COMMISSION STAFF WORKING DOCUMENT EVALUATION Accompanying the document Report from the Commission to the European Parliament and the Council on the evaluation and implementation of the EU nuclear decommissioning assistance programmes in Bulgaria, Slovakia and Lithuania
Date: 2018-06-13
Institutions: Directorate-General for Energy, European Commission
Subjects: Bulgaria, EU programme, Lithuania, Slovakia, co-financing, decommissioning of power stations, nuclear policy, nuclear power station, nuclear safety, radioactive waste

EN 

  EN 

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

SUMMARY ........................................................................................................................................... 5 

1 

INTRODUCTION ............................................................................................................................ 8 

1.1 
1.2 
1.3 

PURPOSE AND SCOPE .......................................................................................................................... 8 
MAIN ISSUES ..................................................................................................................................... 8 
EVALUATION CRITERIA ......................................................................................................................... 8 

2 

BACKGROUND TO THE INTERVENTION ......................................................................................... 9 

2.1 
2.2 

HISTORICAL DEVELOPMENT OF THE NDAP .............................................................................................. 9 
INTERVENTION LOGIC ........................................................................................................................ 11 
2.2.1  Objectives ................................................................................................................................ 11 
2.2.2  Management of the NDAP ...................................................................................................... 12 
BASELINE AND POINTS OF COMPARISON ................................................................................................ 13 

2.3 

3 

IMPLEMENTATION / STATE OF PLAY ............................................................................................ 14 

4  METHOD ..................................................................................................................................... 15 

4.1 
4.2 
4.3 
4.4 

PREVIOUS EVALUATIONS AND OTHER REPORTS ....................................................................................... 15 
EVIDENCE FROM MONITORING ............................................................................................................ 15 
SPECIFIC EVALUATION ACTIONS ........................................................................................................... 16 
LIMITATIONS AND ROBUSTNESS OF FINDINGS ......................................................................................... 16 

5 

ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS ........................................................ 17 

5.1 

5.2 

5.3 

RELEVANCE ..................................................................................................................................... 17 
Evaluation Question 1 To what extent are the general and specific objectives of the NDAP 

5.1.1 
still appropriate in relation to the existing needs? ............................................................................... 17 
COHERENCE .................................................................................................................................... 18 
5.2.1 
Evaluation Question 2 Is the NDAP coherent with the Euratom Treaty’s acquis in the area of 
nuclear safety and responsible management of spent fuel and radioactive waste?  and with the EU 
acquis in other relevant areas? ............................................................................................................ 18 
EFFECTIVENESS ................................................................................................................................ 19 
Evaluation Question 3 To what extent have the objectives of the NDAP been achieved for 

5.3.1 
each of the three programmes? ........................................................................................................... 19 
5.3.2 
Evaluation Question 3.1 Overall, what level of progress has been made towards the 
objectives of each national programme? Is the progress in line with the decommissioning baseline 
adopted by the Commission? If not, what is the risk that objectives will not be achieved? ................ 19 
5.3.3 
Evaluation Question 3.2 What external and internal factors influenced (positively and 
negatively) the progress of the decommissioning programmes? ........................................................ 28 
5.3.4 
Evaluation Question 3.3 To what extent has the level of risk at each nuclear site been 
improved thanks to the NDAP support? ............................................................................................... 30 
5.3.5 
Evaluation Question 3.4 To what extent are Monitoring & Control systems in place to 
measure the progress of the decommissioning programmes? ............................................................ 31 
5.3.6 
the public effective, adequate and accurate? ...................................................................................... 33 
5.3.7 
Evaluation Question 4 Aside from the financial assistance provided, what other types of 
results and impacts can be attributed to the NDAP? ........................................................................... 33 
5.3.8 
Evaluation Question 5 How effective is the governance and project management framework 
at EU and national levels? .................................................................................................................... 36 
5.3.9 
Evaluation Question 5.1 How well are roles defined and effective at EU level in terms of 
planning, monitoring and reporting? ................................................................................................... 36 
5.3.10 
Coordinator defined and effective in terms of: planning; monitoring; and reporting? ........................ 38 

Evaluation Question 3.5 Are the communication actions addressed to the stakeholders and 

Evaluation Question 5.2 At national level, how well are the roles of the Programme 

1 

 
 
Evaluation Question 5.3 How effective is the governance system of the decommissioning 

5.3.11 
programmes? ....................................................................................................................................... 39 
EFFICIENCY ...................................................................................................................................... 40 

5.4 

Evaluation Question 6 To what extent is the management of the decommissioning 

Evaluation Question 6.1 To what extent has the NDAP been cost-effective when considering 

5.4.1 
programmes cost effective and efficient? ............................................................................................ 40 
5.4.2 
each activity and cost category compared against performance indicators? ..................................... 42 
5.4.3 
Evaluation Question 6.2 What are the major factors impacting the efficiency of the 
assistance programmes? What are the root causes of these factors? ................................................ 43 
5.4.4 
Evaluation Question 6.3  What factors can explain differences in costs (and possibly benefits) 
arising between Member States? ........................................................................................................ 49 
5.4.5 
Evaluation Question 7 How does the governance and management system of the NDAP 
compare to other programmes managed by the Commission (or other actors)?  Do these 
comparators provide any best practices in terms of governance or management?............................ 51 
EU ADDED VALUE ............................................................................................................................ 54 

5.5 

5.5.1 
Evaluation Question 8 What would be the likely result of ending the NDAP in the three 
Member States concerned? ................................................................................................................. 54 

6 

CONCLUSIONS ............................................................................................................................. 56 

6.1 

ASSESSMENT BY EVALUATION CRITERIA ................................................................................................. 56 
6.1.1  Relevance ................................................................................................................................ 56 
6.1.2  Coherence ............................................................................................................................... 56 
Effectiveness ........................................................................................................................... 56 
6.1.3 
Efficiency ................................................................................................................................. 56 
6.1.4 
EU added value ....................................................................................................................... 58 
6.1.5 
SCOPE FOR MODIFICATION OF THE DETAILED IMPLEMENTATION PROCEDURES ............................................... 58 
6.2.1  Roles and responsibilities ........................................................................................................ 58 
6.2.2  Programming and Monitoring ................................................................................................ 58 
6.2.3 
Simplification .......................................................................................................................... 59 
6.2.4  Co-financing ............................................................................................................................ 59 
OPPORTUNITIES FOR IMPROVEMENT .................................................................................................... 59 
6.3.1  Knowledge sharing .................................................................................................................. 59 
6.3.2  Waste-led decommissioning ................................................................................................... 60 

6.2 

6.3 

2 

 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

2011 IA 

the 2011 NDAP impact assessment - SEC(2011)1387 

AWP 

CEF 

CPI 

CPMA 

D&D 

Annual Work Programme 

Connecting Europe Facility - a key EU funding instrument to promote 
growth, jobs and competitiveness through targeted infrastructure 
investment at European level 

Cost Performance Index – indicator used by the Earned Value 
Management method 

Central Project Management Agency – national agency in Lithuania 

Dismantling and Decontamination 

detailed 
implementation 
procedures 

Commission Implementing Decision C(2014)5449 of 7 August 2014 on 
the rules of application for the nuclear decommissioning assistance 
programmes for Bulgaria, Lithuania and Slovakia for the period 2014-
2020 

EBRD 

EIA 

EQ 

EVM 

IAEA 

INEA 

INPP 

ISDC 

JAVYS 

KNPP 

ESIF 

European Bank for Reconstruction and Development - an international 
financial institution 

Environmental Impact Assessment 

Evaluation Question 

Earned Value Management - a management methodology for 
objectively measuring project performance and progress 

International Atomic Energy Agency 

Innovation and Networks Executive Agency 

Ignalina Nuclear Power Plant – the decommissioning operator for the 
Ignalina programme 

International Structure for Decommissioning Costing - a standard 
itemisation of decommissioning costs 

Jadrová a vyraďovacia spoločnosť – the decommissioning operator for 
the Bohunice programme 

Kozloduy Nuclear Power Plant – the company operating the Kozloduy 
nuclear units 5 and 6 

European Structural and Investment Funds 

ESIF Major Projects 

Large-scale infrastructure projects implemented under European 
Structural and Investment Funds 

MFF 

NDAP 

Multi-Annual Financial Framework 

Nuclear Decommissioning Assistance Programmes 

3 

 
 
2013 NDAP 
Regulations 

Council Regulations 1368/2013/Euratom and 1369/2013/EU on Union 
support for the nuclear decommissioning assistance programmes in 
Bulgaria, Slovakia and Lithuania 

NPP 

PMU 

RBMK 

SERAW 

SIEA 

SME 

SPI 

VVER 

Nuclear Power Plant 

Project Management Unit – temporary team, usually constituted in 
part by external consultants, assisting an organisation with project 
management competences 

A type of graphite-moderated nuclear power reactor designed and 
built by the Soviet Union 

Държавно предприятие „Радиоактивни отпадъци” or State 
Enterprise Radioactive Waste - the decommissioning operator for the 
Kozloduy programme 

Slovak Innovation and Energy Agency - national agency in Slovakia 

Small and Medium Enterprises 

Schedule Performance Index – indicator used by the Earned Value 
Management method 

A type of pressurised water reactor designs originally developed in the 
Soviet Union 

4 

 
 
 
SUMMARY 

The mid-term evaluation of the Nuclear Decommissioning Assistance Programme (NDAP) for the 
period  2014-2020  provides  robust  evidence,  analysis  and  conclusions  with  regards  to  i)  the 
results of the programmes against the NDAP objectives, as well as the irreversibility of nuclear 
plants’  shut-down,  enhancement  of  nuclear  safety,  changes  in  organisational  structures  of 
decommissioning operators and management systems, ii) the efficiency of the use of resources, 
and  iii)  the  EU  Added  Value  of  the  programmes.  Other  evaluation  criteria  (e.g.  relevance  & 
coherence) and the indirect impacts of the NDAP were also examined. 

