COMMISSION STAFF WORKING DOCUMENT Accompanying the document Proposal for a Council Regulation establishing a dedicated financial programme for decommissioning of nuclear facilities and management of radioactive waste, and repealing Council Regulation (Euratom) No 1368/2013
Date: 2018-06-13
Institutions: Directorate-General for Energy, European Commission
Subjects: Bulgaria, EU programme, Slovakia, decommissioning of power stations, financial aid, nuclear power station, nuclear safety, radioactive waste, storage of waste, waste disposal

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 13.6.2018  SWD(2018) 343 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document Proposal for a Council Regulation establishing a dedicated financial programme for decommissioning of nuclear facilities and management of radioactive waste, and repealing Council Regulation (Euratom) No 1368/2013  {COM(2018) 467 final}  
 
 
1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ..................................... 3 

1.1.  Scope and context ......................................................................................................... 3 
Kozloduy programme and Bohunice programme ............................................................ 5 

1.1.1. 

1.1.2. 

JRC decommissioning and waste management programme ............................................ 8 

1.2.  Lessons learned from previous programmes .............................................................. 11 
Kozloduy programme and Bohunice programme .......................................................... 11 

1.2.1. 

1.2.2. 

JRC decommissioning and waste management programme .......................................... 13 

2.  THE OBJECTIVES ................................................................................................... 15 

2.1.  Challenges for the programmes of the next MFF ....................................................... 15 
Kozloduy programme (BG) and Bohunice programme (SK) ........................................ 15 

2.1.1. 

2.1.2. 

JRC decommissioning and waste management programme .......................................... 16 

2.2.  Objectives of the programmes of the next MFF ......................................................... 19 
General objectives .......................................................................................................... 19 

2.2.1. 

2.2.2. 

2.2.3. 

2.2.4. 

Objectives of the Kozloduy and Bohunice programmes ................................................ 19 

Objectives of the JRC decommissioning and waste management programme .............. 20 

Common specific objectives .......................................................................................... 21 

3.  PROGRAMME STRUCTURE AND PRIORITIES ................................................. 23 

3.1.  Kozloduy programme and Bohunice programme ....................................................... 23 
JRC decommissioning and waste management programme ....................................... 24 
3.2. 

4.  DELIVERY MECHANISMS OF THE INTENDED FUNDING ............................ 25 

4.1.  Kozloduy programme (BG) and Bohunice programme (SK) ..................................... 25 
Policy option 1 - Discontinuation of the programmes .................................................... 26 

4.1.1. 

4.1.2. 

4.1.3. 

4.1.4. 

Policy option 2 - Programmes under cohesion policy .................................................... 26 

Policy option 3 - Programmes as dedicated spending programme ................................. 28 

Policy options benchmark .............................................................................................. 29 

4.2. 

JRC decommissioning and waste management programme ....................................... 29 

5.  HOW WILL PERFORMANCE BE MONITORED AND EVALUATED? ............ 30 

5.1.  Kozloduy programme and Bohunice programme ....................................................... 30 
Programming, monitoring and control system ............................................................... 30 

5.1.1. 

5.1.2. 

5.1.3. 

Performance indicators ................................................................................................... 31 

Preliminary evaluation criteria ....................................................................................... 32 

5.2. 

JRC decommissioning and waste management programme ....................................... 32 
Programming, monitoring and control system ............................................................... 32 

5.2.1. 

5.2.2. 

Performance indicators ................................................................................................... 33 

ANNEX 1: PROCEDURAL INFORMATION ................................................................ 34 

ANNEX 2: FUNDING ...................................................................................................... 35 

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BG 

D&WMP 

EBRD 

ECA 

ESIF 

ESSOR 

EVM 

HFR 

IAS 

ISPRA-1 

ISSG 

JRC 

KPI 

MFF 

NDAP 

Glossary 

Term or acronym 

Meaning or definition 

Republic of Bulgaria 

JRC decommissioning and waste management programme 

European Bank for Reconstruction and Development 

European Court of Auditors 

European Structural and Investment Funds  

Essai Orgel research reactor at JRC Ispra 

Earned Value Management 

High-flux research reactor at JRC Petten 

Internal Audit Service 

Research reactor at JRC Ispra 

Inter-service Steering Group 

Joint Research Centre 

Key Performance Indicator 

Multi-annual Financial Framework 

Nuclear Decommissioning Assistance Programmes,  
whereby the EU provides financial support to Lithuania to shut 
down and decommission two reactors at the Ignalina NPP, to 
Bulgaria to shut down and decommission four reactors at the 
Kozloduy NPP, and to Slovakia to shut down and decommission 
two reactors at the Bohunice V1 NPP. 

NPP 

Nuclear Power Plant 

'Radioactive Waste' directive 

Council Directive 2011/70/Euratom of 19 July 2011 establishing a 
Community framework for the responsible and safe management of 
spent fuel and radioactive waste 

SERAW 

SIEA 

SK 

VVER 

State Enterprise Radioactive Waste (BG) 

Slovak Innovation and Energy Agency 

Slovak Republic 

Water-Water Energetic Reactor is a series of pressurised water 
reactor designs originally developed in the Soviet Union. 

2 

 
 
 
 
1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

1.1. 

Scope and context 

The  present  ex-ante  evaluation  relates  to  the  funding  programme  for  financial  assistance  for 
"Decommissioning  of  Nuclear  Facilities  and  Management  of  Radioactive  Waste",  (the 
'programme') that addresses the decommissioning of nuclear facilities and the management of the 
arising waste under a common instrument to optimise synergies and knowledge sharing in order 
to secure meeting of relevant obligations. 

This ex-ante evaluation identify the following needs on a current basis: 

  The Kozloduy nuclear power plant units 1-4 (Kozloduy, Bulgaria) and the Bohunice V1 
nuclear  power  plant  (Jaslovské  Bohunice,  Slovakia)  consist  of  six  pressurized  water 
reactors originally developed in the Soviet Union (VVER 440). The decommissioning of 
these plants contributes towards increased nuclear safety in the region and in the EU as a 
whole. 

  The  Commission's  Joint  Research  Centre  (JRC)  owns  nuclear  research  installations  in 
four  sites:  JRC-Geel  in  Belgium,  JRC-Karlsruhe  in  Germany,  JRC-Ispra  in  Italy  and 
JRC-Petten  in  the  Netherlands.  Some  of  these  installations  are  still  in  use  today  while 
others  have  been  stopped.  The  JRC  is  responsible  for  the  decommissioning  of  these 
installations  and  for  the  safe  management  from  generation  to  disposal  of  the  resulting 
spent fuel and radioactive waste. 

Figure 1 – Decommissioning sites. 

3 

 
 
Given this making, the programme is naturally subdivided into: 

(i) 

(ii) 

the  two  programmes  providing  financial  support  to  Bulgaria  and  Slovakia  to  safely 
decommission  six  nuclear  reactors  at  the  Kozloduy  nuclear  power  plant  units1-4  and 
the Bohunice V1 nuclear power plant (respectively the 'Kozloduy programme' and the 
'Bohunice programme'); and 

the  programme  of  Joint  Research  Centre 
the 
decommissioning process and the management of the resulting radioactive waste of the 
Commission's own nuclear installations at the JRC sites (the 'JRC decommissioning and 
waste management programme', D&WMP). 

implementing  safely 

(JRC), 

This  ex-ante  evaluation  is  carried  out  in  preparation  of  the  next  MFF  and  it  is  based  on  the 
lessons learnt and progress achieved so far.  

4 

 
 
 
1.1.1.  Kozloduy programme and Bohunice programme 

The  Kozloduy  and  Bohunice  programmes  originated  in  the  context  of  the  negotiations  for 
accession  to  the  EU  of  Bulgaria  and  Slovakia,  which  took  the  commitment  to  close  and 
subsequently  decommission  their  old  Soviet-designed  nuclear  reactors  by  a  commonly  agreed 
date. The closure commitment of the two Member States as well as the commitment of the EU to 
provide  financial  support  was  foreseen  in  the  corresponding  Accession  Treaties1,2  (Slovakia 
acceded  in  2004;  Bulgaria  in  2007).  The  two  Member  States  and  the  EU  have  fulfilled  their 
respective Accession Treaty commitment.  

On  the  basis  of  Article  203  of  the  Euratom  Treaty3  and  to  ensure  continuity  of  safety  related 
measures, the EU provided financial assistance4,5 to the decommissioning of Bohunice V1 NPP 
beyond  the  timeframe  that  was  stipulated  in  Slovakia's  Accession  Treaty6.  Similarly,  following 
the  period  covered  by  Bulgaria's  Accession  Treaty7  the  EU  continued  providing  financial 
assistance5,8 for the safe decommissioning of the Kozloduy NPP Units 1-4. 

the  Internal  Audit  Service  (IAS) 

The  programmes  have  been  subject  to  extensive  audits  in  the  first  part  of  the  current  MFF:  an 
internal  audit  conducted  by 
three 
recommendations9,  all  implemented  to  date;  a  performance  audit  of  the  European  Court  of 
Auditors  that  issued  a  special  report10  resulting  in  eight  recommendations,  either  fulfilled  or 
under implementation according to the established plan. In particular, the recommendation no 5 
issued  by  the  European  Court  of  Auditors  (ECA)  calls  for  discontinuation  of  the  programmes 
after 2020 or transfer under other instruments (such as the European Structural Investment Funds, 
ESIF). Therefore, as per the reply provided by the Commission11, an assessment of policy options 
is presented in this ex-ante evaluation in order to examine if the existing instruments for support 
to Bulgaria and Slovakia should be: 

that  resulted 

in 

1  
2  
3  

4 

5  

OJ L236, 23.9.2003, p. 33 and p. 954 
OJ L157, 21.6.2005, p.11 and p. 38 
"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  Council  shall,  acting  unanimously  on  a  proposal  from  the 
Commission and after consulting the European Parliament, take the appropriate measures." (Article 203 Treaty 
establishing the European Atomic Energy Community) 
Council Regulation (Euratom) No 549/2007 of 14 May 2007 on the implementation of Protocol No 9 on Unit 1 
and Unit 2 of the Bohunice V1 nuclear power plant in Slovakia to the Act concerning the conditions of accession 
to  the  European  Union  of  the  Czech  Republic,  Estonia,  Cyprus,  Latvia,  Lithuania,  Hungary,  Malta,  Poland, 
Slovenia and Slovakia (OJ L 131, 23.5.2007, p. 1) 
Council Regulation (Euratom) No 1368/2013 of 13 December 2013 on Union support for the nuclear 
decommissioning assistance programmes in Bulgaria and Slovakia (OJ L 346, 20.12.2013, p. 1) 

7  

6    Article 2.1 "During the period 2004-2006, the Community shall provide Slovakia with financial assistance in 
support of its efforts to decommission and to address the consequences of the closure and decommissioning of 
Unit 1 and Unit 2 of the Bohunice V1 Nuclear Power Plant" ." (Act of accession, Protocol No 9 - OJ L954, 
23.9.2003) 
Article  30.2 "During  the  period  2007-2009,  the  Community  shall  provide  Bulgaria  with  financial  assistance  in 
support of its efforts to decommission and to address the consequences of the closure and decommissioning of 
Units 1 to 4 of the Kozloduy Nuclear Power Plant." (2005 Act of accession, Protocol Concerning the conditions 
and  arrangements  for  admission  of  the  republic  of  Bulgaria  and  Romania  to  the  European  Union  (OJ  L157, 
21.6.2005)) 
Regulation (Euratom) No 647/2010 of the Council of 13 July 2010 on financial assistance of the Union with 
respect to the decommissioning of Units 1 to 4 of the Kozloduy Nuclear Power Plant in Bulgaria (Kozloduy 
Programme) (OJ L 189, 22.7.2010, p.9) 
The recommendations concerned the assessment of ex-ante conditionalities, the control strategy, and the co-
financing. 

9  

10    ECA Special Report 22/2016 - EU nuclear decommissioning assistance programmes in Lithuania, Bulgaria and 

8 

Slovakia: some progress made since 2011, but critical challenges ahead. 

11    The  Commission's  reply  to  recommendation  5  ("Discontinue  dedicated  funding  programmes  for  nuclear 
decommissioning  in  Lithuania,  Bulgaria  and  Slovakia  after  2020")  of  the  ECA  Special  Report  22/2016  reads: 
"The  Commission  will  carry  out  an  impact  assessment  […]  with  regard  to  proposals  of  new  [nuclear 
decommissioning] initiatives. This impact assessment will explore whether funding should be continued and if so 
the most suitable financing mechanisms." 

5 

 
                                                            
(i) 

(ii) 

(iii) 

discontinued in the next MFF, or 

merged into the Funds under cohesion policy, or 

merged  in  a  combined  programme  including  the  decommissioning  of  JRC  sites 
(baseline option). 

Originally and until 2013 the European Union assistance was designed to support these Member 
States  both  in  their  efforts  to  shut  down  and  decommission  the  concerned  reactors,  but  also  to 
address  the  consequences  of  the  early  closure,  such  as  enhancement  of  security  of  supply  and 
energy efficiency. This has changed under the current MFF where the scope of the programmes 
was restricted to decommissioning activities only, i.e. on safety related measures. The disposal of 
spent fuel and radioactive waste in a deep geological repository was never part of the programme. 
This  shift  from  financing  a  complex  mix  of  energy  and  decommissioning  projects  towards  a 
dedicated and focused effort on decommissioning programmes resulted in increased effectiveness 
and efficiency. 

