline for the use of funds under each annual 
financial commitment. 
On a procedural level it is foreseen to a dopt not later than 31 December 2014 detailed 
implementation procedures for the duration of  the Programme. This decision shall also 
contain expected results, activities with the corresponding performance indicators, as well as 
the decommissioning plans for all three individu al Programmes that will serve as baseline for 
the monitoring of the progress and the timel y achievement of the expected results. 
A major precondition to ensure efficient use of the further EU support in meeting the 
objectives is the need for the three Member States to put in place by January 2014, a national 
legal framework to provide adequate provisions for the timely accumulation of national financial resources for the safe  completion of decommissioning.  
7.2. Broad outline for possible monitoring and evaluation arrangements 
The monitoring is based on the review of the identified i ndicators, measuring progress 
towards meeting the objectives. 
A revised Commission Decision on Procedures (s imilar to the current programme) will define 
all related procedural issues related to th e implementation of the extended EU financial 
support, amongst others also the monitoring an d reporting requirements. The EU monitoring, 
reporting and evaluation arrangements will contain at least: 
– Twice per year a monitoring committee meeti ng with EU on the spot to verify the 
advancement of the decommissioning works. 
 
EN 30   EN – Regular status and progress reporting from the beneficiary NPP as well as the 
implementing bodies (EBRD and CPMA). 
– Yearly combined programming documents, annexed to the Commission Decision on 
financing reporting progre ss towards decommissioning. 
– Status reports to the European Parliame nt and Council on the implementation of the 
financial EU assistance 
Additionally, a monitoring system should be put in place by the beneficiaries, allowing for 
active day-to-day monitoring of the projec ts and tasks, and allowing for immediate 
operational feedback into the planning with corrective measures. 
Regarding arrangements for evaluations it is  foreseen that no later than end 2016, an 
evaluation report shall be established by the Commission on the achievement of the objectives 
of all the measures (at the level of results and impacts), the efficiency of the use of resources 
and its European added value, in view of a decision on modi fication or suspension of the 
measures. The evaluation shall additionally addr ess the scope for simplification, its internal 
and external coherence, the con tinued relevance of all objectives , as well as the contribution 
of the measures to the Union priorities of smart,  sustainable and inclusiv e growth. It shall take 
into account evaluation results on the long- term impact of the predecessor measures. 
It is planned to perform ex-post evaluation in  close cooperation with the Member States and 
beneficiaries. The ex-post evaluation shall examine the effectiveness and efficiency of the Programme and its impact on decommissioning. 
Evaluations will take account of progress against identified performance indicators in the 
Regulation and the Work Programmes. 
 
 
LOGICAL FRAMEWORK MATRIX 
 Intervention logic Indicators Source of 
Verification Assumptions 
Overall 
Objective Support the Member 
States efforts in safe decommissioning. 
 Progress according 
decommissioning plan (tasks, costs, resources, 
timing); Decommissioning 
plan; 
Regular 
monitoring 
meetings; 
Reporting by NPP 
and national 
authorities; Stable political and 
regulatory framework; 
National funding 
forthcoming to meet the funding gap; 
Purpose To reach an 
irreversible state 
within the decommissioning 
process; 
To safely manage the 
spent fuel and 
radioactive waste; Dismantling according 
decommissioning plan; 
  
Waste management 
according detailed waste management plan Decommissioning 
and waste 
management plan; 
Regular reporting 
and monitoring 
meetings; Stable political and 
regulatory 
framework; 
No changes in 
decommissioning 
strategy; 
 
EN 31   EN To maintain the key 
expertise and 
knowledge; Use of staff from the nuclear 
power plants; 
Outputs 
(expected 
results) NPPs safely 
maintained; 
No environmental 
impact; 
Spent fuel safely 
stored; 
Nuclear waste safely 
stored; 
Decommissioning 
license in place; 
Design of 
core/primary circuit 
dismantling; 
Staff engaged on 
decommissioning; Nb of incidents/accidents; 
Environmental monitoring 
data; 
Nb of fuel elements stored 
and Nb of waste packages stored according to the 
planning; 
License issued according to 
the time schedule; 
Design completed in time; 
Nb of staff employed; 
Earned value analysis; Status and 
progress reports; 
Regular 
monitoring 
meetings; 
License issued by 
the regulator; 
Staff accountancy; Efficient NPP 
management structure for decommissioning 
established and fully 
operational; 
Efficient 
decommissioning 
planning in place; 
Operational feedback 
effectively used; 
No changes in 
decommissioning 
strategy; 
Proactive project 
monitoring function 
in place; 
Activities Safe maintenance; 
Defueling; Dismantling works; 
Radwaste treatment 
and conditioning; 
Licensing docs; 
Engineering design 
core/prim circuit dismantling; 
Staff training and 
reallocation; Planning of safe 
maintenance; 
Nb of fuel elements 
unloaded; 
Quantity of material/system 
dismantled; 
Quantity of rad waste treated 
and conditioned; 
Submission of licensing doc; 
Design feasibility and 
engineering studies; 
Nb of staff trained and 
reallocated; Status and 
progress reports; 
Regular 
monitoring 
meetings; 
Detailed 
decommissioning 
work plan; 
Operational 
feedback to NPP 
planning department; 
HR plan; Efficient NPP 
management structure for decommissioning 
established and fully 
operational; 
National funding 
forthcoming to meet 
the funding gap; 
Economic viability 
for using own NPP 
staff; 
 