Having begun the process of decommissioning at different points in time and with each national 
decommissioning  programme  subject  to  unique  factors  and  challenges  (e.g.  type  and  size  of 
units,  existence  of  necessary  waste  management  infrastructure,  major  delays  etc.),  the 
programmes  have  attained  different 
levels  of  advancement  to  date.  The  expected 
decommissioning end dates range from 2025 for Bohunice to 2030 for Kozloduy and 2038 for 
Ignalina. By 2020, some EUR 2 995 million in EU financial assistance is expected to have been 
committed  within  the  framework  of  the  NDAP  since  1999  for  nuclear  decommissioning,  of 
which  EUR  671  million  for  Bohunice  (SK),  EUR  731  million  for  Kozloduy  (BG)  and  EUR  1553 
million for Ignalina (LT). This amount is in addition to national contributions mobilised through 
dedicated  funds  and/or  programmed  budgets.  The  total  allocated  amount  of  national 
contributions currently amounts to EUR 1 086 million. EU already disbursed EUR 1366 million to 
date. 

Main findings & conclusions 

The NDAP remains a relevant & coherent instrument 

The  NDAP  remains  a  relevant 
instrument  for  supporting  the  three  decommissioning 
programmes and is well embedded in the wider policy and regulatory context. On the general 
level, the objective set out for the programmes in the Regulations remains relevant: the NDAP 
continues  to  support  a  stepwise  reduction  in  the  level  of  risk  and  radiological  hazard  at  the 
three sites  concerned. Current decommissioning  strategies  for  the three programmes  and on-
going activities also remain at present fully aligned with the specific and detailed objectives set 
out  for  each  programme.  Coherence  with  the  Euratom  Treaty’s  acquis  in  the  area  of  nuclear 
safety and management of spent nuclear fuel and radioactive waste has been ensured through 
the legal base of the NDAP, even if the programme constitutes an exception to some underlying 
principles enshrined in the Euratom acquis.  

Programmes are generally on track to achieve objectives for the current MFF 

Programmes  can  generally  be  considered  to  be  on  track  towards  reasonably  achieving  the 
principal objectives set for this programming period. However, satisfactory achievement of the 
objectives  will  in  some  cases  require  proactive  management  or  projects  and  programmes  to 
recover delays and mitigate present and future risks.  

Actual physical dismantling of equipment is progressing relatively quickly compared to previous 
programming  periods.  Dismantling  &  Decontamination  work  in  the  turbine  halls  and  auxiliary 
buildings  is  winding  down  at  Bohunice  and  progressing  well  at  Ignalina  and  Kozloduy.  The 
Bohunice  programme  has  embarked  on  important  physical  works  in  the  Controlled  Area, 
whereas the Ignalina and  Kozloduy programmes remain at different stages of the preparatory 
phase. Delays and challenges during this phase will need to be managed closely to avoid longer-
term delays with the beginning of major physical works.  

This  progress  reflects  the  nature  of  nuclear  decommissioning  programmes,  which  require 
significant  upfront  investment  in  planning  and  supporting  infrastructure.  Investments  under 
previous programmes have thus laid the foundation for the progress being achieved today. In 
particular,  the  completion  of  key  waste  management  infrastructure  projects  has  laid  the 

5 

 
groundwork  for  accelerating  work  at  Ignalina  and  Kozloduy.  At  Ignalina,  for  example,  the 
commissioning  of  the  Interim  Spent  Fuel  Storage  Facility  puts  the  programme  on  track  to 
complete the critical task of defueling.  

Finally,  progress  against  waste  management  targets  has  been  slow  to  date,  although 
programmes  should  be  able  to  recover  delays.  This  underperformance  has  mainly  been  the 
result  of  uncertainties  concerning  radiological  inventory  and  /  or  lack  of  anticipation  of 
regulatory  procedures  leading  to  under  or  overestimations  of  target  values,  slower  than 
planned  progress  with  D&D  activities,  technical  challenges  related  to  specific  legacy  waste 
streams and some delays in the commissioning of waste management facilities. 

Reduction of radiological hazards 

Since  reactors’  final  shutdown,  the  level  of  risk  at  each  site  has  been  reduced  in  a  stepwise 
manner,  notably  with  the  defueling  of  reactors  and  the  decontamination,  dismantling  and 
disposal of  contaminated  and  irradiated equipment and  materials. At Kozloduy  and  Bohunice, 
the  remaining  radiological  hazard  concerns  primarily  workers  inside  the  nuclear  facility.  The 
most significant risk reduction was achieved in the previous programming period and the level 
of risk to the surrounding environment and general population has been highly diminished. In 
comparison,  a  relatively  significant  level  of  risk  remains  at  Ignalina  prior  to  the  completion  of 
defueling  activities.  During  the  period  covered  by  this  mid-term  evaluation,  the  NDAP  has 
contributed to a risk reduction associated with the Ignalina site with the beginning of defueling 
activities. This contribution will continue to increase significantly in the coming five years as the 
process follows its course.  

Improved Monitoring & Control framework 

With  the  current  programming  period,  significant  progress  has  been  achieved  compared  with 
previous generations of the programme in terms of articulating clear objectives and translating 
those  objectives  into  a  robust  monitoring  framework.  The  introduction  of  Earned  Value 
Management  has  also  enhanced  the  quality  of  programme  monitoring.  New  templates  were 
developed  for  key  monitoring  and  programming  documents  that  are  reviewed  at  new 
programme-level  Monitoring  Committees.  The  Commission  also  continues  to  conduct  regular 
monitoring  missions.  While  these  developments  represent  an  important  step  forward,  some 
continued progress is desirable in terms of improving the quality of certain indicators, adjusting 
and  streamlining  the  contents  of  Monitoring  Reports  and  Annual  Work  Programmes  and 
continuing to perfect the implementation and use of the Earned Value Management system.  

Programme governance & management structures  

The  programme  governance  and  management  system  is  generally  considered  to  be  fit-for-
purpose. It provides for a clear and logical division of roles and responsibilities and is adapted to 
the  specific  constraints  of  the  programme.  In  practice,  however,  some  divergences  can  be 
observed between the intended and actual functioning, which may impact its effectiveness and 
efficiency.  

Programme  Coordinators  have  assumed  an  increasing  ownership  of  the  implementation  of 
decommissioning programmes thanks to political and procedural efforts to strengthen their role 
as well as a now high level of buy-in; however, there remains further margin for continuing to 
strengthen  their  role  to  varying  extents,  in  particular  through  stronger  technical  capacity. 
Moreover,  the  current  detailed  implementation  procedures  afford  only  limited  latitude  to 
Programme Coordinators to assume a more active role in programme governance.  

The  national  contribution  levels  achieved  appear  suitable  for  sustaining  proper  efficiency; 
however,  they  are  not  established  in  the  legal  basis,  which  creates  residual  uncertainties. 
Increasing national relative to EU contributions and defining a clear and formalised framework 
for ‘co-financing’ (either at programme or project level) would very likely continue to encourage 
greater national ownership. 

6 

 
Cost performance has been satisfactory, but margins for improvements have been noted 

The  cost  performance  of  all  three  programmes  has  generally  been  satisfactory  to  date.  This 
stands  in  contrasts  to  difficulties  with  some  programmes  faced  in  the  previous  MFFs.  At  the 
time  of  the  study,  the  2014  programme  cost  estimates  are  expected  to  be  maintained  or 
decrease  slightly  for  Ignalina  and  Bohunice  respectively.  The  recent  revision  of  the  Kozloduy 
decommissioning overall cost estimate shows an increase (+23%) which does not affect the size 
of the funding gap because the national contribution has been increased as well in response to 
the outcome of the plan's revision. 

Some  of  the  largest  increases  in  project  budgets  over  the  years  are  in  fact  a  result  of  revised 
planning and cost estimation or simple uncertainty rather than cost increases per se. Following 
poorly made initial estimates, project cost estimates naturally increased as the technical design, 
planning  and  regulatory  uncertainties  became  clearer.  However,  decommissioning  operators 
have strengthened their planning and cost estimation methodologies, notably at Kozloduy and 
Ignalina. The stronger management allows for further transfer of risks (cost overruns, delays) to 
the  respective  Member  States,  which  in  turn  would  empower  the  beneficiaries  to  seek 
increased cost performance. 