More  in  particular,  in  the  MFF  2014-2020  the  programmes  objectives  have  been  specified  as 
follows: 

Table 1: Specific objectives for MFF 2014-2020 

SPECIFIC OBJECTIVES 

Kozloduy programme 
and 
Bohunice programme 

  Dismantling of large components and equipment in the reactor 

buildings; 

  Dismantling in turbine halls and auxiliary buildings; 
  Safely managing the decommissioning waste in accordance with 

detailed waste management plans. 

implementation  procedures12  of 

The 
the  baseline 
(decommissioning  plans)  for  each  decommissioning  programme  up  to  the  respective  end-state 
and provided concrete targets per each specific objective of the current MFF. 

the  current  Regulation  established 

The European Union financial assistance has been implemented by indirect management13 since 
its inception. It has been made available through pillar assessed implementing bodies in the form 
of contributions: 

(i) 

(ii) 

to two International Decommissioning Support Funds14 managed by the European Bank 
for Reconstruction and Development (EBRD) since 2001; 

to  Slovak  Innovation  and  Energy  Agency  (SIEA)  for  the  Bohunice  programme  since 
2016, reflecting increased national ownership of the programme. 

The  total  financial  assistance  from  the  European  Union  to  the  two  Member  States  for  the 
decommissioning  of  the  concerned  reactors  as  well  as  for  mitigating  measures  in  the  energy 
sector until the end of 2020 sums up to EUR 1 992 million. Thereof EU assistance earmarked for 
decommissioning  of  the  six  reactors  until  the  end  of  2020  sums  up  to  EUR  1 446  million  (see 
Annex 2). 

12   Commission Implementing Decision of 7.8.2014 on the rules of application for the nuclear decommissioning 
assistance programmes for Bulgaria, Lithuania and Slovakia for the period 2014-2020 — C(2014) 5449 final 
13   Art 60 Regulation (EU, Euratom) No 966/2012 of the European Parliament and of the Council of 25 October 

2012 on the financial rules applicable to the general budget of the Union 

14   Kozloduy International Decommissioning Assistance Fund; 
Bohunice International Decommissioning Assistance Fund. 

6 

 
 
 
                                                            
As mentioned, for the two nuclear power plants the final decommissioning plans (baseline) were 
prepared in 201415. These plans set out the schedules, covering a timespan longer than the current 
MFF,  and  the  cost  estimates  for  the  decommissioning  activities  until  the  accomplishment  of  a 
well-established  end-state.  Funding  provided  in  this  MFF  is  fit  for  effective  and  efficient 
accomplishment of the related objectives. 

In  line  with  the  Rome  Declaration16,  the  EU  budget  should  enable  a  Europe  that  is  safe  and 
secure; this is a dimension where the nuclear decommissioning programmes have contributed so 
far and  may further contribute.  The  main positive impact to be  achieved by the programmes is 
indeed the progressive decrease of the level of radiological hazard for the workers, the public and 
the  environment  in  the  concerned  Member  States  but  also  in  the  EU  as  a  whole.  Nuclear 
decommissioning  and  waste  management  are  key  processes  of  a  modern,  clean  and  circular 
economy. 

Like all existing EU instruments the programmes need to undergo the EU value added test in line 
with  the  reflection  paper17  on  the  future  of  EU  finances.  As  reflected  in  the  list  of  options, 
consideration is hereby given whether the programmes remain indispensable or whether there is 
scope  for  merging  programmes  or  modifying  them  with  a  view  to  budgetary  flexibility  and/or 
simplification, which are other key principles underpinning the next MFF. The programmes' EU 
added  value  test  fits  into  the  lines  and  principles  drawn  by  the  Commission  in  its 
communication18 on a new, modern Multi-annual Financial Framework (MFF) post-2020. 

The programmes have taken the attention of both the European Parliament and the Council of the 
European  Union.  Both  bodies  intervened  specifically  on  the  Nuclear  Decommissioning 
Assistance Programmes (NDAP) after the publication of the dedicated ECA Special Report10. 

The European Parliament19 underlined that nuclear safety is of prime importance, not only for the 
Member States concerned but for the population in the whole Union and its neighbourhood and 
called upon the Commission to perform a thorough assessment of the needs for continuation of 
the  dedicated  funding  programmes  for  nuclear  decommissioning  in  Bulgaria  and  Slovakia 
beyond 2020. 

The  Council20  also  recalled  that  the  premature  closure  and  subsequent  decommissioning  of  the 
Soviet-designed  nuclear  reactors  in  Bulgaria  and  Slovakia  was  one  of  the  conditions  for 
accession  to  the  EU.  It  further  underlined  the  fact  that  this  condition  entailed  a  significant 
financial burden based on which the EU agreed to provide financial assistance, underscored the 
need  for  adequate  supporting  actions  for  the  decommissioning  of  the  concerned  nuclear  power 
plants  in  the  two  Member  States  to  ensure  successful  completion  of  the  decommissioning 
processes whilst maintaining a high level of nuclear safety, and noted that any potential new EU 
funding  beyond  2020  should  include  clear  rules  and  the  right  incentives  to  pursue 
decommissioning, with regard to both financing and timing. 

15   The definition of detailed decommissioning plans and the associated financing plans was a pre-condition (ex-ante 

conditionality) to the launch of the programme in the MFF 2014-2020. These plans describe in detail the 
decommissioning strategy, how the facilities will be safely dismantled, how radiation protection of workers and 
the public is ensured, how environmental impacts are addressed, how materials – radioactive and non-radioactive 
– are to be managed, and how the regulatory authorisation for the facilities and sites are to be terminated. 
16   Declaration of the leaders of 27 member states and of the European Council, the European Parliament and the 

European Commission (25 March 2017) 
http://www.consilium.europa.eu/en/press/press-releases/2017/03/25/rome-declaration/pdf 

17   Reflection Paper on the Future of EU Finances - COM(2017) 358 
18   Communication from the Commission to the European Parliament, the European Council and the Council - A 
new, modern Multiannual Financial Framework for a European Union that delivers efficiently on its priorities 
post-2020 - COM(2018) 98 final 

19   Committee on Budgetary Control "Report on the Court of Auditors’ special reports in the context of the 2015 

Commission discharge" (2016/2208(DEC)) 

20    Council conclusions on the ECA Special Report No 22/2016, adopted by the Council at its 3511th meeting held 

on 13 December 2016 (document n° 15534/16  ATO 68) 

7 

 
                                                            
1.1.2.  JRC decommissioning and waste management programme 

The JRC's D&WMP relates to nuclear facilities and spent fuel and radioactive waste owned by 
the Commission.  

The JRC was established under Article 8 of the Euratom Treaty: 

(1)  After  consulting  the  Scientific  and  Technical  Committee,  the  Commission  shall 
establish  a  Joint  Nuclear  Research  Centre.  This  Centre  shall  ensure  that  the  research 
programmes  and  other  tasks  assigned  to  it by  the  Commission  are  carried  out.  It  shall 
also ensure that a uniform nuclear terminology and a standard system of measurements 
are established. It shall set up a central bureau for nuclear measurements. 
(2)  The activities of the Centre may, for geographical or functional reasons, be carried 
out in separate establishments 

In application of this Article, Site agreements were signed during the period 1960-62 between the 
Community,  Germany,  Belgium,  Italy  and  the  Netherlands.  In  the  two  latter  cases  national 
nuclear  installations  were  transferred  to  the  Community.  An  infrastructure  geared  to  nuclear 
research was put in place at the four sites. Some of these installations are still in use today while 
others  have  been  stopped, in  some  instances  more  than  20 years  ago,  and  have  mostly  become 
obsolete.  

On  the  basis  of  Article  8  of  the  Euratom  Treaty,  the  JRC  has  to  manage  its  historical  nuclear 
liabilities  and  decommission  its  shut-down  nuclear  installations.  To  this  end,  a  budget  heading 
was  created  in  agreement  with  the  European  Parliament  and  the  Council.  The  Commission's 
objective  has  always  been  to  provide  sound  management  to  clear  Euratom's  nuclear  liabilities, 
part of which stem from the development of families of reactors at the start of the 1960s and the 
rest from research programmes on reactor safety.  

To  this  end  and  based  on  the  1999  Communication  of  the  Commission  "Historical  Liabilities 
Resulting  from  Nuclear  Activities  carried  out  at  the  JRC  under  the  Euratom  Treaty  – 
Decommissioning of obsolete Nuclear Installations and Waste Management" (COM(1999)114), 
the programme was initiated and a specific ad hoc budget line was created, in agreement with the 
European  Parliament  and  the  Council  (European  Parliament  Resolution  on  Historical  liabilities 
resulting  from  nuclear  activities  carried  out  at  the  JRC21).  Since  then,  the  Commission  reports 
regularly  to  the  Council  and  European  Parliament  on  the  progress  of  the  D&WM  programme, 
thereby providing an updated budget forecast (2004, 2008, and 201322). 

The aim of this ex-ante evaluation is to evaluate how the JRC could tackle best the challenges the 
D&WM programme currently faces. More specifically, there is a need for an appropriate level of 
flexibility and maximised effectiveness and efficiency. The ex-ante evaluation will also give the 
rational  for  the  projections  and  estimations  of  the  budgetary  needs,  and  address  the  risks 
associated with the programme implementation. 

21   European Parliament resolution on the communication from the Commission to the European Parliament and the 
Council on historical liabilities resulting from nuclear activities carried out at the JRC under the Euratom Treaty 
(COM(1999) 114 + C5-0214/1999 + 1999/2169(COS)) (OJ C 67, 1.3.2001, p. 167) 

22   Communication from the Commission to the Council and the European Parliament - Decommissioning of 

nuclear installations and waste management - Nuclear liabilities arising out of the activities of the Joint Research 
Centre (JRC) carried out under the Euratom Treaty, SEC(2004)621 final   
Communication from the Commission to the Council and the European Parliament - Decommissioning of 
Nuclear Installations and Management of Radioactive Waste: Management of Nuclear Liabilities arising out of 
the Activities of the Joint Research Centre (JRC) carried out under the Euratom Treaty, COM(2008)903 final 
Communication from the Commission to the Council and the European Parliament - Decommissioning of 
Nuclear Installations and Management of Radioactive Waste: Management of Nuclear Liabilities arising out of 
the Activities of the Joint Research Centre (JRC) carried out under the Euratom Treaty, COM(2013)734 final 

8 

 
 
                                                            
Scope of the D&WMP 

As nuclear operator under Italian, Dutch, German and Belgian laws, JRC is responsible in these 
four Member States for the decommissioning of these installations and for the safe management 
from generation to disposal of the resulting spent fuel and radioactive waste. 

Initially,  the  D&WM  programme  focused  on  the  so-called  "historic  liabilities",  mainly 
constituted  by Ispra's nuclear facilities that had ceased to operate  in the previous decades. This 
also included the historical waste present at the JRC sites. Currently the programme covers also 
the nuclear installations which will become obsolete in the future at all four JRC sites, including 
the  management  of  nuclear  material.  The  D&WM  programme  shall  contribute  to  the  JRC  host 
Member  States  national  programmes  in  their  implementation  of  the  Council  Directive 
2011/70/Euratom on the responsible and safe management of spent fuel and radioactive waste. In 
line with Article 7 of the Directive, JRC has the prime responsibility for the safe management of 
the spent fuel and radioactive waste that is generated from its operations. Therefore, the costs of 
the  management  of  these  materials  from  generation  to  disposal  including  the  disposal  of  spent 
fuel and radioactive waste in a final repository are included in the scope of the programme. 

To this end, JRC has re-assessed in detail its strategy, schedule and budget needs for the future. 
The revised tentative timeframe as of 2017 indicates that: 

(i) 

at JRC Ispra, decommissioning is ongoing and will be completed by 2038; 

(ii) 

at  JRC  Petten,  the  JRC-owned  High-Flux  Reactor  (HFR)  is  operated  by  a  private 
company  and  is  today  one  of  the  major  producers  of  some  medical  radioisotopes.  It  is 
also used in the frame of R&D (by JRC and Member States). Decommissioning will start 
under  the  responsibility  of  JRC  after  the  shut-down  of  the  reactor.  This  will  certainly 
happen once a replacement reactor will be available (shutdown foreseen in 2025, when 
the new Dutch research reactor (PALLAS) is expected to be operational according to the 
Article 41 notification for new investment received by the Commission from the Dutch 
authorities); 

(iii) 

at JRC Karlsruhe, nuclear R&D operation will normally continue on long-term until the 
end of the site lease contract in 2059. However, three nuclear laboratory buildings will 
successively get obsolete and be decommissioned, starting in 2025;  

(iv) 

at JRC Geel, nuclear R&D operation will normally continue on long-term until the end of 
the site lease contract in 2060. 

In  line  with  the  reflection  paper  on  the  future  of  EU  finances,  the  JRC  has  undergone  the  EU 
value  added  test.  Having  the  responsibility  for  the  safe  management  of  its  own  spent  fuel  and 
nuclear waste in the four host Member States, the D&WM programme remains indispensable for 
the fulfilment of the Commission's obligations as licence holder23 of these facilities. By releasing 
as  soon  as  possible  any  obsolete  nuclear  research  facilities  free  of  radiological  constraint,  it 
contributes to a Europe that is safe and secure and sets a good benchmark across Europe for the 
safe and responsible management of radioactive waste and spent fuel. The timely completion of 
this process though is highly dependent on the host Member State. 