EN 32   EN 8. ANNEXE 1: OVERVIEW OF 3 COUNTRIES BASIC DATA  
 LITHUANIA SLOVAKIA BULGARIA 
Type of reactor (and 
number) RBMK (2) VVER 440/230 (2) VVER440/230 (4)  
Capacity shut down 
early 2600 MWe nominal
average load factor before closure 70%Effective lost capacity = 1820 
MWe   880 MWe nominal
average load factor before closure 86,8%Effective lost capacity = 764 MWe  TOTAL 1760 MWe 
nominal Units 1to4 880MWe 
average load factor 
before closure 75%Effective lost capacity = 660 MWe 
(taken into account also upgrade of units 5-6 with 300 MWe) 
Lost years due to early closure compared to 30 years of operation 17 4 15 
Specific conditions / 
circumstances to be taken into account • 70 % of 
energy 
production shut down early 
• Isolation from 
EU grid • Electricity price 
already high at 
top of EU range 
• 10% of energy 
production shut 
down early 
• V1 NPP 
covered approx. 20% of electricity consumption 
• Slovakia 
became net 
importer of electricity after closure (exporter before) • Contribution 
nuclear to 
overall electricity production 45% before shutdown in 2002 of units 1&2 and 17% in 2007 after shutdown of units 3&4 
    
Total cost of decommissioning (waste 2800 MEUR 1 146 MEUR 1858 MEUR 
 
EN 33   EN man. incl.); 
Updates estimation by 
Member States 
Completion date for Decommissioning 2029 2025 2030 
    
International funding 
until 201415  1451 MEUR 636 MEUR 890 MEUR 
Of which already 
received EU funding up to 2014 1367MEUR 613 MEUR 850 MEUR 
Of which already 
received funding from other donors up to 2014
16 84 MEUR 23 MEUR 40 MEUR 
    
Existing National 
Funding  50 Mio € 230 MEUR 180 MEUR 
National budget 
provisions earmarked No Yes Yes 
    
Funding GAP 
Updated estimation by 
Member States 1350 MEUR 426 MEUR 853 MEUR 
Requested EU funding 770+580= 1350 
MEUR17 426 MEUR 450 MEUR 
Proposed EU funding 210 MEUR 105 MEUR 185 MEUR 
Required national 
funding  1110 MEUR 318.5 MEUR 700.5 MEUR 
    
                                                 
15 Including also other international donors and interest 
16 Including international donors and accumulated interest 
17 €770 million for the period 2014-2020 and additional €530 million for the period 2021-2028 
 
EN 34   EN Key milestones with 
specific EU added value or interest    
• Closure Reached Reached Reached 
• Core defueling 2009/2013 Reached Reached 
• Reactor building 
defueling 2016/2017 Reached U1&2 reached 
U3&4 to be reached 
end 2011 
• Decommissioning 
licence Ongoing – building 
wise licensing approach Reached for phase 1 U1&2 end 2011 
U3&4 end 2012 
• Primary circuit 
decontamination Started for unit 1 December 2012 2027 
• Dismantling 
turbine hall 2016/2017 2015 2020 
• Commission of a 
national repository for low and intermediate radioactive waste 2018 2015 End 2015 
• Primary circuit 
(incl. RPV) 
dismantling 2022/2023 August 2020 Units 1&2 end 2024 
Units 3&4 end 2028 
 
 
EN 35   EN 9. ANNEXE 2: FULL DECOMMISSIONING PLANS FOR LT,  SK,  BG 
9.1. Annexe 2.1: Detailed decommissioning plan – Lithuania 
 
 
EN 36   EN 9.2. Annexe 2.2: Detailed decommissioning plan – Slovakia 
 
 
EN 37   EN 9.3. Annexe 2.3 Detailed decommissioning plan – Bulgaria 
 
 
EN 38   EN 
 
 
EN 39   EN 
 
 
EN 40   EN 10. ANNEXE 3: CONCLUSIONS OF PREVIOUS /ONGOING AUDITS  
Conclusion of mid term eval uation Slovakia and Lithuania  
The mid term evaluation for Slovakia and Lithuani a showed that a majority of the projects has 
been well implemented in so far as the results match the objectives. The costs of the projects, 
to the extent that it could be assessed within the evaluation, are fair when compared to the 
results.  
The following provides an extract of the recommendations : 
• That the EC develops a consistent st rategy with goals and criteria for the 
decommissioning assistance programme(s), against which any ongoing and future 
assistance could be judged and evaluated. 
• Ensure that any assistance provided is consistent and complementary with the 
national activities (implemented via na tional decommissioning funds and/or other 
national means). 
• With the consideration that the conceptu al decommissioning plans for both Bohunice 
and Ignalina were devel oped and decommissioning strategies selected in both 
countries, a more accurate estimate of actual decommissioning and related energy 
sector costs (against which the needs for financial assistance commitments could then be assessed) should be developed. 
• In light of the changing framework conditions, it is suggested to carry out an 
assessment to identify an optimal vehicle for providing assistance in the future. 
Preliminary recommendations of European Co urt of Auditors performance audit (2011)
 
(a) The Commission should put in place the c onditions for an effective, efficient 
and economical use of EU funds. To this effect: 
• It should establish a detailed needs assessment showing the progress of 
the programmes so far, the activities still to be performed and an overall 
financing plan identifying the f unding resources from the different 
stakeholders. 
• Before further spending takes place,  the Commission should analyse the 
resources available and the expected be nefits. This should lead in turn to 
objectives being aligne d with the budget made available and to the 
establishment of meaningful indica tors, which can subsequently be 
monitored and reported on as necessary for the programme implementation as a whole. 
(b) Should the EU decide, as proposed by the Commission, to provide further 
financial assistance in the next multi -annual financial framework, this support 
should be based on an ex-ante evaluati on of the EU added value of such 
intervention, identifying the specific ac tivities to be financed through the EU 
 
EN 41   EN budget, taking account of other funding fac ilities such as Structural Funds and 
the conditions for EU disbursements.