EU Added Value  

The  NDAP  has  been  important  to  supporting  the  decommissioning  processes  in  the  current 
MFF.  Continued  progress  of  decommissioning  would  likely  have  been  negatively  impacted  to 
varying degrees in absence of the NDAP during the current programming period. Nonetheless, 
the added value of the programme is naturally declining as implementation progresses.  

The  EU  added  value  of  the  NDAP  from  its  beginning  has  been  cast  in  terms  of  financial 
mitigation  and  nuclear  safety.  With  a  finite  level  of  radioactivity  on  site,  however,  each 
additional  euro  of  investment  provides  decreasing rates  of  return. The  EU  added  value  of  the 
programme  is  thus  naturally  decreasing  over  time.  Moreover,  the  funding  gap  for  two  of  the 
three programmes (Kozloduy and Bohunice) has been closed to small amounts that do not pose 
risks for State finances.  

The question of the continued added value of the programme can thus be raised on the basis of 
the  diminishing  rate  of  return  observed  at  present;  however,  other  types  of  EU  added  value 
could be further leveraged to justify an adequate ‘return on investment’ for Europe for future 
EU  assistance.  Of  the  more  than  90  nuclear  reactors  currently  permanently  shut  down  in 
Europe, only three have been completely dismantled. The level of experience in the dismantling 
of nuclear reactors in Europe (as well as internationally) is thus limited. The NDAP’s contribution 
to  securing  the  shutdown  and  immediate  dismantling  of  these  reactors  has  led  to  the 
generation  of  a  highly  significant  amount  of  experience  that  can  be  of  benefit  to  other 
decommissioning projects. However, the large part of this added value remains confined to the 
companies  benefiting  from  NDAP  contracts  and  the  decommissioning  operators.  While  these 
actors  are  well  placed  to  disseminate  and  apply  this  knowledge  in  the  future,  there  are  no 
mechanisms  in  place  to  ensure  this  knowledge  is  diffused  into  the  public  domain  for  use  by 
relevant actors, other NPPs, decommissioning operators, national authorities, research actors, 
etc. 

7 

 
1 

INTRODUCTION 

1.1  Purpose and scope 

When  they  acceded  to  the  EU,  Bulgaria,  Slovakia  and  Lithuania  committed  to  shutting  down 
eight nuclear reactors before the end of their scheduled lifetime: 

  Kozloduy nuclear power plant in Bulgaria (units 1 to 4); 
  Bohunice V1 nuclear power plant in Slovakia (2 units); and 
 

Ignalina nuclear power plant in Lithuania (2 units). 

The EU itself committed to providing financial assistance for decommissioning those reactors. 

The Nuclear Decommissioning Assistance Programmes (NDAP) as defined in the relevant Council 
Regulations1, 2  (the  2013  NDAP  Regulations)  were  set  up  to  provide  support  to  these 
decommissioning  programmes  in  the  Multiannual  Financial  Framework  (MFF)  2014-2020, 
continuing the assistance provided in previous periods. 

This  mid-term  evaluation  of  the  NDAP  focuses  on  the  current  setup  and  refers  to  the  period 
2014-2017 unless specified otherwise. 
This evaluation supports the Commission's report3 to the European Parliament and the Council. 
The  evaluation  also  addresses  the  scope  for  modification  of  the  detailed  implementation 
procedures.4  Finally,  the  conclusions  of  this  evaluation  have  fed  in  the  preparation  of  the 
programme proposals for the next MFF. 

1.2  Main issues 

The evaluation focuses on the following topics: 

  Safety  –  enhancement  of  nuclear  safety  and  safety  standards  for  public  health  and 

environment. 

  Governance – impact of the changes introduced in 2014 and scope for possible further 

improvement. 

  Programmes  output  –  the 

irreversibility  of  the  plants  shut-down  and  their 
decommissioning as well as overall progress and performance of the decommissioning 
programmes. 

  Knowledge – know-how development, knowledge sharing / codification with potential 

for positive effects in the general EU decommissioning market. 

The evaluation also touches the economic, social and environmental impacts stated in the 2011 
NDAP impact assessment5 (hereafter the "2011 IA"). 

1.3  Evaluation criteria 
In line with the requirements of the Better Regulation  guidelines6, the mid-term evaluation of 
the NDAP has assessed the effectiveness, efficiency, relevance, coherence and EU added value 
of the assistance programmes. 

1 Regulation (Euratom) 1368/2013 
2 Regulation (EU) 1369/2013 
3 Under Article 9 of the NDAP Regulations, the Commission is required to establish a mid-term evaluation 
report  on  the  achievement  of  the  objectives  of  all  the  measures  related  to  the  Kozloduy,  Bohunice  and 
Ignalina programmes. 
4 C(2014)5449 
5 SEC(2011)1387 
6 https://ec.europa.eu/info/better-regulation-guidelines-and-toolbox_en 

8 

 
                                                            
The  progress  of  the  implementation  has  been  evaluated  against  the  specific  and  detailed 
objectives  of  the  2013  NDAP  Regulations  and  more  generally  against  the  detailed 
decommissioning plans and the successive annual work programmes that set the basis for the 
monitoring of the programmes. 

In addition the issues of risk, sustainability, simplification, complementarity, coordination, and 
communication have been considered even though no specific objectives were defined in those 
domains. 

2  BACKGROUND TO THE INTERVENTION 

2.1  Historical development of the NDAP 

The  1986  Chernobyl  disaster  and  its  cross-border  impact  generated  broad  concern  in  Europe 
and beyond with regard to the operation of some first generation nuclear reactor types. At the 
1992  Munich  summit,  the  G-7  heads  of  state  and  government  committed  to  supporting  the 
countries  of  Central  and  Eastern  Europe  with  Soviet-designed  nuclear  power  plants  requiring 
safety upgrades. As part  of these efforts the EU provided financial and technical assistance to 
partner countries through the TACIS and PHARE programmes. 

Figure 1 - EU map with nuclear plants included in NDAP 

9 

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

Table 1: Nuclear reactors included in NDAP 

Member State 

Reactor unit / type 

Envisaged 
operational 
lifetime 

Closure 
date 

Bulgaria 

Kozloduy NPP 

Slovak Rep. 

Bohunice V1 

Lithuania 

Ignalina NPP 

Unit 1: VVER- 440/230 

1974 - 2004 

Unit 2: VVER- 440/230 

1975 - 2005 

Unit 3: VVER- 440/230 

1981 - 2011 

Unit 4: VVER- 440/230 

1982 - 2011 

Unit 1: VVER- 440/230 

1980 - 2008 

Unit 2: VVER- 440/230 

1981 - 2010 

Unit 1: RBMK 1500 

Unit 2: RBMK 1500 

1984 - 2013 

1987 - 2017 

2002 

2002 

2006 

2006 

2006 

2008 

2004 

2009 

Source: 2011 IA 

It is  to  be  noted  that on  the  Kozloduy  site there are also  two  reactors  in operation (Kozloduy 
units  5  &  6)  and  on  the  Bohunice  site  there  is  also  another  reactor  in  decommissioning 
(Bohunice  A1)  and  two  reactors  in  operation  (Bohunice  V2  units  3  &  4);  decommissioning  of 
these  facilities  is  not  eligible  under  this  assistance  programme.  When  this  document  further 
refers to Kozloduy and Bohunice, it refers to Kozloduy units 1 to 4 and Bohunice V1 units 1 & 2 
respectively. 

Recognising  the  financial  burden  due  to  the  closure  of  these  reactors  on  the  economies  of 
Bulgaria,  Slovakia  and  Lithuania  (hereafter  the  concerned  Member  States,  unless  specified 
otherwise), the EU committed to provide assistance, to support the decommissioning process as 
well  as  support  for  mitigation  measures  to  address  the  consequences  of  early  closure.  In  all 
three  cases,  the  reactors  were  shutdown,  as  per  the  timescales  set  out  in  the  Accession 
Treaties.  

The Union assistance, provided through the Nuclear Decommissioning Assistance Programmes 
can  be  divided  into  four  distinct  periods  beginning  during  the  pre-accession  period  and 
stretching to the current Multi-Annual Financial Framework (MFF): 

  During  the  pre-accession  period  (up  to  2004  for  Slovakia  and  Lithuania  and  2007  for 
Bulgaria),  the  three  countries  received  funding  through  the  instruments  targeted  at 
candidate  and  partner  countries  (PHARE  and  later  the  Instrument  for  Pre-accession 
Assistance).  

  Financial assistance over the second period (2004 - 2006 for Slovakia and Lithuania and 
2007 – 2009 for Bulgaria) was provided under the protocols to the countries’ accession 
acts.  

  Since  2007  for  Slovakia  and  Lithuania  and  2009  for  Bulgaria,  Council  regulations  have 
ensured  the  continuation  of  assistance  for  decommissioning  assistance  programmes 
until 2013. 

  Two  Council  Regulations  were  adopted  on  13  December  2013  to  provide  support  to 
these decommissioning programmes in the period 2014-2020, continuing the assistance 
but  restricting  its  scope  to  decommissioning  activities  only  and  excluding  mitigation 
measures in the energy sector that were supported in previous periods. 