23  

JRC is owner and/or license holder for the operation of the nuclear facilities in Ispra, Karlsruhe and Geel. The 
current license holder for the operation of the nuclear facility in Petten is the private company NRG (medical 
radioisotope production), but as owner of the facility the JRC is liable for decommissioning and waste 
management. 

9 

 
                                                            
Implementation and Financing 

As nuclear operator under  Belgian, Dutch, German and Italian laws, the Commission is legally 
obliged to provide for, and maintain, adequate financial and human resources necessary to fulfil 
its  obligations  with  respect  to  nuclear  safety  of  a  nuclear  installation  (Article  6  of  Directive 
2009/71/Euratom). In addition, the Commission as licence holder23 has the prime responsibility 
for  the  safety  of  spent  fuel  and  radioactive  waste  management  of  the  facilities  and/or  activities 
that fall under its responsibility (Article 7 of Directive 2011/70/Euratom). 

Therefore,  the  D&WM  programme  is  implemented  by  direct  management,  under  the 
responsibility  of  JRC;  outsourced  services  and  supplies  are  financed  by  an  ad  hoc  budget  line 
specifically  created  for  this  purpose  by  agreement  between  the  Council  and  the  European 
Parliament. However, this budget line cannot be used for administrative expenses (e.g. staff costs, 
technical experts) which represent an important part of the decommissioning process. As a result, 
the human resources necessary for the implementation of the programme (for  management  and 
supervision)  have  been  so  far  funded  through  the  Euratom  Research  and  Training  framework 
programme. 

The timely completion of the D&WM programme is highly dependent on the host Member State. 
Moreover, in light of the  expected  increase of decommissioning activities  at the different sites, 
continuing financing decommissioning staff from the Euratom Research and Training framework 
programme bears the risk of penalising the overall JRC's research work programme in the future. 
Therefore,  the  Commission  services  have  extensively  worked  with  JRC  to  identify  options  to 
further  improve  the  management  and  governance  in  implementing  the  programme.  In  the  long 
term, a handing over of JRC nuclear facilities including nuclear material would present financial 
and  legal  benefits  for  JRC  –  it  would  ensure  that  the  JRC  would  cease  to  be  responsible  for 
decommissioning and waste management, would no longer bear the associated costs and it would 
release  JRC  from  its  obligations  as  nuclear  operator.  Should  the negotiation  with  host  Member 
states encounter difficulties, the JRC will nevertheless ensure sufficient personnel, to carry out in 
an  appropriate  and  safe  way  its  decommissioning  activities  and  fulfil  its  legal  obligations  also 
with regard to waste management.  

Since  its  launch  in  1999,  the  D&WM  Programme  will  have  consumed  EUR  535  million  of 
operational credits by 2020. Pre-decommissioning activities have been pursued under the current 
licenses, following the granting of ad hoc authorisations by the national Safety Authorities. The 
greatest part of the budget however has been spent for maintaining the safety of the shut-down 
nuclear installations in Ispra, for building up the waste management infrastructures in Ispra, and 
for  the  management  of  JRC's  nuclear  material  and  waste  (see  section  2.1.2).  This  includes  the 
mandatory payments for the ongoing construction of the German repository. 

The  JRC  is  regularly  reviewing  the  progress  and  performance  of  the  programme  using 
independent  external  advice  (D&WM  programme  Expert  Group,  external  consultants).  The 
programme  has  made  important  progress  and  achievement  since  its  launch.  The  programme  is 
also  audited  by  the  EC  Internal  Audit  Service.  Following  the  recommendations  from  the  last 
audit,  JRC  has  revised  the  decommissioning  planning  and  determined  expected  costs  for  each 
JRC  site  using  a  harmonised  approach,  based  on  recent  international  recommendations  for 
estimation of decommissioning costs. The new strategy and budget forecast was reviewed by the 
D&WM  Programme  Expert  Group  and  received  a  positive  opinion  in  2017.  Still,  significant 
uncertainties affect the timelines and the cost estimate for the different sites. 

In light of the financial uncertainties and the risk to penalise JRC's research work programme in 
the  future,  an  instrument  which  fully  covers  the  JRC  D&WM  programme  including 
administrative costs is fundamental.   

10 

 
 
1.2.  Lessons learned from previous programmes 

1.2.1.  Kozloduy programme and Bohunice programme 

A mid-term evaluation of the NDAP was conducted pursuant to Article 9 of the relevant Council 
Regulation5,  and  in  line  with  the  Better  Regulation  guidelines.  The  mid-term  evaluation 
considered  and  assessed  the  results  and  impacts,  the  efficiency  of  the  use  of  resources  and  its 
Union  added  value.  The  evaluation  focused  on  the  period  2014-2017  but  considered  where 
relevant the previous financial framework (2007-2013). 

For  the  mid-term  evaluation  the  Commission  gathered  relevant  information  and  data  by 
extensively  involving  key  stakeholders  (i.e.  Ministries,  implementing  bodies,  decommissioning 
operators, members of the NDAP Committee).  

Moreover,  an  Open  Public  Consultation  was  launched  by  the  Commission  in  June  2017  for  an 
extended  duration  of  14  weeks.  The  consultation  received  limited  interest  (20  responses).  In 
addition  to  this  consultation,  a  targeted  e-survey  consultation  was  launched  in  July  2017;  it 
gathered  an  additional  17 responses  (1  from  Bulgaria,  4  from  Lithuania  and 12  from  Slovakia) 
from  90  stakeholders  contacted  in  total.  The  replies  received  were  overall  positive  about  the 
NDAP  but  did  not  provide  any  additional  input  on  the  programmes.  These  two  consultations 
were complemented with targeted consultations of around 100 interviews with decommissioning 
operators and relevant stakeholders. 

The conclusions of the NDAP mid-term evaluation can be summarised as follows: 

Coherence  with  EU  policies.  The  mid-term  evaluation  concluded  that  the  NDAP  are  coherent 
with  EU  policies  aiming  at  ensuring  the  highest  level  of  nuclear  safety.  The  EU  support 
through the NDAP ensures that the immediate dismantling  strategy in Bulgaria and Slovakia is 
steadily  pursued  and  prevents  that  undue  burden  is  transferred  to  future  generations,  while  it 
partially  derogates  for  historical  reasons  to  the  ultimate  responsibility  of  the  Member  States  to 
ensure  adequate  financial  resources  for  nuclear  decommissioning  and  radioactive  waste 
management. The decommissioning strategy in Bulgaria was modified in 2013 in preparation for 
the current MFF: the resulting plan advanced the end date of the programme by seven years from 
2037 to 2030. 

Progress.  In  line  with  expectations  set  for  the  MFF  2014-2020,  Bulgaria  and  Slovakia  have 
progressed  effectively  and  efficiently  in  the  decommissioning  of  their  reactors  in  line  with 
the agreed baseline (decommissioning plans). There have been challenges and setbacks due to the 
programmes' complexity, but the management system has proven increasing ability to cope with 
them. Roadblocks from the previous financial framework have been removed and delays carried 
over were recovered to the extent possible. 

Safety. The analysis demonstrated also that substantially improved levels of safety are going to 
be  achieved  at  the  sites  as  a  result  of  the  Union  funding  in  this  MFF.  Major  ongoing 
developments in the field are: 

 

in Bulgaria the construction of the disposal facility for low level waste, the management 
of legacy waste, and decontamination and dismantling works in the reactor buildings; 

 

in Slovakia the finalisation of the reactor cores dismantling. 

Financial  scope.  The  preparation  and  endorsement  in  2014  of  the  respective  decommissioning 
plans was a  major  milestone and clarified  scope, schedule, and budget of the decommissioning 
programmes.  Between  2014  and  2016,  the  Commission  has  analysed  these  baselines  and 
concluded that they are based on complete and comprehensive plans, and on sound overall cost 
estimates which could be improved by considering a higher level of contingencies (max 16%). In 
2017,  the  cost  estimate  until  the  decommissioning  end-state  was  confirmed  for  the  Bohunice 

11 

 
the  Kozloduy  programme 

programme,  whereas  for 
the  organisation  responsible  for 
decommissioning, State Enterprise Radioactive Waste (SERAW),  has produced  a draft updated 
cost estimate as part of the compulsory triannual review foreseen under the Bulgarian legislation, 
which  claims  a  headline  increase  (+17%)  in  decommissioning  cost  and  contingencies.  This 
increase of cost estimates does not affect the current MFF and, as per the information currently 
available, is not linked to any extension of the programme scope and the programme end date is 
confirmed. Bulgaria has increased the national contribution so that the residual financing gap is 
about  EUR  92  million.  At  this  point  in  time  the  cost  revision  has  not  been  yet  agreed  by  the 
Commission; Bulgaria needs to provide full justification of the revised cost estimates. The formal 
revision process should be completed in 2018 in the context of the adoption of the new detailed 
implementation procedures as per Articles 7 and 9 of the relevant Regulation5 add will be taken 
into account during the negotiations for the next programming period. 

In both Bulgaria and Slovakia, the residual financing gap beyond 2020 is in the range of EUR 80-
90 million per Member State.  

National  contribution.  The  mid-term  evaluation  showed  that  the  achieved  levels  of  national 
contribution  appear  fit  to  sustain  proper  efficiency;  nonetheless  co-financing  is  not 
established in the legal basis, thus creating uncertainties that should be removed. Moreover, the 
analysis showed that increasing levels of national contribution are a necessary but not sufficient 
condition  to  set  the  right  incentives  for  timely  and  efficient  decommissioning.  To  this  end,  the 
explicit  transfer  of  risks  (cost  overruns,  delays)  to  the  concerned  Member  States  would  have  a 
greater  impact.  This  practice  has  been  already  introduced  to  a  certain  extent  under  the  current 
MFF where possible. 

Governance. The governance setup has ensured effective and efficient implementation of the 
programmes  and  compensated  for  the  uncertainties  mentioned  on  the  national  contribution 
aspects. Main factors of success were clear definitions of roles and responsibilities as well as a 
strengthened  monitoring  framework.  The  analysis  has  also  identified  areas  for  further 
improvement such as: 

(i) 

increased  involvement  of  the  Member  States  (programme  coordinator)  for  increased 
ownership together with stronger accountability of the decommissioning operators (final 
beneficiaries); 

(ii) 

streamlining of procedures to enhance the timeliness of the management cycle; 

(iii) 

increased inter-comparability of the programmes' performance. 

Objectives.  The  mid-term  evaluation  confirmed  that  the  programmes  objectives  of  the  NDAP 
(see  Table  1)  remain  valid  in  the  current  MFF.  Nevertheless,  some  of  the  expected  results, 
milestones, target dates, as well as the corresponding performance indicators should be adapted 
in line with the latest updates of the decommissioning plans to allow for effective monitoring for 
the period 2018-2020. 

Although  the  reduction  of  the  ultimate  risk  to  the  general  population  posed  by  these  facilities 
while  ensuring  that  the  decommissioning  is  conducted  in  a  safe  manner  have  been  the  driving 
factors  behind  the  NDAP,  the  mid-term  evaluation  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  (e.g.  reporting  to  the  Council  and  the  Parliament).  Any  post-2020 
funding  should  therefore  focus  on  explicit  safety  objectives  monitored  by  means  of  dedicated 
performance indicators. 

12 

 
Knowledge gain. Finally the  mid-term  evaluation has highlighted that the experience gained  so 
far  from  the  projects  implemented  under  the  Kozloduy  programme24  and  the  Bohunice 
programme25  provide  a  solid  base  of  knowledge 
the  EU  for  conducting  future 
decommissioning programmes of VVER type reactors (e.g. Czech Republic, Hungary, Germany, 
Finland). These EU co-funded programmes (including the Ignalina programme in Lithuania) may 
aim at becoming a solid benchmark for governance related issues and management practices such 
as cost estimation methodologies or planning. 

in 

1.2.2.  JRC decommissioning and waste management programme 

Under the current legal framework, a mid-term evaluation is not mandatory. The JRC is regularly 
reviewing  its  progress  and  performance,  using  independent  external  advice  (D&WMP  Expert 
Group, external consultants). Due to the high inherent risks of the D&WM programme, such as 
the  risk  of  delays  and  resourcing  risks,  the  programme  has  been  selected  for  two  audits  by  the 
Internal Audit Service (IAS) during the current MFF, one of which has been launched recently.  

The  main  outcomes  and  recommendations,  as  well  as  their  follow-up  by  JRC,  are  summarised 
below. These recommendations together with those from the group of experts should further help 
JRC to improve the performance of its programme.  

Continuous technical advice by the D&WM Expert Group 

In  managing  the  D&WM  programme,  the  JRC  is  regularly  advised  by  a  group  of  independent 
European  decommissioning  experts  (biannual  meetings  and  additional  ad-hoc  meetings).  Their 
advice  relates  to  the  decommissioning  and  radioactive  waste  treatment  strategy,  the  available 
technology, technical aspects of the organisation and any other aspects relating to the programme 
(see section 5.2.1). 