10 

 
The  overall  EU  financing  made  available  to  the  three  programmes  for  decommissioning  (and 
mitigation measures in the energy sector until 2013) are summarised in the table below.  

Table 2: NDAP financial allocation 1999 – 2020 

Programme 

1999 – 2013 (M€) 

2014 – 2020 (M€) 

Total 1999 – 2020 
(M€) 

Kozloduy (BG) 

Bohunice (SK) 

Ignalina (LT) 

Total 

868 

612 

1 367 

2 847 

Source: Commission financing decisions 

293 

225 

451 

969 

1 161 

837 

1 818 

3 816 

Early political resistance in the Member States in past MFFs has  given way to acceptance and 
greater  ownership.  The  political  commitment  obtained  by  the  EU  for  the  early  closure  of  the 
reactors in the three Member States was met with some domestic resistance in early years, with 
negative  impacts  on  both  the  political  and  technical  levels.  Already  before  the  end  of  the 
previous  programming  period,  this  resistance  had  progressively  given  way  to  widespread 
acceptance of the irreversible nature of the shutdown of the reactors and resulted in positive 
developments  at  technical  level.  Increasingly,  this  has  also  been  translated  into  increased 
ownership over the decommissioning process on the part of national governments.  

2.2 

Intervention logic 

The  underlying  need,  which  constitutes  the  starting  point  of  the  intervention  logic,  is  to 
contribute to the safety of citizens by ensuring that all nuclear plants in the EU meet the high 
level  of  safety  standards  required  in  the  EU.  It  is  this  need  that  has  been  at  the  heart  of  the 
Union action in this domain from the very beginning.  

The  NDAP  answers  the  need  for  the  timely  availability  of  funds  for  ensuring  the  safe  and 
immediate decommissioning resulting from the decision to prematurely shutdown the nuclear 
reactors in question. 

2.2.1  Objectives 

The 2013 NDAP Regulations define the general objective (article 2.1) and the specific objectives 
(article  2.2)  for  each  programme.  The  general  objective  is  to  assist  Member  States  in 
implementing  the  steady  process  towards  the  decommissioning  end  state  of  the  reactors  in 
question  in  accordance  with  their  respective  decommissioning  plans,  whilst  maintaining  the 
highest level of safety.  

The 2013 NDAP Regulations required a number of ex-ante conditionalities to be met prior to the 
start  of  the  programming  period.  These  required  the  set-up  and  agreement  of  the  detailed 
decommissioning plans that would later serve as the baseline of the programmes against which 
progress would be measured and eligibility would be determined. In 2014, the three Member 
States 
the 
decommissioning  end  state,  a  schedule  for  all  tasks  required  to  reach  this  situation,  and  the 
related  cost  estimates.    They  constitute  a  clear  and  comprehensive  baseline  for  assessing  the 
progress of the implementation globally and at the level of each project. 

their  detailed  decommissioning  plans.  The  plans  describe 

submitted 

It  should  be  noted  that  unlike  in  previous  programming  periods,  the  current  NDAP  did  not 
include further support to mitigate the consequences of the early closure of the nuclear power 
plants. It restricted EU support to the tasks described in the approved detailed decommissioning 
plans, so focussing on safety related activities. 

11 

 
 
 
The specific objectives for each programme are summarised in the table below.  

Table 3: Specific objectives of NDAP 

Plant 

Specific Objectives (as per Article 2.2 of the 2013 NDAP Regulations) 

)

G
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(
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o
K

)
K
S
(
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i
n
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o
B

)
T
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(
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n

i
l

a
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g
I

1. Performing dismantling in the turbine halls of units 1 to 4 and in auxiliary buildings; 

2. Dismantling of large components and equipment in the reactor buildings of units 1 to 
4; and 

3.  Safely  managing  the  decommissioning  waste  in  accordance  with  a  detailed  waste 
management plan.  

1. Performing dismantling in the turbine hall and auxiliary buildings of reactor V1, to be 
measured by the number and type of systems dismantled; 

2.  Dismantling  of  large  components  and  equipment  in  the  V1  reactor  buildings,  to  be 
measured by the number and type of systems and equipment dismantled; and 

3.  Safely  managing  the  decommissioning  waste  in  accordance  with  a  detailed  waste 
management  plan,  to  be  measured  by  the  quantity  and  type  of  safely  conditioned 
waste. 

1. Defueling of the reactor core of unit 2 and the reactor fuel ponds of units 1 and 2 into 
the dry spent fuel storage facility; 

2. Safely maintaining the reactor units; and 

3.  Performing  dismantling  in  the  turbine  hall  and  other  auxiliary  buildings  and  safely 
in  accordance  with  a  detailed  waste 
managing  the  decommissioning  waste 
management plan.  

Source: 2013 NDAP Regulations 

Additionally,  detailed  objectives,  targets,  milestones  and  performance  indicators  have  been 
defined  for  each  programme  and  each  specific  objective 
in  annexes  to  the  detailed 
implementation procedures. 

To achieve these objectives, inputs such as EU and national financial resources and expertise are 
translated  into  programme  activities.  These  activities  are  defined  in  the  annual  work 
programmes  prepared  by  the  concerned  Member  States,  and  further  detailed  in  project 
documentation. 

The results and impacts naturally mirror the objectives of the NDAP as presented above.  

2.2.2  Management of the NDAP 

level  of  technical  capacity  and  expertise  necessary  to 

implement 
Due  to  the  high 
decommissioning  activities  and  within  the  historical  context  at  that  time, 
in  2001 
implementation  tasks  were  delegated  to  the  European  Bank  for  Reconstruction  and 
Development  (EBRD).  The  accession  of  the  three  countries  to  the  EU  has  given  access  to 
additional  options.  In  Lithuania,  the  Central  Project  Management  Agency  (CPMA),  a  national 
public-sector  body,  has  been  selected  and  approved  by  the  Commission  to  act  as  an 
Implementing  Body  since  2003.  Since  2015,  Slovakia  has  also  formally  established  a  national 
implementation channel, the Slovak Innovation and Energy Agency (SIEA), which implements all 
new projects. The first project to be implemented by the SIEA was approved in May 2017. Thus 
in Lithuania and Slovakia the implementation of union budget is progressively being transferred 
to national bodies. 

Each  concerned  Member  State  appoints  a  Programme  Coordinator  (ministerial  or  state 
secretary rank) to be responsible for the overall programming, coordination and monitoring of 
the decommissioning programme. 

12 

 
 
 
 
 
 
 
In Bulgaria and Slovakia, the facilities to be decommissioned were transferred from the nuclear 
plant  operator  to  separate  organisations;  respectively  State  Enterprise  Radioactive  Waste  
(SERAW) and Jadrová a vyraďovacia spoločnosť (JAVYS). In Lithuania, the Ignalina Nuclear Power 
Plant  (INPP)  organisation  has  been  maintained  but  with  a  new  mission.  The  three 
decommissioning  operators  are  the  owners  of  the  nuclear  licenses  and  they  implement  the 
decommissioning programme under the supervision of the Programme Coordinator and of the 
Implementing Bodies. 

For  each  programme,  a  Monitoring  Committee  ensures  a  coordinated  monitoring  of  all 
measures and financial assistance under the decommissioning programme. It is chaired by the 
Programme Coordinator and a representative of the Commission. The other members are the 
Financial Coordinator and representatives of the Implementing Bodies. 

Figure 2: NDAP key stakeholders and their relations 

Each  of  the  three  Member  States  concerned  submits  to  the  Commission  an  annual  work 
programme  which  updates  the  implementation  schedule  of  the  detailed  decommissioning 
plans, taking into account the latest developments in the implementation of the projects. The 
annual  work  programmes  must  however  remain  within  the  objectives  and  scope  of  the 
decommissioning plans as initially adopted by the Commission. 

The Commission reports annual progress on the NDAP to the Council, the European Parliament 
and  the  general  public.  This  annual  reporting  concludes  the  annual  planning  and  monitoring 
cycle for that year and constitutes the basis for the adoption of the following year’s annual work 
programmes.  

2.3  Baseline and points of comparison  

The 2011 IA framed the Commission initiative in these terms: 'to eliminate as far as possible the 
source  of  radiological  hazard,  the  closed  reactor  units  must  remain  closed,  be  defueled  and 
safely  dismantled.  In  the  context  of  ‘early  closure’  and  considering  the  related  economic 
consequences for the three concerned Member States this closure must become irreversible.  At 
present this stage is not yet reached'. 

13 

 
 
By the end of the previous financing period, JAVYS, the decommissioning operator in Slovakia, 
had obtained its first decommissioning license for Bohunice V1. In Bulgaria, the Kozloduy units 1 
and 2 were defueled and transferred from the plant operator to the decommissioning division 
of  SERAW.  In  Lithuania,  the  defueling  operations  of  the  reactor  of  unit  2  in  Ignalina  were  on 
hold while the construction of the Spent Fuel Safe Storage Facility had to be completed. In all 
three concerned Member State, the political movements demanding the restart of the reactors 
were losing influence. 
The  Commission's  initial  proposal7  for  a  single  NDAP  Regulation  foresaw  an  extension  of 
financial support from the Union with the general objective to reach an irreversible state within 
the decommissioning process of Kozloduy units 1 to 4, Ignalina units 1 and 2 and Bohunice V1 
units  1  and  2,  in  accordance  with  their  respective  decommissioning  plans,  while  keeping  the 
highest level of safety. During the legislative process of adopting the NDAP Regulation, the there 
was  a  broad  consensus  in  the  Council  in  recognising  the  need  for  continued  financing  of 
decommissioning  of  the  nuclear  reactor  units.  Accordingly  the  Legislator  intervened  on  the 
initial Commission proposal, in particular by increasing the budget for all three Member States 
and the duration of the assistance for LT and SK. 

The  baseline  is  defined  by  the  detailed  decommissioning  plans  submitted  by  each  concerned 
Member  State  in  2014  and  adopted  by  the  Commission  as  annexes  to  the  detailed 
implementation procedures. The programmes overall cost estimates were thereby included and 
updated  with  respect  to  previous  issues;  in  one  case  the  estimates  were  revised  slightly 
downwards (-1% for the Kozloduy programme), whereas in the other two cases the estimates 
increased  (+40%  and  +24%  for  the  Ignalina  programme  and  the  Bohunice  programme 
respectively).  The  increase  of  the  Ignalina  programme  cost  estimate  came  along  with  a  nine-
year extension of its overall duration. 

The  Commission  assessed  that  the  detailed  decommissioning  plans  were  complete,  relevant, 
comprehensive,  and  the  overall  cost  estimations  were  generally  appropriate,  as  further 
supported by an independent review8. Thus both the limits of the scope of EU support and the 
baseline  costs  to  monitor  cost-effectiveness  have  been  clearly  drawn.  The  work  breakdown 
structure and the schedule form the base for assessing the timeliness of the implementation. 

3 

IMPLEMENTATION / STATE OF PLAY 

The decommissioning operators are all fully working on decommissioning activities. Slovakia has 
advanced the most and is currently carrying out Dismantling &  Decontamination (D&D) in the 
reactor  building  at  the  Bohunice  site.  D&D  is  well  advanced  in  the  auxiliary  buildings  at  the 
Kozloduy  and  Ignalina  sites.  In  addition,  the  key  safety-related  project  in  Lithuania  to  remove 
the  spent  nuclear  fuel  from  the  RBMK  reactor  (similar  to  that  used  in  Chernobyl)  is  now  well 
underway. Defueling of Unit 2 reactor core was finalised on 25 February 2018 (i.e. 15 months 
ahead of schedule). 

The  programmes  are  generally  on  track  to  achieve  the  specific  objectives  of  the  Regulations 
with  the  funding  provided  in  this  MFF.  A  clear  trend  towards  increased  efficiency  has  been 
observed throughout the monitoring activities, as confirmed by  independent experts. In some 
areas, the risk of delays needs further mitigation and close follow-up. 

At  Kozloduy  and  Bohunice,  the  removal  of  spent  fuel  from  the  reactors  and  adjacent  reactor 
pools  and  its  transfer  to  an  external  dedicated  interim  storage  facility  (i.e.  defueling)  was 
completed  during  the  2007  –  2013  period.  Defueling  is  currently  underway  in  Lithuania  at 
Ignalina. In February 2018, the second reactor has been completely defueled and the transfer of 

7 COM(2011)783 
8 Deloitte 2016 

14 

 
                                                            
the remaining spent fuel from the ponds in the reactor building to the new safe storage facility 
is expected to be completed by July 2022.9 

Important waste management infrastructure projects have recently been commissioned or are 
being commissioned at Kozloduy and Ignalina. Most of the other final key waste management 
infrastructure  projects  are  approved  and  under  procurement  or 
implementation.  This 
infrastructure is critical to the functioning of the ‘waste management systems’ set up for each 
programme  and  has  been  the  object  of  much  of  the  investment  in  the  early  years  of  the 
programmes.  Slovakia  already  possessed  much  of  the  requisite  infrastructure  prior  to 
decommissioning and the development of its waste management system is highly mature.  

Actual  physical  dismantling  of  equipment  is  progressing  quickly  at  all  three  sites  compared  to 
the  first  decade  of  programme 
implementation.  This  reflects  the  nature  of  nuclear 
decommissioning  programmes,  which  requires  significant  upfront  investment  in  planning  and 
infrastructure  development  as  explained  above.  Dismantling  & 
waste  management 
Decontamination (D&D) work in the Turbine Halls and Auxiliary buildings outside the Controlled 
Area has advanced substantially and is expected to  be largely completed by 2020 at Kozloduy 
and Ignalina and significantly sooner at Bohunice.  

Except  for  Bohunice,  limited  D&D  work has  been  undertaken in  the  reactor  buildings  to  date, 
reflecting  the  varying  timelines  of  programmes.  The  Kozloduy  &  Ignalina  programmes  are 
currently  preparing  the  technical  design  for  the  dismantling  of  the  reactor  cores  /  primary 
circuit, which will begin in the coming years. The Bohunice programme is advancing well in D&D 
of the primary circuit, with key projects well underway. 

4  METHOD 

4.1 

Previous evaluations and other reports 

The  latest  Commission's  evaluation  report  dates  back  to  201110.  In  the  same  period  the 
European Court of Auditors realised a performance audit11. Their recommendations were taken 
up in the 2014-2020 NDAP legal bases. 

The  European  Court  of  Auditors  has  conducted  a  follow-up  audit  of  the  NDAP  in  2015.  The 
conclusions of the Special Report12 issued on 20 September 2016 have been taken into account 
in the design of this evaluation. 

A complete list of reports analysing the situation of the NDAP can be found in Annex 1. 

4.2 

Evidence from monitoring 

The programme benefits from an intense monitoring process leveraging the strong managerial 
competences  of  the  main  stakeholders  (Implementing  Bodies,  programme  coordinators  and 
decommissioning operators). The main stakeholders report to the Commission the progress of 
the  technical  and  financial  implementation  in  detail  every  six-month  in  a  comprehensive 
quantitative  monitoring  report.  It  presents  a  comprehensive  overview  of  the  implementation 
including a comparison of the actual performance relative to the baseline schedule and progress 
made  in  achieving  the  objectives  of  the  programme.  Monitoring  reports  are  reviewed  and 
approved by the respective Monitoring Committees. 

Based  on  the  internal  assessment  of  the  results  of  periodic  monitoring  actions  and  the 
documentation provided  by  stakeholders  the Commission drafts  an  annual  report. Three such 

9  Annual Work Programme 2017 
10 COM(2011)432 
11 ECA Special Report No 16/2011 
12 ECA Special Report No 22/2016 

15 

 
                                                            
reports  from  the  Commission  to  the  European  Parliament  and  the  Council  on  the 
implementation  of  the  work  under  the  nuclear  decommissioning  assistance  programme  to 
Bulgaria, Lithuania and Slovakia have been issued so far: in 2015,13 in 201614 and 2017.15 
Besides the scheduled monitoring activities, the Commission commissioned an external study16, 
which  included  an  evaluation  of  the  programmes’  global  cost  estimations,  an  overall  risk 
assessment,  an  analysis  of  the  national  funds  and  other  sources,  and  an  analysis  of  the 
robustness  of  the  state  budgets.  In  addition  in  2017,  an  auditor  verified  the  conditions  under 
which  procurement  procedures  have  been  carried  out  by  the  Implementing  Bodies  under  the 
NDAP. 

4.3 

Specific evaluation actions 

In 2016, the Commission started the preparation for the mid-term evaluation by publishing the 
evaluation roadmap17 and by procuring in 2017 an external study18 to complement the existing 
body  of  evidence.  The  contractor's  report  addresses  directly  the  evaluation  questions  and  is 
based on in depth desk research, interviews with targeted stakeholders, field visits, analysis of 
the  general  public  consultation  and  a  targeted  consultation,  a  benchmarking  exercise  with 
comparable  instruments,  and  an  expert  panel.  Annex  3  provides  a  detailed  description  of  the 
contractor's activities. 
The Open Public Consultation19 has been accessible for an extended period of 14 weeks from 23 
June to 29 September 2017 and has elicited 20 contributions from the public. 

The  main  stakeholders  of  the  programme  have  been  directly  involved  in  the  evaluation  with 
regular  reporting  of  the  progress  to  the  three  Monitoring  Committees  and  the  Nuclear 
Decommissioning Assistance Committee.  

4.4 

Limitations and robustness of findings 

Stakeholders  with  a  deep  knowledge  of  the  programme  are  limited  in  number  and  generally 
directly involved in the programme in some way – e.g. Implementing Bodies, decommissioning 
operators  and  Programme  Coordinators.  This  is  due  primarily  to  the  technical  nature  of  the 
programme and the limited circulation of detailed information outside this circle. This also likely 
contributed to the limited response received to the Open Public Consultation launched by the 
Commission  or  the  targeted  e-survey  consultations  launched  by  the  evaluation  contractor  to 
external  actors  on  the  national  level.  Indeed,  a  number  of  stakeholders  contacted  for  the 
targeted consultation responded that they did not feel adequately informed to respond to the 
survey. 