Findings from external reviews and past audits 

The progress of the programme and its budget is periodically reviewed by external experts. Back 
in 2011, the experts found overall evidence that the activities on the different sites were on track, 
despite  some  delays,  and  that  the  plans  and  cost  estimates  for  future  decommissioning  were 
established  in  a  coherent  way.  Nevertheless,  several  uncertainties  and  risks  were  identified, 
which to a large extent were related to the long-lead times involved: figures were considered in 
many  cases  based  on  best  estimates,  with  no  or  only  few  provisions  to  cover  for  uncertainties, 
particularly for the projects planned in the longer term (i.e. after 2020). The experts emphasised 
the  importance  of  assessing  in  detail  the  expected  amounts  of  waste,  and  encouraged  JRC  to 
investigate  managerial  and  technical  measures  which  should  be  taken  in  order  to  limit  waste 
volumes and to reduce to the extent possible any uncertainties on the costs related to their future 
disposal.  

In  2014/2015,  the  IAS  audited  the  financial  aspects  of  the  D&WM  programme26.  It  concluded 
that  the  current  operational  set-up  provides  reasonable  short-term  assurance  for  achieving  the 
JRC's objectives. However, such a short-term assurance is not enough for covering the needs of 
such  a  long-term  complex  programme.  Among  other  recommendations,  IAS  confirmed  the 

25  

24   At  Kozloduy,  for  example, the  Plasma  Melting  Facility represents  a  state-of-the-art equipment to  achieve  very 
high  volume  reduction  of  radioactive  waste.  It  is  the  second  application  in  the  domain  of  nuclear  waste 
management in the world. Demand for such cost-effective technologies can be expected to grow in coming years. 
JAVYS – the decommissioning operator and final beneficiary in Slovakia  – has included as an objective in its 
organizational  strategy  the  leverage  of  gained  experience  into  future  commercial  opportunities.  So  far  the 
company  has  acquired  on  the  international  decommissioning  market  contracts  in  the  area  of  radioactive  waste 
management with the Czech company ČEZ (NPPs Dukovany and Temelín) and for the Italian company SOGIN 
(NPP Caorso). 

26   Audit on Nuclear Decommissioning and Waste Management Programme at the JRC – Financial Aspects, IA – 14 

– 06 (224); Final Report (Ares(2015)2299901) 

13 

 
                                                            
necessity of regular in-depth assessments, with focussed review of the decommissioning budget, 
paying  special  attention  to  the  assessment  of  fixed  costs  and  to  the  improvement  of  current 
estimates (Very Important Recommendation). IAS also looked at the mid-term planning needs in 
the field of human resources. 

Recent improvements 

Following these consistent recommendations for improving the cost estimates, and in light of the 
new  strategy  2017  (see  section  1.1.2),  JRC  sites  with  the  support  of  external  consultants,  re-
assessed  in  more  detail  their  waste  inventory  and  revised  their  decommissioning  planning.  A 
harmonised  approach,  based  on  recent  international  recommendations  for  estimation  of 
decommissioning  costs,  has  been  applied  to  determine  expected  costs  on  each  site.  The  new 
budget  forecast  (as  of  December  2017)  includes  contingencies,  depending  on  the  level  of 
uncertainty  associated  with  the  respective  activities  and  the  external  conditions  at  the  different 
locations. The new strategy and budget forecast was reviewed by the D&WM Programme Expert 
Group  and  received  a  positive  opinion  at  the  end  of  the  process.  Still,  significant  uncertainties 
affect the timelines and the cost estimate for the different sites, inherent to the long-lead times for 
nuclear decommissioning and delays caused by the host Member State. 

New IAS Audit  

The IAS has launched a new audit on the D&WM programme implementation27. A draft Scoping 
Memo has been received on 13 March 2018. One of the main risks identified is in relation to the 
evolution  of  the  planned  activities  in  the  period  2021-2060,  which  does  not  appear  compatible 
with  flat  budget  allocations  as  noted  in  JRC's  updated  strategy.  The  increase  of  operational 
D&WM  programme  activity  covering  multiple  JRC  sites  will  also  impact  the  overall 
management strategy and need of internal JRC resources. The variable and unpredictable level of 
expenditures makes it difficult to manage the budget.  

Moreover, the dedicated D&WM budget line cannot be used for administrative expenses. In light 
of the expected increase of decommissioning activities at the different sites, continuing financing 
decommissioning staff from the Euratom Research and Training framework programme bears the 
risk  to  penalise  JRC's  research  work  programme  in  the  future.  The  current  trend  of  the 
Commission to reduce staff as well as the fact that the D&WM relies heavily on intra-muros is 
also conflicting with the need to ensure knowledge transfer on long-term.  

Other  risk  factors  identified  are  related  to  the  additional  costs  due  to  delays,  the  complexity of 
contracts to be managed, the difficulty of implementation of such a multi-site programme and the 
operational consequences of the long-term risk factors. 

The final Audit Report is expected in mid-2018. The findings of the IAS will further help JRC to 
improve programme performance in the future. 

27   Launch of the 2018 IAS Audit on Nuclear Decommissioning and Waste Management Programme 
implementation in DG JRC, as notified in the Announcement Letter (Ares(2017)5064966) 

14 

 
 
 
                                                            
2. 

THE OBJECTIVES  

1.3.  Challenges for the programmes of the next MFF  

The  key  aim  in  nuclear  decommissioning  is  the  progressive  removal  of  hazards  inherently 
associated to the concerned installations. This process is stepwise in nature, mainly because the 
removal of major batches of radioactive materials is obtained over several stages. The reduction 
of the safety measures and associated costs evolves likewise. 

The key aim of the programmes is the progressive removal of hazards inherently associated to the 
concerned  installations,  however  the  programmes  face  different  challenges.  The  differences 
mainly originate from the type of nuclear facilities covered, and the respective responsibilities of 
the Commission. 

1.3.1.  Kozloduy programme (BG) and Bohunice programme (SK) 

At  this  point  in  time  the  decommissioning  operators28  are  focussing  on  dismantling  activities. 
Slovakia has advanced the most and is currently carrying out decontamination and dismantling in 
the reactor building at the Bohunice site, while in Bulgaria at the Kozloduy site decontamination 
and  dismantling  are  well  advanced  in  the  auxiliary  buildings  and  have  started  in  the  reactor 
buildings.  

These programmes are on track to accomplish the specific objectives with the funding provided 
in  the  current  MFF  (2014-2020)  and  a  clear  trend  towards  increased  efficiency  was  observed 
throughout the monitoring activities as confirmed by independent experts29. 

Safety challenges 

Progress in the implementation of the Kozloduy and Bohunice programmes in the current MFF 
(2014-2020) has led already to a significant decrease in radiological hazard to the general public, 
because the most important sources of radiological hazards are tackled in the current MFF (e.g. 
decontamination  and  dismantling  of  the  reactor  primary  cooling  circuits  and  cores,  and 
completion  of  waste  management  routes).  Technical  and  technological  challenges  have  been 
coped with successfully thus far. For the future challenges, knowledge sharing and synergies are 
key to ensure continued success, provided that the reactors are of the same model. 

The availability of financing in a timely manner is a crucial element for ensuring nuclear safety 
and  the  protection  of  the  workers  and  the  EU  citizens.  In  case  of  insufficient  funding,  delays 
could  be  incurred  with  subsequent  extra-costs,  safety implications  and  increased  risk  of  loss  of 
unique expertise. 

In case of continuing the programmes after 2020 in Bulgaria and Slovakia, the budget estimates 
are reduced to less than one fourth compared to the current MFF.  The annual average amounts 
(commitments)  needed  in  the  scenario  with  unchanged  policy  (i.e.  continuation  of  the 
programmes) are shown in Annex 2. 

The  EU  funding  under  the  next  MFF  and  the  allocated  national  contributions  will  cover  the 
completion of the programmes in Bulgaria and Slovakia, thus addressing all safety challenges. In 
Slovakia, the funding may be over before the mid-term of the next MFF.  

28  

29  

SERAW / ДП РАО (State Enterprise Radioactive Waste / Държавно предприятие „Радиоактивни отпадъци”) 
in Bulgaria;  
JAVYS (Jadrova a vyradovacia spolocnost, a. s. / Nuclear and Decommissioning Company) in Slovakia 
"Support to the mid-term evaluation of the Nuclear Decommissioning Assistance Programmes", EY, An 
evaluation for the European Commission DG Energy, 2018 

15 

 
                                                            
Social challenges 

The social impact in the concerned regions caused by the shutdown of the reactors was initially 
important.  Kozloduy  is  located  in  the  Vratsa  district  (BG)  which  is  one  of  the  poorest  areas  in 
Bulgaria with a high unemployment rate30. Bohunice is located in the Trnava region (SK) which 
has a low unemployment rate31; social challenges are therefore less significant in Bohunice than 
in Kozloduy. 

Nuclear  power  plants  in  operation  are  located  on  both  sites  (Kozloduy  NPP  Units  5  and  6; 
Bohunice V2 NPP). 

In 2017 under the Kozoduy programme approx. 650 full time equivalents were employed. Under 
the Bohunice programme 235 full time equivalents are currently working.  

Other available EU instruments may be deployed in the regions ensuring this way synergies and 
complementarities.  For  example,  the  European  Regional  Development  Fund  (ERDF),  the 
European Social Fund Plus (ESF+) and the Cohesion Fund could support measures to accompany 
the related social and economic transition, including also energy efficiency and renewable energy 
measures  as  well  as  certain  other  activities  not  linked  to  radiological  safety  processes.  As  such 
these  Funds  can  create  additional  activities  in  the  concerned  regions  and  utilise  the  locally 
available expertise as a major driver of job creation, sustainable growth and innovation. Similarly 
synergies should be explored with FP9 and / or the Euratom Research and Training programme 
in areas such as technology development and testing, as well as training and education. 

1.3.2.  JRC decommissioning and waste management programme 

The  D&WM  programme  covers  the  decommissioning  of  a  variety  of  experimental  research 
nuclear  facilities,  and  the  management  of  non-standard  spent  fuel  and  historical  waste.  This  is 
notably  a  key  distinguishing  feature  of  this  programme  in  relation  to  the  'Kozloduy'  and 
'Bohunice'  programmes  which  have  to  deal  with  power  generating  reactors.  Additionally,  as 
owner  and  nuclear  operator  under  national  laws  of  the  nuclear  facilities,  JRC  has  the  prime 
responsibility  for  the  safe  management  from  generation  to  disposal  of  the  spent  fuel  and 
radioactive  waste  it  has  generated  (Article  7  of  Directive  2011/70/Euratom),  until  transfer  of 
ownership to the host Member State or release of the facilities from regulatory control. Actually, 
JRC is implementing the D&WM programme as license holder in four different Member States. 

Uncertainties due to external factors  

The  four  JRC  sites  face  uncertainties  of  different  types.  For  example,  in  Ispra,  where  the 
D&WMP  is  more  advanced,  the  complex  and  long  licensing/authorisation  process  is  causing 
significant delays, both for the management of radioactive waste and for the decommissioning of 
the facilities.  

Italy: Lack of criteria for waste management 

Directive  2011/70/Euratom  on  the  safe  and  responsible  management  of  radioactive  waste  and 
spent fuel obliges each Member State to establish a national programme (to be communicated to 
the Commission) which translates the national policies into concrete plans of actions, in order to 
ensure that progress is made. 

30     Average unemployment rate in the Vratsa province in the first half of 2016 was 19.0 % compared to the national 

average of 9.4%. 
[https://ec.europa.eu/eures/main.jsp?countryId=BG&acro=lmi&showRegion=true&lang=en&mode=text&region
Id=BG0&nuts2Code=%20&nuts3Code=null&catId=9574] 

31   Unemployment rate in Trnava region in January 2018 was 2.06% being the lowest rate in Slovakia. 

[http://www.upsvar.sk/media/medialne-spravy/v-januari-2018-miera-evidovanej-nezamestnanosti-v-sulade-s-
dlhodobym-trendom.html?page_id=764912] 

16 

 
                                                            
Italy  has  not  yet  adopted  such  a  national  programme,  formulating  how  it  would  implement 
concrete  radioactive  waste  and  spent  fuel  management  solutions.  This  has  two  essential 
consequences: 

 

 

JRC  has  no  information  how  the  radioactive  waste  generated  during  operation  and 
decommissioning  needs  to  be  conditioned  in  order  to  transfer  it  to  the  Italian  radioactive 
waste management organisation. This is commonly referred to as "waste acceptance criteria". 
In  absence  of  such  criteria,  there  is  a  risk  of  having  to  re-condition  the  materials  a  second 
time – which is a costly operation with increased safety risks due to the radiological hazards 
involved.  Therefore,  such  operations  often  require  to  be  put  "on  hold"  until  the  acceptance 
criteria are defined, potentially leading to overall delays in the decommissioning process32. 

JRC cannot transfer the radioactive waste generated during decommissioning directly to the 
Italian radioactive waste management organisation, i.e. the "waste management route" is not 
open. As a consequence, capacity for storing the materials has to be  maintained on the site 
(see "Technical and Technological challenges" below). 

Italy: pending authorisations for decommissioning 

Decommissioning  of  nuclear  facilities  is  subject  to  authorisation,  a  process  which  in  Italy 
involves  agreements  from  several  State  Ministries.  For  each  decommissioning  phase,  the 
activities  to  be  performed  have  to  be  described  in  detail,  including  safety,  environmental  and 
radiation protection implications as well as the initial and final state of the site and the solution 
envisaged for waste management and waste disposal. The identification and analysis of possible 
hazard  and  of  accident  scenarios  for  each  phase  of  decommissioning  must  be  addressed  in  the 
application,  together  with  implication  for  the  outside  emergency  plan  and  proposal  for  its 
updating.  