The assessment of the efficiency of the assistance programme was rendered more difficult by a 
lack  of  relevant  cost  data  from  comparable  decommissioning  projects.  Indeed,  there  are  real 
barriers to sharing cost data publicly. At the moment, numerous cost estimates are available for 
decommissioning  projects  worldwide  but  few  actual  cost  reports  for  completed  projects  have 
been made public. 

Some challenges were faced in the analysis of efficiency internally within each programme and 
through  comparison  between  programmes  due  to  varying  approaches  for  project  /  financial 

13 COM/2015/078 
14 COM/2016/0405 
15 COM/2017/0328 
16 Deloitte 2016 
17 ENER - PLAN/2016/249 
18 EY 2018 
19 https://ec.europa.eu/energy/en/consultations/ 
consultation-mid-term-evaluation-nuclear-decommissioning-assistance-programme 

16 

 
                                                            
management.  Each  decommissioning  operator  has  developed  different  work  breakdown 
structures,  cost  structures  and  modalities for  monitoring  expenditure  and  results  that are  not 
entirely  comparable  between  programmes,  nor  do  they  always  align  neatly  internally  within 
programmes.  This  presented  challenges  in  analysis,  in  particular  of  efficiency,  and  limits 
comparison between programmes or with other decommissioning programmes. While it did not 
significantly impact the validity of findings, it limited the extent to which quantitative data from 
different sources could be fully integrated within and compared across programmes. 

The  introduction  of  the  Earned  Value  Management  (EVM)  System  in  the  three  programmes 
from  2014  delivered  valuable  results.  A  full 
implementation  of  the  system  requires 
modifications  in  the  procedures  and  organisations  involved,  from  the  decommissioning 
operators  to  their  contractors  and  sub-contractors.  While  considerable  progress  has  been 
noted, the progressive adoption of the methods and tools provided by the EVM System is still 
relatively  recent;  therefore  the  evaluation  met  some  limitations  in  measuring  actions  and 
contracts started before the EVM System introduction. 

The  initial  analysis  of  the  intervention  logic  clarified  that  the  possible  social  and  economic 
impacts of the intervention, while considered explicitly in the 2011 IA, had not been associated 
to any objectives in the 2013 NDAP Regulations adopted by the legislator. These impacts have 
eventually been analysed in less detail than planned in the evaluation roadmap. 

5  ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS 

The  evaluation  was  conducted  against  the  five  main  criteria  set  up  by  the  Better  Regulation 
guidelines  and  toolbox20:  relevance,  coherence,  effectiveness,  efficiency  and  EU  added  value. 
The eight evaluation questions covering the five evaluation criteria are summarised in Annex 4. 
Unless  otherwise  specified,  the  answers  and  analysis  refer  to  the  period  2014-2017  and  are 
based on the study prepared in support of this evaluation.21 

5.1  Relevance 

5.1.1  Evaluation Question 1 

To what extent are the general and specific objectives of the NDAP still 
appropriate in relation to the existing needs? 

5.1.1.1  The programme objectives at general and specific levels remain relevant 

The general objective to assist Member States in implementing the steady process towards the 
decommissioning  end  state  of  the  reactors  in  question  in  accordance  with  their  respective 
decommissioning plans, whilst maintaining the highest level of safety and the specific objectives 
(see Table 3: Specific objectives of NDAP) set out for the programmes in Bulgaria, Lithuania and 
Slovakia in the 2013 NDAP Regulations remain relevant. Indeed, the underlying need to safely 
remove  or  reduce  radiological  hazards  through  decommissioning  remains  as  long  as  all  highly 
radioactive  materials  have  not  been  treated;  as  well  as  the  need  for  continued  assistance  to 
provide  funds  at  the  right  time  ensuring  the  uninterrupted  decommissioning  of  the  nuclear 
power plants in question. 

Continued progress in the decommissioning at the three plants would likely have been impacted 
in the absence of EU support. The NDAP thus continues to support a stepwise reduction in the 
level of risk and radiological hazard at the three sites concerned, in particular at Ignalina where 
defueling  operations  are  ongoing.  Current  decommissioning  strategies  for  the  three  NDAP 
programmes remain aligned with the specific objectives set out for each programme. 

20 https://ec.europa.eu/info/better-regulation-guidelines-and-toolbox_en 
21 EY 2018 

17 

 
                                                            
5.2  Coherence 

5.2.1  Evaluation Question 2 

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

The  assessment  focused  primarily  on  the  extent  to  which  the  2013  NDAP  Regulations  are 
themselves coherent with EURATOM / EU acquis. 

5.2.1.1  The NDAP is coherent with the Euratom Treaty’s acquis in the area of nuclear 

safety and constitutes an exception to the financial responsibilities for the 
management of spent nuclear fuel and radioactive waste 

Coherence with the Euratom Treaty’s acquis in the area of nuclear safety and management of 
spent nuclear fuel and radioactive waste has been embedded in the legal base of the NDAP. The 
preamble of the 2013 NDAP Regulations states that the decommissioning of the nuclear power 
plant  covered  by  this  Regulation  should  be  carried  out  in  accordance  with  the  legislation  on 
nuclear  safety,  namely  Council  Directive  2009/71/Euratom,  [and]  waste  management,  namely 
Council Directive 2011/70/Euratom.  

The  decommissioning  activities  have  also  been  implemented  in  coherence  with  radiation 
protection  law,  covering  basic  safety  and  emergency  preparedness  and  response.  Reporting 
issued by Regulators between 2014 and 2016 has not signalled any exceeding of dose limits for 
staff and contractors working on site. Radiological activity surrounding sites is monitored in all 
countries  and  has  shown  no  abnormal  levels  of  radiological  release  to  the  surrounding 
environment.  More  generally,  Regulators’  reports  and  company  policies  of  decommissioning 
operators indicate that requirements on the health and safety of workers are fully respected. 

While  the  legal  base  ensures  coherence,  the  NDAP  itself  constitutes  an  exception  to  some 
underlying principles enshrined in the Euratom acquis. On the one hand, the support provided 
by  the  NDAP  has  played  an  important  role  in  accelerating  decommissioning  efforts  in  a  safe 
manner and avoiding the passing on of an undue burden to future generations, a fundamental 
principle in international and EU law. However, the NDAP derogates to the principle, sanctioned 
by the Council Directive 2011/70/Euratom, that the costs for the management of spent fuel and 
radioactive waste is borne by those who generated those materials. The exceptional nature of 
this programme is due to the specific historical context recognised by the Accession Treaties. 

The  Council  adopted  Directive  2011/70/Euratom  on  the  safe  and  responsible  management  of 
spent fuel and radioactive waste management. Within this framework, complementary efforts 
are  undertaken  by  the  Commission  to  encourage  and  support  all  Member  States  in  the 
development  of  solutions  for  long  term  management  of  spent  fuel  and  high  level  radioactive 
waste  in  line  with  legal  obligations,  as  communicated  in  its  2017  report22.  These  actions  are 
highly complementary to the NDAP in that they provide support to the three Member States for 
aspects of decommissioning not  covered by  the NDAP (e.g. the final disposal of spent nuclear 
fuel). 

5.2.1.2  The NDAP has also ensured coherence with other relevant EU acquis, in areas 

such as environmental and social protections 

The implementation of the NDAP has been coherent with the principles and obligations of the 
Environmental  Impact  Assessment  Directive.23  Environmental  Impact  Assessments  have  been 
conducted  across  all  programmes  for  both  decommissioning  programmes  and  /or  individual 
projects in compliance with national law.  

22 COM/2017/0236 
23 Directive 2011/92/EU 

18 

 
                                                            
The NDAP has also been implemented in compliance with relevant social protections in EU law. 
The decommissioning process has entailed a process of organisational transformation, creating 
in  some  cases  collective  redundancies.  These  cases  have  been  managed  in  compliance  with 
relevant EU legislation, such as the Collective Redundancies Directive concerning the situation 
of workers affected by decisions of employers to lay off a group of employees or the Transfer of 
Undertakings  Directive  protecting  employees'  rights  in  the  event  that  an  undertaking  is 
transferred from one employer to another.  

While the NDAP was coherent with the relevant social acquis, stronger linkages could have been 
assured  with  some  EU  instruments,  namely  the  European  Structural  and  Investment  Funds 
(ESIF). National authorities remained solely responsible for designing strategies to mitigate the 
socio-economic impact of plant closure. However, in none of the three Member States did the 
relevant authorities adopt formal strategies as is recognised as best practice. 

5.3  Effectiveness 

5.3.1  Evaluation Question 3 

To what extent have the objectives of the NDAP been achieved for each of the 
three programmes? 

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

5.3.2  Evaluation Question 3.1 

Overall, what level of progress has been made towards the objectives of each 
national programme? Is the progress in line with the decommissioning 
baseline adopted by the Commission? If not, what is the risk that objectives 
will not be achieved? 