So far, only one laboratory has been fully decommissioned and released from regulatory control 
as  this  did  not  require  this  authorisation  process.  Dismantling  of  some  internal  parts  of  the 
installations  in  Ispra  is  currently  possible  within  the  existing  licenses  for  running  the  facilities, 
but  only  if  special  ad  hoc  authorisations  are  granted  by  the  Safety  Authorities.  The 
implementation  of  the  'Settlement  Agreement'  that  was  signed  in  2009  between  Italy  and  the 
Commission,  transferring  over  the  responsibility  for  the  decommissioning  of  one  of  the  two 
reactors at the Ispra site to the Italian authorities, started only in 2018. 

The JRC Ispra decommissioning programme end date has already been postponed from 2028 to 
2030, and it is currently scheduled for 2038.   

Petten: Uncertainties regarding operational life time 

In Petten, the end of operation of the High-Flux Reactor (HFR) was not defined until recently. On 
November 21, 2017 the Commission received the Notification of Investment for the new Dutch 
research reactor (PALLAS), to be built in Petten. According to this notification, HFR would be 
shut  down  once  PALLAS  becomes  operational  (scheduled  for  2025).  However,  there  is  no 
guarantee  that  the  new  reactor  will  be  built.  For  this,  the  Dutch  Authorities  should  give  final 
authorisation (after completion of the Environmental Impact Assessment, licensing etc.) 

32  

JRC has mitigated the financial risks for potential re-conditioning by signing a 'Settlement Agreement' with the 
Italian State in 2009, as to which the costs have a certain ceiling; this agreement however was only recently 
recognised by Italy. The agreement ("Accordo Transattivo … sui principi governanti le responsabilita' di gestione 
dei rifiuti radioattivi nel sito del Centro Comune di Ricerca di Ispra", signed on Nov 27, 2009) is based on three 
commitments by the Italian Government: take charge of decommissioning the Ispra-1 reactor; take ownership 
and manage the interim storage facility and the conditioned waste stored therein; cap costs for potential re-
conditioning of waste. The agreement was pending implementation by the Italian Government. Only recently it 
was recognised by publishing the Italian Budget Law for 2018 (Leggi di Stabilità) which included provisions for 
2018 to implement one of Italy's commitments, namely that to take charge of one of the two reactors at the Ispra 
site 

17 

 
                                                            
Cost increases 

Costs  for  delays  currently  amount  to  EUR  10  million  per  year  for  the  safe  conservation  of  the 
nuclear  facilities  at  the  Ispra  site,  in  addition  to  the  staff  costs  (58  members  of  JRC  staff  paid 
from Euratom R&D budget).  

Today,  the  best  available  cost  estimate  of  decommissioning  is  significantly  higher  than  past 
estimates  (EUR  1.6  billion  vs  EUR  0.9  billion  forecasted  in  2013).  Real  costs  could  be  even 
higher  at  the  time  of  completion  of  the  programme,  depending  on  which  risks  actually 
materialise.  

In Ispra, the current estimate for waste disposal (EUR 138 M) is conditional to high uncertainties 
due to the lack of any national disposal path for radioactive waste and nuclear material (lack of 
national repositories and definition of Waste Acceptance Criteria by the host Member State).  

Belgium,  Germany  and  the  Netherlands  have  established  waste  disposal  paths  for  low  level 
waste. It has to be noted that waste disposal costs increased by 60% in Belgium within the last 5 
years. The cost estimate in Karlsruhe does not include the disposal of nuclear material and spent 
fuel due to the current lack of a disposal path. These costs will be incurred in the frame of future 
decommissioning activities in Karlsruhe (around 2030 and beyond).  

Technical and technological challenges 

The nuclear facilities at the JRC Ispra site include two research reactors (ESSOR and Ispra1), a 
hot-cells laboratory building, a former test facility for nuclear material, a cyclotron building, and 
a liquid treatment station with 'tank farm'. Even though the nuclear research facilities have been 
shut down long time ago, the decision to go ahead with their decommissioning was postponed for 
different  reasons.  As  regards  the  ESSOR  reactor,  the  final  decision  to  proceed  with 
decommissioning was taken in 1998. 

Italy is only at the beginning of the process of identifying a national radioactive waste repository, 
and all the waste generated by the operation and decommissioning of nuclear installations in Italy 
is currently stored in the sites of origin. In this context, JRC Ispra has started to build new waste 
treatment and storage facilities on its premises to manage its own radioactive waste until the final 
Italian repository will be available. 

Part  of  the  JRC  Ispra  premises  was  used  for  the  treatment  and  storage  of  waste  and  nuclear 
material.  In  the  frame  of  the  D&WM  programme,  new  facilities  for  waste  treatment, 
characterisation and safe storage have been, or are being established. The establishment of state-
of-the-art procedures for the safe treatment of historical waste is one of the key challenges of the 
programme.  The  knowledge  gained  by  JRC  in  this  kind  of  "pilot  tests"  would  be  a  valuable 
contribution to Member States national decommissioning programmes. Where appropriate from 
licensing,  technical  and  financial  point  of  view,  external  nuclear  facilities  are  used  to  process 
waste and nuclear material. 

In comparison with the technological, administrative and environmental challenges JRC Ispra is 
facing,  the  decommissioning  activities  in  Karlsruhe  (low  activity  laboratories  and  Hot  Cells), 
Geel (low activity laboratories and two accelerators) and Petten (one research reactor) are more 
straightforward:  waste  disposal  paths  have  been  established  by  the  host  Member  States,  and 
future decommissioning will build on the experience gained by JRC during the R&D operation of 
the facilities (e.g. regular disposal of obsolete laboratory equipment and waste). 

Availability of adequate resources 

Decommissioning  is a long-term industrial activity which requires adequate resources, in terms 
of  budget  and  staff,  throughout  the  programme.  Budget,  as  well  as  the  JRC  staff  dealing  with 

18 

 
decommissioning, should be available throughout the duration of the decommissioning activities 
which are expected to peak around 2025 and remain high for several years until circa 2040.  

A  specialised  workforce  is  required,  with  skills  in  the  technical  field  (engineering  /physics 
/chemistry /radiation protection), in industrial project and contract management, and with specific 
knowledge in the licencing processes of the four host Member States. In the current framework, 
the workforce is stemming and paid from the Euratom R&D budget. If  – in light of the current 
staff reduction strategy of the Commission – DG JRC has to maintain the number of staff or even 
reduce it, increasing the number of staff in decommissioning in the future would mean decreasing 
the number of staff engaged in other important activities of JRC (research, policy support, etc.).  

The  decommissioning  programme  as  an  "industrial  activity"  depends  on  strong  administrative 
support  to  prepare  and  manage  high-volume  and  technically  complex  contracts  (legal  advice, 
procurement staff). In the past, the preparation of such contracts, moreover their implementation, 
were  frequently  behind  schedule  and  caused  additional  delays  and  budget  underspending  (on 
average 20% of unspent yearly payment allocations  in the current MFF). Unexpected  technical 
difficulties  or  contamination  levels  are  possible  in  any  decommissioning  project,  and  might 
require  additional  licensing,  negotiations  and/or  lawsuits  with  existing  contractors,  and 
preparation of additional contracts. Flexibility in budget allocation would be needed throughout 
the programme. 

1.4.  Objectives of the programmes of the next MFF 

1.4.1.  General objectives 

The 'Kozloduy' and 'Bohunice' programmes aim to assist Bulgaria and Slovakia in managing 
the radiological safety challenges of the decommissioning process. 

The D&WMP programme pursues the decommissioning of the Commission (JRC) sites, and 
explores  and  develops  options  for  anticipated  transfer  of  decommissioning  and  waste 
management liabilities to the JRC host Member States. 

These  two  main  general  objectives  are  complemented  by  the  aim  of  enhancing  the  EU  added 
value  of  the  programme  through  dissemination  of  knowledge  (thereby  generated)  to  all  EU 
Member States on the decommissioning process. 

Finally,  a  key  policy  objective  remains  the  increase  of  Member  States'  ownership  of  the 
decommissioning and waste management processes. 

1.4.2.  Objectives of the Kozloduy and Bohunice programmes 

The specific objectives  for the programmes in Bulgaria and Slovakia need to be adapted to the 
actual  progress  of  the  decommissioning  programmes  and  the  need  to  foster  knowledge  sharing 
and potential synergies. 

The disposal of spent fuel and radioactive waste in a deep geological repository is excluded from 
the  scope  of  the  programmes,  and  has  to  be  developed  by  each  Member  State  in  its  national 
programme for the management of spent fuel and radioactive waste as required by the relevant 
directive33,34.  The  Slovak  national  programme  covers  the  realisation  of  a  deep  geological 

33   Council Directive 2011/70/Euratom of 19 July 2011 on establishing a Community framework for the responsible 

and safe management of spent fuel and radioactive waste, OJ L199, 2.8.2011, p. 48-56. 

34   Report  from  the  Commission  to  the  Council  and  the  European  Parliament  on  progress  of  implementation  of 
Council  Directive  2011/70/Euratom  and  an  inventory  of  radioactive  waste  and  spent  fuel  present  in  the 
Community's territory and the future prospects – C(2017) 236 final. 

19 

 
 
                                                            
repository and schedules it in 2065; however until 2020 the alternative option to explore solutions 
for  disposal  in  other  countries  will  be  also  considered.  The  Bulgarian  national  programme 
presents  a  cut-off  date  in  2030,  therefore  does  not  cover  the  funding  for  a  deep  geological 
repository. 

Three specific objectives reflect the need to progress in the removal of radiological hazards: 

(1)  Finalise dismantling and decontamination of the reactor primary circuit and big components 
in accordance with the decommissioning plan; progress has to be measured by the quantity 
and type of materials removed as well as earned value; 

(2)  Finalise safe management of the decommissioning and legacy waste up to interim storage or 
to  disposal  (depending  on  the  waste  category),  including  the  completion  of  the  waste 
management  infrastructure  where  necessary.  This  objective  has  to  be  accomplished  in 
accordance with the decommissioning plan; progress has to be measured by the quantity and 
type of safely stored or disposed of waste as well as earned value; and 

(3)  Continue downgrading of radiological hazards; this objective has to be measured through the 
safety  assessments  of  the  activities  and  the  facility,  identifying  ways  in  which  potential 
exposures  could  occur  and  estimating  the  probabilities  and  magnitude  of  potential 
exposures.  Removal  of  the  facilities35  from  regulatory  control  is  planned  by  2025  in  the 
Bohunice programme and by 2030 in the Kozloduy programme. 

The plans shall include a proper set of milestones (output, date and budget) and target amounts. 

Other  two  specific  objectives  reflect  the  general  policy  objective  to  increase  Member  States' 
ownership: 

(4)  Specify the maximum level of EU co-financing both in relative and absolute terms. The EU 
funding  provided  under  the  next  MFF  is  the  final  allocation  for  the  completion  of  the 
Bohunice and Kozloduy programmes; 

(5)  Support national  initiatives to develop implementing agencies to  ensure local  capacity and 

increased ownership to govern decommissioning and waste management.  

1.4.3.  Objectives  of  the  JRC  decommissioning  and  waste  management 

programme 

The main general objective of the JRC D&WM programme is to pursue the decommissioning of 
the  Commission's  JRC  installations  in  four  sites:  JRC-Geel  in  Belgium,  JRC-Karlsruhe  in 
Germany, JRC-Ispra in Italy and JRC-Petten in the Netherlands and to safely manage the spent 
fuel  and  radioactive  waste  until  the  transfer  of  responsibilities  to  the  host  Member  State. 
Activities financed under this programme in the period 2021-2027 have to deliver the following: 

(1)  For all sites: 

Explore and develop options for anticipated transfer of decommissioning and waste management 
liabilities to the host Member State. 

(2)  At  JRC-Ispra  (depending  on  release  of  the  relevant  authorisations  by  the  Italian  Safety 

Authorities):  

35   Refers exclusively to Kozloduy nuclear power plant units 1-4 and Bohunice V1 nuclear power plant. 

20 

 
                                                            
  Retrieval, treatment and safe storage of the historical waste until transfer of ownership to 

the host Member State; 

  Retrieval, treatment and safe storage of nuclear material and spent fuel until transfer of 

ownership to the host Member State; 

  Decommissioning of licensed nuclear facilities;  

  Safe management of decommissioning radioactive waste and materials. 

(3)  At JRC-Karlsruhe: 

  Decommissioning of obsolete equipment; 

  Safe management of decommissioning radioactive waste and materials; 

  Reduced inventory of obsolete nuclear material and spent fuel; 

  Decommissioning of shut-down facilities; 

  Preparatory phases of the decommissioning of building parts 

 (4)  At JRC-Petten: 

  Safe management of historical and decommissioning waste and materials; 

  Reduced inventory of obsolete nuclear material and spent fuel. 

  Preparatory phases of the decommissioning of the HFR, in coordination with the current 

operator 

 (5)  At JRC-Geel: 

  Decommissioning of obsolete equipment; 

  Safe management of decommissioning radioactive waste and materials. 

The D&WM programme shall contribute to the JRC host Member States national programmes on 
their  implementation  of  the  Council  Directive  2011/70/Euratom  on  the  responsible  and  safe 
management of spent fuel and radioactive waste. To this end, the costs for the disposal of spent 
fuel and radioactive waste in a final repository are included in the scope of the programme. 

1.4.4.  Common specific objectives 

An  additional  specific  objective  should  reflect  the  opportunity  and  need  to  create  and  share 
knowledge for all EU Member States managing decommissioning programmes. When possible, 
additional synergies should be also developed and exploited. 

The merger in one instrument of the decommissioning activities in Bulgaria and Slovakia, and of 
the JRC will build synergies between the two programmes and additional in-house know-how for 
the Commission to explore and develop options for anticipated transfer of decommissioning and 
waste management liabilities to the JRC host Member States. As mentioned, synergies with the 
European Regional Development Fund (ERDF), the European Social Fund Plus (ESF+) and the 
Cohesion Fund can be strengthened in the next programming period. Similarly synergies should 
be  explored  with  FP9  and  /  or  Euratom  Research  and  Training  programme  in  areas  such  as 
technology development and testing, as well as training and education. 

(1)  Develop ties and exchanges among EU stakeholders (e.g. Member States, safety authorities, 

utilities and decommissioning operators) and 

21 

 
 
(2)  document  explicit  knowledge  and  make  it  available  through  multi-lateral  knowledge 
transfers  on  decommissioning  and  waste  management  governance  issues,  managerial  best 
practices, and technological challenges, with a view to develop potential EU synergies. 

Progress is to be measured by the number of knowledge products created and their outreach. 

22 

 
 
3. 

PROGRAMME STRUCTURE AND PRIORITIES 

The programme for Bulgaria and Slovakia is indirectly managed through the European Bank for 
Reconstruction  and  Development  and  a  national  agency 
the 
decommissioning  of  these  reactors  under  a  dedicated  spending  programme  implies  that 
implementation continues seamlessly through the established implementing bodies. However, the 
establishment of a national agency in Bulgaria should be assessed. 

in  Slovakia.  Keeping 

The programme for the decommissioning  of the Commission's sites is  managed directly by the 
JRC.  

Having  the  two  programmes  under  one  instrument  provides  the  proper  flexibility  to  maximise 
effectiveness and efficiency, ensure knowledge sharing and synergies, and support JRC exploring 
and  developing  options  for  anticipated  transfer  of  decommissioning  and  waste  management 
liabilities to the JRC host Member States. 

1.5.  Kozloduy programme and Bohunice programme 

The common legal basis for the Kozloduy programme and Bohunice programme is the Euratom 
Treaty. Article 203 of the Treaty establishing the European Atomic Energy Community (EAEC) 
states  that  "the  Commission  shall  establish  uniform  safety  standards  to  protect  the  health  of 
workers and of the general public and ensure that they are applied. If action by the Commission 
should  prove  necessary  to  attain  this  objective  and  the  Euratom  Treaty  has  not  provided  the 
necessary powers, the Council shall, acting unanimously on a proposal from the Commission and 
after consulting the European Parliament, take the appropriate measures." 

The  actions  to  be  funded  post-2020  will  be  derived  from  the  latest  version  of  the 
decommissioning  plans  and  are  generally  responding  to  the  safety  objective.  The  main  priority 
for the programmes is to ensure timely availability of funds for the accomplishment of the safety 
objective. 

In order of importance the priorities for the programmes are: 

(i) 

sharper  focus  on  safety  (nuclear  safety,  protection  of  workers,  public,  and  the 
environment); 

(ii) 

dissemination of knowledge for the EU nuclear decommissioning market; 

(iii) 

incentivised and enhanced performance through increased ownership; 

(iv) 

simplification and synergies; 

(v) 

solidarity. 

Based  on  the  already  good  established  practice  of  the  current  MFF,  whereby  the  focus  of  the 
programmes  was  restricted  to  decommissioning  only,  the  programmes  should  further  focus  on 
activities strictly related to the delivery of the general and specific objectives and the EU added 
value, i.e. removal of radiological hazards and creation and dissemination of relevant knowledge. 
The established decommissioning plans will continue to serve as the baseline, defining this way 
the  precise  scope  for  EU  assistance.  At  the  same  time  incentives  to  pursue  decommissioning 
should be embedded in the funding mechanism, including time limitations and appropriate levels 
of national contribution from the beneficiary Member States. 

The  aspect  of  EU  solidarity  also  deserves  the  right  level  of  political  attention,  because  it 
underpinned the agreements between the two Member States and the Union when the decision to 
prematurely shut-down those reactors was taken. 

23 

 
Hence, it is important that the programme be prioritised for further EU support in the next MFF 
(2021-2027) as it has the potential for achieving notable EU-added value both in terms of safety 
and knowledge gain. 

1.6. 

JRC decommissioning and waste management programme 

As  nuclear  operator  under  Italian,  Dutch,  German  and  Belgian  laws,  JRC  is  responsible  in  the 
four host Member States for the safe management from generation to disposal of the spent fuel 
and  radioactive  waste  it  has  generated.  This  includes  the  provision  of  adequate  financial  and 
human  resources  to  ensure  the  safety  of  spent  fuel  and  radioactive  waste.  In  this  context,  the 
availability  of  the  necessary  human  resources,  as  well  as  volume  and  flexibility  of  the  budget 
shall be ensured.  

Following the proposal of the high level Working Group of Commission Services (see 1.1.2), the 
handing  over  of  JRC  nuclear  facilities  including  nuclear  material  present  financial  and  legal 
benefits for JRC – it would ensure that JRC would cease to be responsible for decommissioning 
and waste management, would no longer bear the associated costs and would release JRC from 
its  obligations  (for  the  safety  of  spent  fuel  and  radioactive  waste  management  as  well  as  for 
decommissioning activities). Therefore, the exploration and development of anticipated transfer 
of liabilities to the JRC host Member States should be prioritised. 

The  handing-over  of  JRC's  nuclear  facilities  to  the  respective  host  Member  State  is  possible. 
Such transfers occurred in the past in some of the concerned Member States. Any such financial 
settlement  can  take  different  forms,  for  example,  it  could  be  paid  over  several  multiannual 
financial framework periods, given the length of the decommissioning process. 

It is important to bear in mind that currently the situation needs to be differentiated: in Belgium, 
Germany, and the Netherlands waste acceptance criteria are defined and therefore, the situation is 
relatively  more  stable  than  in  Italy  where  the  waste  routes  are  not  clear  in  the  national 
programme. The higher uncertainties related to the JRC Ispra decommissioning plan are due to 
the current absence of waste acceptance criteria and the absence of the final disposal facility. 

A  successful  hand-over  to  Member  States  will  also  allow  to  free  JRC  human  resources  for 
effective  transfer  of  explicit  knowledge  on  decommissioning  and  waste  management  issues  to 
Member States, in line with the common specific objectives (2.2.3). 

Should  the  negotiations  with  the  Member  States  encounter  difficulties,  the  JRC  would  need  to 
ensure sufficient staff levels (adapted to the volume and pace of activities), to carry out the safe 
decommissioning  of  its  facilities  and  fulfil  its  legal  obligations  also  with  regard  to  waste 
management. JRC will also ensure the continuous dissemination of knowledge gained throughout 
the implementation of the programme at the different sites. 

24 

 
 
 
4. 

DELIVERY MECHANISMS OF THE INTENDED FUNDING 

1.7.  Kozloduy programme (BG) and Bohunice programme (SK) 

In  the  context  of  the  mid-term  evaluation  the  current  NDAP  has  been  benchmarked  with  three 
‘comparator’  instruments36:  Connecting  Europe  Facility  (CEF),  Budget  Support  aid  delivery 
mechanism  and  ESIF  major  projects.  The  benchmark  focused  on  the  identification  of  relevant 
best practices concerning the governance, the programme and project management and financial 
management. 

The  benchmark  showed  that  the  performance  monitoring  framework  for  the  current  NDAP  is 
generally in line with best practice - in particular practices in Budget Support operations – given 
that  a  results-based  performance  monitoring  is  in  place.  In  this  respect  the  NDAP  could  be 
improved by linking additional funding to the achievement of pre-defined targets. 

As  sought  by  the  current  NDAP,  all  'comparator'  instruments  seek  to  ensure  strong  national 
ownership of project implementation through early buy in and strong Member State involvement. 
Member States are involved early on in the development of the projects or programmes and have 
input at key phases.  

CEF  and  ESIF  have  a  clearly  defined  framework  for  EU  co-financing,  with  minimum  and 
maximum EU co-financing rates set out in the legal base. Unlike CEF and ESIF, the NDAP has 
no formalised framework for EU co-financing at the moment. 

All  instruments,  the  current  NDAP  inclusive,  offer  a  fully  multi-annual  rather  than  annual 
framework for programming. While 'comparator' instruments all imposed annual monitoring and 
reporting requirements (similar to NDAP), none had in place an annual cycle for programming 
and  commitments  (in  contrast  to  NDAP).  Projects  are  implemented  in  line  with  their  approved 
work plans. For CEF and major projects, specific approval is necessary prior to funding as well 
as for substantive deviations from the approved programme of works or approved budget. 

The  defining  feature  of  major  projects  is  the  specific  approval  procedure  to  which  they  are 
subject to. This includes a number of analyses carried out by the Commission services with the 
aim  to  ensure  the  quality  of  the  project  proposal,  its  feasibility,  maturity  and  its  utility.  The 
NDAP delegates this role to the implementing  bodies that are entrusted budget implementation 
tasks via a delegation agreement.  

A new financial regulation is being prepared to provide the EU with enhanced tools to implement 
the budget. The design of a new delivery mechanism will have to make use of the new features 
proposed by the financial regulation. 

Based  on  the  above,  the  following  three  policy  options  should  be  considered  in  assessing  the 
impact of the Kozloduy and Bohunice programmes in the next MFF: 

(i) 

Policy option 1 - Discontinuation of the programmes, 

(ii) 

Policy option 2 - Programmes under cohesion policy, 

(iii) 

Policy  option  3  -  Programmes  combined  with  the  decommissioning  of  JRC  sites 
(baseline option). 

36   These three comparators were selected because they represent a variety of different approaches for programme 

implementation and are used to deliver large-scale projects, including notably in the energy sector. 

25 

 
                                                            
1.7.1.  Policy option 1 - Discontinuation of the programmes 

Under Option 1 no further financial EU assistance would be provided and consequently the two 
Member  States  would  have  to  guarantee  safe  completion  of  their  decommissioning  programme 
with own national resources.  

As  mentioned  under  section  2.1.1  above,  in  case  of  insufficient  funding,  there  is  a  risk  of 
rendering  the  whole  decommissioning  process  more  lengthy  and  costly,  as  well  as  a  result  in 
possible safety implications and risk of loss of unique expertise. 

Firstly, in Bulgaria and Slovakia significant decrease in radiological hazard to the general public 
has already been accomplished by the programmes. 

Secondly, the Commission services have found in a previous study37 that the State budgets of the 
concerned Member States appear able to absorb the additional financing needs. 

Finally,  the  national  policies  and  programmes  which  are  established  by  the  Member  States  in 
application  of  the  'Radioactive  Waste'  directive  include  the  management  of  spent  fuel  and 
decommissioning waste from the concerned facilities and the associated cost estimates until the 
completion of the programmes.  

In summary, given that national policies and programmes are in place, key safety objectives have 
been  met  already,  and  the  national  economies  appear  fit  for  bearing  future  charges,  the 
discontinuation option may appear viable in some respect. 

However, in such a scenario the Union would have no more leverage on the timely execution of 
the safety actions within the timescales set out in the approved decommissioning plans.  

Moreover,  the  discontinuation  of  the  programmes  could  harm  the  reputation  of  the  EU  in 
Bulgaria and Slovakia as they had to shut down the six reactors on request by the EU at the time 
of the accession  negotiations. They were relying on Union  support for the decommissioning  as 
well as for measures mitigating the important effects to their economies due to the loss of inland 
energy production38. 

These  risks  should  be  assessed  also  in  view  of  the  reduced  average  yearly  needs  of  the 
programmes altogether, and of the increased programmes' effectiveness and efficiency obtained 
during the current MFF. 

1.7.2.  Policy option 2 - Programmes under cohesion policy 

Cohesion  policy  is  the  Union's  main  investment  policy,  aiming  to  strengthen  economic,  social 
and territorial cohesion and reduce disparities among regions. It is a major driver of job creation, 
sustainable growth and innovation in Europe’s diverse regions.   

As a result of a performance audit on the NDAP, in 2016 the ECA recommended39 discontinuing 
dedicated  spending  programmes  after  2020  and  considering  access  to  ESIF  for  nuclear 

37  

38  

"Nuclear Decommissioning Assistance Programme (NDAP) – Assessment of the robustness of the financing 
plans considering the economic-financial-budgetary situation in each concerned Member State and of the 
relevance and feasibility of the detailed decommissioning plans", Deloitte, NucAdvisor, VVA Europe, A study 
prepared for the European Commission DG Energy, 2016 
For example Slovakia – as a consequence of the shutdown of Bohunice V1 NPP – changed from an exporter of 
electricity to an importer country for electricity.  