5.3.2.1  Programmes overall are making reasonable progress towards objectives, but 

continued proactive efforts will be necessary 

Major achievements have been reached in the Ignalina and Kozloduy programmes with regards 
to key waste management infrastructure projects that had been hampered by serious setbacks 
in the past financial framework. In Lithuania, the commissioning of the Intermediate Spent Fuel 
Storage  Facility  puts  the  programme  on  track  to  complete  the  critical  task  of  defueling.  In 
Bulgaria,  the  on-going  commissioning  of  the Plasma  Melting  Facility and the  Size  Reduction & 
Decontamination Workshop open the way to ramping up D&D activities and clearing out waste 
backlog.  

Programmes can generally be considered to be on track towards achieving the objectives set for 
this programming period – with some delays to recover. In particular, the Bohunice programme 
has  worked  proactively  to  optimise  programme  implementation  in  the  final  years  in  light  of 
some technical challenges previously faced. The Kozloduy programme will also need to define a 
path for recovering delays, partly due to issues faced in the previous MFF, which have impacted 
the pace of advancement in the Controlled Area. The generally satisfactory progress, as well as 
the room for improvement, is reflected in the key performance indicators, including the physical 
progress  indicators  (presented  in  the  following  subsections)  and  the  Schedule  Performance 
Indicators.  The  critical  path  analysis  shows  that  it  remains  possible  to  achieve  the  NDAP 
objectives  and  to  complete  the  decommissioning  programmes  within  the  planned  time. 
However,  the  Schedule  Performance  Indicators  show  that  the  programmes  are  accumulating 
delays  in  projects  which  are  not  on  the  critical  path.  Figure  3  shows  how  the  Earned  Value 

19 

 
(green  line),  a  global  indicator  of  progress  across  the  whole  of  activities  making  up  each 
programme,  is  lagging  slightly  behind  the  Planned  Value  (blue  line)  as  determined  in  2014  by 
the  decommissioning  plan.  The  dashed  blue  line  represents  the  mitigating  actions  for  the 
implementation  of  the  Bohunice  programme  (see  section  0)  confirming  the  programme  end 
date  by  2025.  See  Annex  5  for  a  short  introduction  to  the  main  EVM  indicators  and  to  the 
principles of critical path analysis. 

Figure 3 Evolution of Earned Value Management indicators 

Source: Monitoring reports 2017-H2 

20 

 
 
At  present,  there  is  not  an  immediate  risk  that  the  status  of  on-going  waste  management 
infrastructure projects – e.g. the Near Surface Repository and Landfill Facility at Ignalina and the 
Near  Surface  Repository  at  Kozloduy  –  will  impact  wider  decommissioning  efforts,  because 
temporary  storage  facilities  are  sufficient.  These  particular  projects  should  continue  to  be 
monitored carefully. In addition, the capacity in treating waste streams appears adequate at this 
point in time, but it shall be monitored against D&D objectives. 

5.3.2.2  Progress against waste management targets has been slow to date, although 

programmes should be able to recover delays 

The physical performance indicators demonstrate lower than expected progress to date across 
all  three  programmes.  This  underperformance  has  mainly  been  the  result  of  uncertainties 
concerning radiological inventory and / or lack of anticipation of regulatory procedures leading 
to under or overestimations of target values, slower than planned progress with D&D activities, 
technical  challenges  related  to  specific  legacy  waste  streams  and  some  delays  in  the 
commissioning  of  waste  management  facilities.  These  delays  remain  largely  recoverable  at 
present (during the current MFF). 

5.3.2.3  D&D works in the turbine halls and auxiliary buildings come to an end in 

Slovakia and are progressing well in Lithuania & Bulgaria 

At  Bohunice,  this  stage  of  decommissioning  is  currently  winding  down  with  the  final  projects 
approaching completion. At Kozloduy and Ignalina, D&D work is advancing well or even ahead 
of  schedule  in  the  turbine  halls  and  other  auxiliary  buildings.  Monitoring  reports  show  that 
decommissioning  operators  have  successfully  managed  to  identify  and  address  inefficiencies 
and  remove  bottlenecks  as  they  have  been  identified.  This  represents  the  culmination  of 
significant efforts on the part of decommissioning operators, in particular in Lithuania by virtue 
of the relatively large volume of equipment to be dismantled and the fact that the equipment in 
the  Ignalina  Turbine  Hall  is  subject  to  a  higher  degree  of  contamination  and  thus  requires 
relatively greater effort.  

5.3.2.4  The Bohunice programme has embarked on major physical works in the 

Controlled Area, whereas the Ignalina and Kozloduy programmes remain in 
the preparatory phase 

Since the beginning of the current MFF, significant D&D work has begun in the Controlled Area 
in Bohunice. Some early technical challenges have been met, but the decommissioning operator 
has sorted them out and set out an optimised implementation strategy to avoid impact on time 
and  minimise  impacts  costs.  This  activity  will  form  the  largest  part  of  works  during  the 
remainder of the current MFF and drives the critical path of the overall programme in its final 
stages.  

Minor works have been conducted to date in the Reactor Buildings and other auxiliary buildings 
in the Controlled Area at Kozloduy and Ignalina. Both programmes remain at different stages of 
the preparatory phase for D&D work in this area. At Kozloduy, an important study is underway 
to develop the technical approach for D&D of large components in the Controlled Area. During 
the  current  MFF,  early  physical  works  have  not  advanced  entirely  as  foreseen  in  the  baseline 
schedule  due  to  late  delivery  of  the  Decommissioning  Licenses  linked  to  difficulties  in  the 
previous  MFF  with  regards  to  the  approval  of  the  Environmental  Impact  Assessment.  At 
Ignalina,  the  technical  design  work  is  at  a  relatively  earlier  stage.  While  this  work  has  made 
significant  progress,  some  difficulties  have  been  encountered  with  a  potential  impact  on  the 
start of large-scale physical works (in any case scheduled beyond the current MFF). In this area 
the  Ignalina  programme  faces  technical  challenges  associated  with  its  first-in-kind  nature, 
whereas  the  Kozloduy  programme  can  draw  on  lessons  learnt  from  Bohunice  and  Greifswald 
NPP in Germany.  

21 

 
The  following  sub-sections  provide  a  more  detailed  assessment  of  progress  achieved  for  each 
programme, as well as the main risks identified.  

5.3.2.5  Bulgaria 

The three specific objectives for the Kozloduy Programme are: 

- 

Performing dismantling in the turbine halls of units 1 to 4 and in auxiliary buildings; 

-  Dismantling of large components and equipment in the reactor buildings of units 1 to 4; 

- 

Safely  managing  the  decommissioning  waste  in  accordance  with  a  detailed  waste 
management plan.  

D&D activities are progressing well outside of the Controlled Area, in particular in the Turbine 
Hall (Specific Objective 1) 

The first dismantling work of non-nuclear equipment was initiated in 2010, but dismantling only 
commenced at full pace at the beginning of the current MFF due to late transfer of Units 3 & 4 
to  SERAW  management  during  the  previous  MFF.  One  of  the  key  objectives  of  the  current 
programming  period  is  to  finalise  dismantling  of  the  Turbine  Hall  for  Units  1  –  4  (and  other 
auxiliary buildings). This includes the dismantling of approximately 40 400 tonnes of metal from 
160  main  and  auxiliary  systems.  SERAW  is  currently  on  track  to  accomplish  this  objective  by 
August 2019, despite facing some early issues. By the end of 2016, 21 628 tonnes of metal had 
been dismantled from the equipment of the Turbine Hall. This represents 96% of the planned 
target to date as per the Annual Work Programmes. In addition, 7 744 tonnes of civil structure 
have  been  demolished  in  the  turbine  hall  by  the  end  of  2016  –  122%  of  planned  progress  to 
date. 

Progress has been slower than expected thus far in the Controlled Area (Specific Objective 2) 

Initial  physical  dismantling  work  in  the  Controlled  Area  has  been  undertaken  in  serviced  and 
semi-serviced  areas  since  2014.  By  the  end  of  2016,  299  tonnes  of  material  in  the  Controlled 
Area  had  been  dismantled  –  75%  of  planned  target  to  date  as  per  the  Annual  Work 
Programmes. In order to avoid a build-up of dismantled material in the Controlled Area awaiting 
subsequent  decontamination,  the  pace  of  dismantling  was  decreased 
in  2016  until 
commissioning of the SRDW planned for 2017 in the 2017 Annual Work Programme. The delay 
in the commissioning of the SRDW was due to mainly to procurement delays stemming largely 
from  the  previous  MFF.  Recovery  measures  are  planned  to  be  taken  to  increase  capacity 
through work in shifts once the SRDW is operational. 

More  significant  D&D  works  in  the  Controlled  Area  started  in  2016,  approximately  two  years 
later than planned. This is largely due to delays in the delivery of the Decommissioning Licenses 
that stem from the previous MFF. 

22 

 
Figure 4 Kozloduy Programme dismantling physical progress 

Source: Monitoring reports 2017-H1 

Figure 4 shows the physical progress of the dismantling activities. It illustrates the ratio between 
the  actual  quantity  of  dismantled  materials  (dark  blue)  to  the  total  quantity  to  be  dismantled 
(light blue) and put it in relation to the scheduled duration of those activities. 