39   Recommendation  5:  dedicated  funding  programmes  for  nuclear  decommissioning  in  Lithuania,  Bulgaria  and 
Slovakia should be discontinued after 2020. If a clear need for the use of EU funds beyond 2020 is established, in 
one or more of the three Member States, any future EU funding proposed by the Commission and agreed by the 
legislator should include the right incentives to pursue decommissioning, including by being time limited and by 
being  based  on  appropriate  levels  of  Member  State  co-financing.  One  way  to  do  this  would  be  to  consider 

26 

 
                                                            
 
decommissioning  activities.  This  recommendation  was  made  with  the  aim  to  create  the  right 
incentives  to  pursue  decommissioning  and  adhere  to  the  strict  rules  on  co-financing  applicable 
under ESIF (i.e. fixed maximum EU co-financing rates). The Commission partially accepted this 
recommendation holding over its prerogative to decide based on an impact assessment (replaced 
by  this  ex-ante  evaluation)  in  line  with  the  requirements  of  the  financial  regulation  and  better 
regulation agenda with regard to proposals of new initiatives. 

It is worth recalling that in preparation of the current MFF (2014–2020) the NDAP was already 
revised  to  exclude  all  measures  which  were  not  strictly  related  to  the  decommissioning  of  the 
concerned facilities. As a consequence, support to energy related projects was taken out of NDAP 
as it could be supported through other EU funded measures such as ESIF. 

Currently,  decommissioning  of  nuclear  power  stations  is  explicitly  excluded40  under  ESIF 
(European  Regional  Development  Fund  and  Cohesion  Fund).  Therefore,  a  possible  funding  of 
decommissioning under cohesion policy will lead to a fundamental change in the philosophy of 
these  Funds,  which  are  geared  to  growth  objectives,  notably  in  line  with  the  priorities  of  the 
Europe 2020 strategy. 

Several  arguments  can  be  listed  pro  the  extension  of  eligibility  under  cohesion  policy  to  the 
decommissioning of these specific reactors: 

(i) 

simplification and reduction of administrative burden; 

(ii)  well-established, proven and cross-cutting management and control systems; 

(iii) 

increased  Member  States'  ownership  of  the  decommissioning  programmes,  with  clear 
requirements for national contributions; 

(iv) 

budgetary flexibility transferred to the Member States. 

In other words, implementation under the shared management mode could increase the Member 
States' ownership of the decommissioning programmes (if compared to the baseline scenario) and 
would allow Member States to prioritise decommissioning projects among other eligible projects 
under the cohesion policy funding.  

However, these advantages are offset by two substantial drawbacks:  

(i)  making decommissioning an eligible activity under cohesion policy funding, will create a 
precedence that goes against the principles set by the Council Directive 2011/70/Euratom 
on the safe and responsible management of radioactive waste and spent fuel, whereby the 
costs for the management of these materials shall be borne by those who generated those 
materials; and 

(ii) 

shifting  of  budget  between  priorities  is  possible  during  the  entire  lifetime  of  the 
programme, therefore there is a risk of de-prioritisation of decommissioning in favour of 
other activities financed within cohesion policy. 

In  addition,  given  the  relatively  small  remaining  size  (both  in  time  and  in  costs)  of  the 
programmes  and  the  limited  number  of  new  projects  remaining  eligible  for  EU  co-financing  a 
change of the delivery mechanism would appear disproportionate at this stage.  

widening access to the European Structural and Investment Funds to allow nuclear decommissioning activities to 
be covered, fulfilling these conditions. 

40   Article 3.3 Regulation (EU) No 1301/2013 of the European Parliament and of the Council of 17 December 2013 
on the European Regional Development Fund and on specific provisions concerning the Investment for growth 
and jobs goal and repealing Regulation (EC) No 1080/2006; 
Article 2.2 Regulation (EU) No 1300/2013 of the European Parliament and of the Council of 17 December 2013 
on the Cohesion Fund and repealing Council Regulation (EC) No 1084/2006. 

27 

 
                                                                                                                                                                                 
 
1.7.3.  Policy option 3 - Programmes as dedicated spending programme  

Safety remains at the heart of the Union policy priorities18. The fundamental need of safety has 
been the basis for the NDAP since their inception, i.e. since the pre-accession time. This need is 
still the main driver for continuing the programmes under safety policies. 

As a result of the NDAP mid-term evaluation the current governance setup has proven to ensure 
effective and efficient implementation of the programmes. Main factors of success are the clear 
definitions of roles and responsibilities as well as the strengthened monitoring framework. 

Each  concerned  Member  State  appoints  a  Programme  Coordinator  (deputy  minister  or  state 
secretary  rank)  to  be  responsible  for  the  programming,  coordination  and  monitoring  of  the 
decommissioning programme, thus ensuring at national level the comprehensive oversight of the 
programme and enhancing access to information by the Commission in its supervisory role.  

Committees  with  monitoring  and  reporting  functions  are  in  place  for  each  Member  State,  co-
chaired by a Commission representative and the Programme Coordinators. The Committees are 
well  equipped  with  a  dashboard  of  key  performance  indicators  and  detailed  targets,  in  order  to 
steer  the  programmes  through  a  well-informed  assessment  and  decision  making  process.  The 
detailed  objectives  and  indicators  (proposed  by  the  three  Member  States  and  approved  by  the 
Commission)  provide  quantitative  information  to  measure  progress  towards  the  specific 
objectives.  Moreover,  the  Earned  Value  Management  (EVM)  methodology  enhances  the 
Commission's  supervision  on  both  effectiveness  and  efficiency  with  a  positive  trickle-down 
effect at national level. 

From a legal viewpoint, the base for the continuation of the programmes in Bulgaria and Slovakia 
is  well  identified.  Nonetheless  the  analysis  and  the  benchmark  have  also  identified  areas  for 
further improvement to be achieved in the establishment of a new Regulation for the next MFF, 
should this policy option be selected.  

In particular on the EU co-financing issue, it is worth noting that presently national contributions 
are generally within the ranges defined under the ESIF, although the legal basis has not defined 
the  due  level  of  national  contribution.  While  this  approach  created  uncertainties,  in  the  present 
financial  framework  levels  of  national  contribution  have  increased  compared  to  pre  2014-2020 
period. From a legal viewpoint there are no obstacles to introduce clearer criteria and provisions 
(in line with the ESIF ones); the decision in this respect remains truly political. 

Likewise,  further  increase  of  Member  States  ownership  as  well  as  stronger  incentives  can  be 
devised in dedicated spending programmes, based on the other lessons learnt from 'comparator' 
instruments, such as limitation in time for the funding. 

The programmes are currently implemented by the EBRD in Bulgaria, and Slovakia as well as by 
a  national  agency  in  Slovakia  (SIEA).  The  implementation  via  the  national  agency  was 
established  upon  request  by  Slovakia  in  view  of  increasing  ownership.  Continuing  the 
implementation  of  the  programmes  through  the  established  implementing  bodies  would  ensure 
stability in the safe decommissioning process. However, the establishment of a national agency in 
Bulgaria should also be assessed. This option would further increase the involvement of Bulgaria 
in the implementation of the Kozloduy programme.  

The  progress  achieved  under  the  current  NDAP  in  both  Member  States  is  significant.  The 
existing monitoring tools – remarkably the EVM based methodology - have ensured that issues 

28 

 
that  have  occurred  in  the  implementation  of  projects  have  been  addressed  in  a  timely  and 
efficient manner to prevent delays41.  

With regard to the overarching aims in preparing the next MFF (2021-2027) namely agility and 
simplification, this policy option offers interesting solutions. The budget for the programmes in 
Bulgaria  and  Slovakia  could  be pooled  with  the  Commission's  own  decommissioning  activities 
(in  JRC).  This  should  allow  for  increased  financial  flexibility  between  decommissioning 
programmes  financed  by  the  Commission.  As  mentioned  above,  budgetary  flexibility  is 
necessary in view of the limited needs for the Kozloduy and Bohunice programmes to complete 
the decommissioning activities, and the needs also of the JRC decommissioning programme for 
flexibility  of  budget  allocation  resulting  from  uncertainty  in  the  activities'  schedule.  Moreover 
this option creates opportunities for enhanced knowledge sharing and identification of potential 
synergies between the programmes. 

1.7.4.  Policy options benchmark 

The risks associated to policy option 1 (discontinuation) can be summarised as such: EU would 
waive  leveraging  on  the  safety  objectives  of  the  NDAP  as  well  as  exploiting  the  knowledge 
gained in favour of other EU Member States; moreover, from a political standpoint, the solidarity 
principle  underpinning  the  NDAP  thus  far  would  be  disregarded  by  the  Union  with  negative 
effect on the European sentiment in Bulgaria, and Slovakia. 

Policy  options  2  and  3  are  mainly  differentiated  in  terms  of  theme  (cohesion  vs  safety)  and 
delivery mechanism (cohesion policy funding vs dedicated spending programme). 

Both  solutions  are  fit  for  addressing  the  substantial  needs  of  increased  ownership  by  the 
beneficiary Member State and of stronger incentives to pursue decommissioning in a timely and 
efficient manner. However, policy option 3 responds more effectively to the needs of: 

(i) 

EU leveraging on the safety objectives; 

(ii) 

exploitation of the knowledge gain for the decommissioning of nuclear reactors EU wide; 

(iii) 

knowledge  sharing  and  development  of  potential  synergies  amongst  decommissioning 
programmes managed by the Commission; 

(iv) 

budgetary flexibility. 

Finally, given the progress achieved in Bulgaria and particularly Slovakia, the change of delivery 
mechanism  at  this  point  in  time  appears  disproportionate  with  respect  to  the  marginal  benefits 
policy option 2 offers. 

1.8. 

JRC decommissioning and waste management programme 

As mentioned above, the JRC D&WM programme unlike other programmes, e.g. Horizon 2020, 
has  no  secondary  legislation.  Instead,  it  relies  on  the  legal  base  provided  by  Article  8  of  the 
Euratom Treaty. 

To this end and based on the Communication of the Commission "Historical Liabilities Resulting 
from Nuclear Activities carried out at the JRC under the Euratom Treaty – Decommissioning of 
obsolete  Nuclear  Installations  and  Waste  Management"  (COM(1999)114),  the  Programme  was 

41  

For example: in the project for the decontamination of the primary circuits of the Bohunice V1 reactors the 
contractor chosen through an open procurement procedure failed to achieve the expected results. Initially the 
consequent delays impacted the critical path of the programme. However the project was put back on track and 
the decontamination was completed with excellent results. In parallel, through a review of the programme critical 
path, any impact was minimised and the end date of the programme (2025) is still valid. 

29 

 
                                                            
initiated  and  a  specific  ad  hoc  budget  line  was  created,  in  agreement  with  the  European 
Parliament and the Council, following the principle of annuality. 

Outsourced services and supplies are financed by budget line (Chapter 10.05.01) that cannot be 
used  for  administrative  expenses.  As  a  result,  the  in  house  human  resources  necessary  for  the 
implementation  of  the  programme  (for  management  and  supervision)  are  funded  through  the 
Euratom Research and Training framework programme.  

The variable and unpredictable level of expenditures in a given year (currently mainly related to 
the  lengthy  authorization  procedures  by  national  authorities  and  complex  procurement  and 
contract  management)  makes  it  difficult  to  manage  the  programme  in  line  with  the  current 
budgetary and financial setup that is based on the annuality principle as it is not always possible 
to predict which payments will have to be made in a particular year. For example, payments have 
often been lower than expected, resulting in apparently "poor" budget execution.  

As  described  in  3.2,  the  handing  over  of  JRC  facilities  to  the  host  Member  State  presents 
financial and legal benefits for the Commission. This is possible and there is precedence of such 
transfers in certain of the Member States concerned. 

In  light  of  the  uncertainties  around  the  D&WMP  that  may  result  in  increasing  volume  and 
uncertainty of budgetary needs more budgetary flexibility is needed.  

Pooling the D&WM budget and the Kozloduy and Bohunice programmes would allow for certain 
financial  flexibility.  As  described  in  4.1.3,  it  would  also  create  opportunities  for  effective 
knowledge sharing and identification of potential synergies between the programmes. 

5. 

HOW WILL PERFORMANCE BE MONITORED AND EVALUATED? 

Nuclear  decommissioning  programs  are  complex  and  long-lasting  (flowing  through  several 
subsequent  MFFs).  Objectives  are  thus  specifically  defined  for  the  short  term  (e.g.  year,  MFF) 
under the framework of a multiannual programme aimed at accomplishing the general objective, 
i.e. achieving a pre-defined end-state at the site as approved by the national nuclear regulator. 

1.9.  Kozloduy programme and Bohunice programme 

1.9.1.  Programming, monitoring and control system 

Under policy option 3 the programming, monitoring and control system will be further improved 
and streamlined with respect to the existing one; lessons learnt from the mid-term evaluation will 
be used in order to ensure continuous improvement. 

In 2013, the Commission modified the governance of the programmes for the MFF 2014-2020 in 
order  to  set  out  clear  roles  and  responsibilities,  and  introduced  increased  planning,  monitoring 
and  reporting  requirements.  In  line  with  this  revised  governance  approach,  each  concerned 
Member State has appointed a Programme Coordinator (deputy minister or state secretary rank) 
to  be  responsible  for  the  programming,  coordination  and  monitoring  of  the  decommissioning 
programme  at national  level.  Currently the Programme  Coordinators have to  submit the  annual 
work programmes for adoption by the Commission along with the relevant financing decision; in 
the  next  MFF  the  tools  provided  by  the  new  Financial  Regulation  will  be  exploited  and  more 
analogies  (to  the  extent  possible)  with  the  management  and  control  structure  for  the  cohesion 
policy funding will be sought in order to ensure streamlining and simplification. 

As far as programming is concerned the multiannual nature of the decommissioning programme 
will  be  reflected  by  the  adoption  of  a  multiannual  work  programme  and  financing  decision,  in 
line  with  the  envisaged  new  financial  regulation.  This  programming  process  will  be  evidently 

30 

 
 
synchronised with the evaluation steps (an interim one after four years, and a final one four years 
after 2027 to ensure completion of tasks in field). 

The  Commission  would  entrust  the  implementation  of  the  programmes'  budget  through  pillar 
assessed implementing bodies (indirect management), i.e.: 

(i) 

(ii) 

to 
in  Bulgaria 
Decommissioning Support Fund; 

the  EBRD,  with  contributions 

to 

the  Kozloduy  International 

in  Slovakia  to  the  Slovak  Innovation  and  Energy  Agency  (SIEA);  the  EBRD  will 
mainly complete the implementation of projects already financed through the Bohunice 
International Decommissioning Support Fund. 

The  establishment  of  a  national  agency  in  Bulgaria  as  implementing  body  of  the  Kozloduy 
programme should be assessed. 

Committees  with  monitoring  and  reporting  functions  are  in  place  for  each  Member  State,  co-
chaired by a Commission representative and the Programme Coordinators. Implementing bodies 
monitor  on  a  day  to  day  basis.  In  addition,  the  Commission  services  closely  follow  project 
implementation through desk and on-the-spot reviews on a biannual basis. 

As far as reporting is concerned, the practice of annual reporting to the European Parliament and 
the Council will be maintained. 

Presently  the  regular  programming,  monitoring  and  control  cycle  is  supplemented  by  thematic 
verifications based on risk reviews. This practice has to continue in the next MFF. 

1.9.2.  Performance indicators 

The present Regulation5 has defined SMART specific objectives for the progress to be achieved 
in  the  funding  period;  those  specific  objectives  have  been  further  detailed  with  targets  and 
indicators within the detailed implementation procedures12. 

Quite  a  number  of  output-based  physical  progress  indicators  are  suitable  both  for  defining 
specific  objectives  and  for  monitoring  the  performance  (i.e.  effectiveness)  of  decommissioning 
programmes;  for  example  amounts  of  systems  dismantled,  materials  released  from  regulatory 
control, radioactive waste processed, conditioned and stored or disposed of. 

Another important category of indicators is project-based; for example milestones i.e. significant 
events in a project properly budgeted and scheduled. Moreover, project management techniques 
such as critical path analysis and the EVM that provides robust project-based KPIs enabling the 
managers to control delays and cost-increases. Accordingly these indicators are used to assess the 
efficiency of the process. 

The combination of output-based and project-based indicators has proven to have a high potential 
for  programmes  such  as  nuclear  decommissioning.  Output-based  indicators  put  very  specific 
activities under the spotlight; the information they provide is sharp and clear, but also limited in 
that the full picture is not covered. Complementarily the EVM KPIs provide a complete view of 
the progress of individual projects/work packages and can be aggregated to inform on the general 
state of play of the overall programme, both time-wise and cost-wise. 

Such set of indicators (fully quantitative) enables control on short-term as well as on long-term 
issues, providing the managers (up to supervisory organisations) the tools to enact corrective or 
mitigation  measures  at  the  earliest  time  possible.  This  is  a  key  feature  for  nuclear 
decommissioning programmes because the processes are not yet fully mature world-wide. 

The  mid-term  evaluation  of  the  programmes  has  shown  that  this  comprehensive  toolkit  of 
performance indicators has supported effective and efficient implementation as demonstrated by 

31 

 
the  deeds,  i.e.  accomplishments.  Therefore,  the  performance  monitoring  and  evaluation  for  the 
future MFF can be profitably built on both the existing system and the lessons learnt to ensure 
continuous improvement. 

Under  policy  option  3  other  indicators  are  needed  to  reflect  safety  related  achievements  in  an 
even stricter manner and to match with the new explicit EU-wide knowledge sharing objective. 

Progressive  and  stepwise  removal  of  radiological  hazards  posed  by  the  facilities  under 
decommissioning  will  have  to  be  measured  based  on  the  safety  cases  prepared  by  the 
decommissioning license holder. 

As far as the EU-wide knowledge sharing objective is concerned, the following key items should 
be  monitored  without  prejudice  to  the  competitive  advantage  of  the  decommissioning  license 
holders having created such know-how: 

(i)  decommissioning cost estimations and estimations methodologies; 

(ii)  radiation protection and industrial safety issues; 

(iii)  identification of proven processes (e.g. decontamination of primary circuits). 

1.9.3.  Preliminary evaluation criteria 

The  Kozloduy  programme  and  the  Bohunice  programme  are  expected  to  be  completed 
respectively in 2030 and 2025. Thus the effectiveness and efficiency criteria for their evaluation 
are straightforward: achievement of the defined decommissioning end-state on schedule and on 
budget.  

Given the above, the current  cycle of programme evaluations should be maintained, i.e.  a mid-
term and evaluation has to be scheduled as well as the mandatory final evaluation. 

1.10.  JRC decommissioning and waste management programme 

1.10.1. Programming, monitoring and control system 

The D&WM programme is executed under the direct management mode and is governed by JRC 
senior  management  through  a  high  level  steering  committee  (chaired  by  the  JRC  Director-
General)42. It meets three times per year to take strategic decisions, set up objectives and monitor 
the progress of the programme. The strategic decisions include e.g. the scheduling of shut-down 
of JRC nuclear facilities, taking due account to the infrastructure needs of the JRC Research and 
Training Work Programme. 

The  high-level  steering  committee  is  supported  by  the  operational-level  steering  committee, 
composed of site representatives of the D&WMP, and the responsible officers for legal, financial 
and procurement support of the D&WM programme. This committee meets three times per year, 
and  aims  to  coordinate  and  monitor  the  D&WM  programme  activities  at  the  different  sites.  It 
discusses  technical,  legal,  financial  and  procurement  issues  of  the  D&WM  programme  and 
monitors both technical progress as well as budget implementation.  

42   The D&WM high-level steering committee is composed of JRC Deputy Director-Generals as well as JRC 
Directorates currently affected by the D&WM programme (the Directorate for Nuclear Safety & Security, 
responsible for the implementation of the D&WMP; Directorate Strategy and Work Programme Coordination, 
and Directors responsible for Health & Safety, i.e. Site Directors in Ispra, Geel, Karlsruhe and Petten). Legal 
support is provided by the JRC unit for Legal Advice. 

32 

 
                                                            
In line with the European Parliament resolution in 199943, the JRC is since the beginning of the 
D&WMP  regularly  advised  by  a  group  of  independent  European  decommissioning  experts 
(biannual  meetings, and additional ad-hoc meetings), the D&WMP Expert  Group. Their  advice 
relates to the decommissioning and waste treatment strategy, the available technology, technical 
aspects of the organisation and any other aspects relating to the programme. Until 2016 experts 
were appointed by the Commission on the basis of proposals made by the Members of the JRC 
Board of Governors or by the JRC itself. In choosing these experts, the Commission took care to 
avoid  any  conflict  of  interest  and  to  ensure  independence  of  analysis  and  foster  gender  and 
geographical diversity. Following the new Commissions Decision on the creation of Commission 
Expert Groups44, the JRC has launched a new Call for Experts and established the Expert Group 
fully compliant to the new Commission rules. 

Since the beginning of the D&WMP, the Commission is regularly reporting to the Council and 
the  European  Parliament  the  progress  and  status  of  the  D&MP,  thereby  providing  an  updated 
budget forecast (2004, 2008, and 2013)45.  

Moreover,  JRC  reports  on  an  annual  basis  on  the  mid-term  targets  and  the  progress  achieved 
(JRC Management Plan, JRC Annual Activity Report).46 

In  the  next  financing  period  the  multiannual  nature  of  the  decommissioning  process  will  be 
reflected in the adoption of a multiannual work programme and financing decision, in line with 
the  envisaged  new  financial  regulation  and  taken  into  account  the  role  of  the  JRC  Board  of 
Governors  (article  4.2  of  Commission  Decision  96/282/Euratom  on  the  reorganization  of  the 
Joint  Research  Centre).  This  programming  process  will  be  evidently  synchronised  with  the 
evaluation steps (an interim one after four years, and a final one after 2027 when the completion 
of  tasks  in  field  is  expected).  Moreover,  annual  reporting  to  the  European  Parliament  and  the 
Council will be introduced in order to align and increase synergies between the programmes.  

1.10.2. Performance indicators 

The specific objectives defined in chapter 2.2.3 lay down the progress to be achieved in the next 
funding period. Progress has to be measured as appropriate by the establishment of appropriate 
and  authorized  pathways  to  implementation  of  decommissioning,  by  the  quantity  and  type  of 
safely  stored  or  disposed  of  waste,  by  the  quantity  and  type  of  safely  stored  or  disposed  of 
nuclear material and spent fuel, by the quantity and type of materials removed. The programme 
progress has to be generally measure also by earned value. 

43   European Parliament resolution COM(1999) – 114 – C5-0214/1999 – 1999/2169(COS): "…ensure that the 
members of the committee of experts from the Member States that is to assist the JRC in its work are 
independent and properly qualified" 

44   C(2016) 3301 final. COMMISSION DECISION of 30.5.2016 establishing horizontal rules on the creation and 

operation of Commission expert group 

45   COM(1999)114, (COM(2004)621, COM(2008)903 and COM(2013)734).  
46   Most recent publications: Management Plan 2017, 2016 Annual Activity Report 

33 

 
 
 
 
                                                            
Annex 1: Procedural information 

1. 

LEAD DG(S), DECIDE PLANNING/CWP REFERENCES 

DG ENER, no entry in Decide Planning required 

2. 

ORGANISATION AND TIMING 

21 February 2018 – ISSG meeting 
18 April 2018 – ISSG meeting 

3. 

EVIDENCE, SOURCES AND QUALITY 

The following documents have been used as input to this ex-ante evaluation: 

[1]  "Support  to  the  mid-term  evaluation  of  the  Nuclear  Decommissioning  Assistance 

Programmes", EY, An evaluation for the European Commission DG Energy, 2018 

[2]  "Report  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 in 2016 and previous years" of 20.06.2017 COM(2017) 
328 final 

[3]  "Report  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 in 2015 and previous years" of 20.06.2016 COM(2016) 
405 final 

[4]  "Report  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 in the period 2010-2014" of 03.03.2015 COM(2015) 78 
final 

[5]  "Report  on  the  assessment  of  the  Nuclear  Decommissioning  Assistance  Programme  in 
framework  2014-2020" 

the  mid-term 

review  of 

financial 

the 

view  of 
[Ares(2016)3562735] 

[6]  "Nuclear  Decommissioning  Assistance  Programme  (NDAP)  –  Assessment  of  the 
robustness of the financing plans considering the economic-financial-budgetary situation 
in  each  concerned  Member  State  and  of  the  relevance  and  feasibility  of  the  detailed 
decommissioning plans", Deloitte, NucAdvisor, VVA Europe, A study prepared for the 
European Commission DG Energy, 2016 

[7]  ECA  Special  Report  22/2016  "EU  nuclear  decommissioning  assistance  programmes  in 
Lithuania, Bulgaria and Slovakia: some progress made since 2011, but critical challenges 
ahead" 

34 

 
 
 
Annex 2: Funding 

Programme 

Planned end date 

Kozloduy 

Bohunice 

JRC 

2030 

2025 

2060 

Programme 

Overall commitments until 2020 (EUR million) 
< 2013 
850 
624 
1 474 
330 
1 804 

Kozloduy 
Bohunice 
Sub-Total 
JRC 
TOTAL 

Cost estimate  
[EUR million] 

1 296 

1 238 

2 019 

2014 – 2020  
293 
225 
518 
205 
723 

Commitments for decommissioning activities until 2020 (EUR million) 

Programme 

Kozloduy 
Bohunice 
Sub-Total  
JRC 
TOTAL 

< 2013 
491 
437 
928 
330 
1 258 

2014 – 2020  
293 
225 
518 
205 
723 

EU contribution per year (average) (EUR million) 

Programme 

Kozloduy (BG) 
Bohunice (SK) 
Sub-Total NDAP 
JRC 
TOTAL 

MFF 2014-2020 
41.9 
32.1 
74.0 
29.3 
103.3 

MFF 2021-2027 
9.0 
7.9 
16.9 
49.7 
66.6 

Decommissioning average costs / year (EUR million) 

Programme 

Kozloduy (BG) 
Bohunice (SK) 
Sub-Total NDAP 

MFF 2014-2020 
47.1 
107.3 
154.4 

MFF 2021-2027 
30.7 
35.6 
66.3 

Post-2020  
financing gap 
[EUR million] 
91 

81 

Total 
1 143 
849 
1 992 
535 
2 527 

Total 
784 
662 
1 446 
535 
1 971 

Δ% 
-79% 
-76% 
-77% 
+70% 
-36% 

Δ% 
-35% 
-67% 
-57% 

Sources:  European  Commission,  Decommissioning  plans,  Monitoring  reports,  Mid-term 

evaluation study. 

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