Waste  management 
infrastructure expected to be commissioned in 2018 (Specific Objective 3) 

infrastructure  projects  are  on  a  positive  trajectory,  with  key 

The construction of the National Disposal Facility will allow for disposal of low and intermediate 
level  short  lived  radioactive  waste.  The  absence  of  a  disposal  path  for  the  waste  produced 
would  eventually  block  decommissioning  activities.  The  transboundary  Environmental  Impact 
Assessment started in the previous MFF resulted in significant delays. It affected the approval of 
the  technical  design  and  issuance  construction  permits.  SERAW  took  mitigation  measures  to 
minimise the impact of delays by restructuring the project scope. In an important milestone, the 
Regulator  approved  the  National  Disposal  Facility  technical  design  in  March  2017  and  the 
construction permit was issued shortly thereafter. 

The  Plasma  Melting  Facility  relies  on  an  innovative  technology  to  significantly  reduce  the 
volume  of  radioactive  waste  to  be  disposed  of.  This  allows  reducing  by  the  same  factor  the 
disposal costs. In the past MFF, this project suffered from a number of difficulties and delays, 
which have been eventually resolved during this MFF. The commissioning of the facility is  on-
going. 

Progress in those two key projects and other projects like the construction of the Size Reduction 
&  Decontamination  Workshop  is  critical  for  removing  bottlenecks,  in  particular  for  processing 
contaminated  materials  arising  from  the  decommissioning  operations,  and  to  expand  the 
capacity of SERAW to match future expected waste flows from decommissioning. 

Performance  of  radioactive  waste  management  activities  has  also  been  impacted  by  wider 
delays in the decommissioning process. Technical issues faced with the removal of legacy waste 
from  Auxiliary  Buildings,  for  example,  has  impacted  waste  management  activities.  Similarly, 
delays  in  work  in  the  Controlled  Area  can  explain  the  low  level  of  progress  achieved  to  date. 
Performance gaps can also be noted with free release of materials. While the level of progress 
achieved  against  the  detailed  objectives  in  the  detailed  implementation  procedures  has  been 
low to date, the programme has consistently performed in a satisfactory manner against annual 
targets set in the Annual  Work Programme, suggesting  that the waste management system is 
capable of performing when progress with dismantling allows. 

23 

 
 
 
 
5.3.2.6  Slovakia 

The three specific objectives for the Bohunice programme are: 

- 

Performing  dismantling  in  the  turbine  hall  and  auxiliary  buildings  of  reactor  V1,  to  be 
measured by the number and type of systems dismantled; 

-  Dismantling  of  large  components  and  equipment  in  the  V1  reactor  buildings,  to  be 

measured by the number and type of systems and equipment dismantled; 

- 

Safely  managing  the  decommissioning  waste  in  accordance  with  a  detailed  waste 
management  plan,  to  be  measured  by  the  quantity  and  type  of  safely  conditioned 
waste. 

The  dismantling  of  the  Turbine  Hall  is  completed  and  the  last  auxiliary  structures  (cooling 
towers) are under demolition (Specific Objective 1) 

By 2016, the dismantling of non-active systems had been almost achieved: the Diesel Group and 
Electric  Power  Supply  Systems,  the  Technical  Equipment  in  the  Turbine  Hall  and  the  external 
buildings. The last project remaining under implementation is the dismantling and demolition of 
the V1 NPP four cooling towers. The project is planned to be completed in 2018. 

Work  in  the  Reactor  Buildings  has  started,  initially  with  some  technical  difficulties,  and 
preparatory work on the dismantling of large components is expected to start by the end of 
2017 (Specific Objective 2) 

JAVYS received the license for  the stage  2  of  decommissioning  (Controlled Area) in December 
2014 which gives the green light to begin the dismantling process in the Reactor Building. One 
project has already been completed: the dismantling of insulation in Controlled Area with the 
dismantling of the technological equipment and piping systems. 

Difficulties with the implementation of the decontamination of the primary circuit have delayed 
subsequent  projects.  The  decontamination  of  the  primary  circuits  is  a  pre-condition  for  the 
dismantling  of  the  primary  circuits  of  Bohunice  V1  NPP.  After  several  months  of 
implementation, including the establishment of the decontamination circuit technology on the 
reactor  vessel,  the  original  contractor  faced  severe  technical  difficulties  and  was  unable  to 
finalise the project. The contract was terminated in 2016 in what constituted an important set-
back. JAVYS however developed a full revision of the project and the technology implemented 
by the original contractor to learn from this experience and gain know-how. The decision was 
taken  to  select  a  new  contractor  through  direct  tendering  and  the  decontamination  process 
restarted in 2017. The project has now been successfully completed. 

Most of the subsequent dismantling projects are on the programme critical path and depend on 
successful completion of the decontamination. In consequence, the dismantling of the reactor 
coolant system large components has been rescheduled for completion in 2022 (compared with 
2020  in  the  baseline  schedule).  In  order  to  optimise  the  final  steps  of  the  programme  and 
ensure  the  completion  of  the  activities  by  2025  despite  the  delays  incurred,  JAVYS  has 
reorganised  the  scope  of  some  projects  to  allow  their  simultaneous  implementation  and 
developed  a  new  strategy  for  the  implementation  of  the  three  final  projects  concerning  the 
Reactor and Auxiliary Building decontamination, building decommissioning, backfilling and site 
restoration  so  that  they  are  implemented  under  one  contract.  These  changes  should  allow  to 
recover the incurred delay at the expense of an increased complexity in projects interfaces and 
tendering process. 

24 

 
Figure 5 Bohunice Programme dismantling physical progress 

Source: Monitoring reports 2017-H1 

Figure 5 shows the physical progress of the dismantling activities. It illustrates the ratio between 
the  actual  quantity  of  dismantled  materials  (dark  blue)  to  the  total  quantity  to  be  dismantled 
(light blue) and put it in relation to the scheduled duration of those activities. 

Most legacy waste and waste produced by the decommissioning of non-Controlled Areas have 
been safely stored and the last storage facilities are under construction (Specific Objective 3) 

The  Bohunice  programme  has  benefited  from  the  availability  of  existing  waste  management 
infrastructure  for  several  contextual  reasons  (operation  of  several  other  reactors  on  site, 
shutdown and decommissioning of the A1 reactor prior to the V1 reactors). The last two waste 
management  projects  are  about  to  be  brought  to  operation.  The  Interim  Radioactive  Waste 
Storage facility was opened in August 2017 and additional radioactive waste disposal capacity at 
the Mochovce disposal site will be available in 2018.  

The  quantities  of  processed  waste  reported  in  the  Monitoring  Reports  are  significantly  lower 
than the overall targets. This is however not a signal of underperformance in waste processing. 
It is  rather  mainly  due to  the time shift of  projects  concerning the  primary  circuit dismantling 
and demolition of V1 NPP cooling towers resulting in a less waste being produced up to 2017. 

5.3.2.7  Lithuania 

The three specific objectives for the Ignalina Programme are: 

-  Defueling of the reactor core of unit 2 and the reactor fuel ponds of units 1 and 2 into 

- 

- 

the dry spent fuel storage facility; 

Safely maintaining the reactor units; and 

Performing  dismantling  in  the  turbine  hall  and  other  auxiliary  buildings  and  safely 
managing  the  decommissioning  waste 
in  accordance  with  a  detailed  waste 
management plan..  

Defueling  operations  are  proceeding  well  following  the  commissioning  of  key  waste 
management infrastructure (Specific Objective 1) 

With the start of operation of the Interim Spent Fuel Storage Facility in October 2016 a major 
milestone  has  been  met  allowing  for  the  critical  process  of  defueling  to  start.  In  addition, 
defueling of Unit 2 reactor core has been completed on 25 February 2018, 15 months ahead of 
schedule. 

The  Interim  Spent  Fuel  Storage  Facility  project  had  accumulated  significant  delays  in  previous 
programming  periods  due  to  a  variety  of  factors  that  eventually  led  to  a  suspension  of 
disbursements in January 2013. These delays had a direct impact and contributed significantly 

25 

 
  
to  the  extension  of  the  overall  duration  of  the  decommissioning  programme  in  the  latest 
version  of  the  detailed  decommissioning  plan.  In  2013,  a  new  management  of  INPP  started 
working  quickly  to  resolve  outstanding  issues  with  the  contractor.  Significantly,  pending 
commercial issues were resolved in November 2015 with no increase in the contract price. 

Figure 6 Ignalina Programmee progress of defueling operations 

Source: Monitoring reports 2017-H2 

Figure 6 shows the progress of the transfer of the spent fuel from the reactor core to the fuel 
ponds  in  the  reactor  building  and  finally  to  the  dry  storage  in  the  Interim  Spent  Fuel  Storage 
Facility,  the  end  stage  in  the  scope  of  the  NDAP.  Since  2011,  as  the  pre-existing  dry  storage 
facility was fully occupied, 1134 spent fuel assemblies remained in the reactor of unit 2 and the 
spent fuel ponds were fully filled with 14421 assemblies. 

INPP  has  ensured  continued  safe  maintenance  of  Units  1  &  2,  as  well  as  the  safety  of 
decommissioning activities (Specific Objective 2) 

The  continuing  presence  of  nuclear  fuel  in  the  reactor  and  spent  fuel  ponds  requires  the 
maintenance  of  a  high  level  of  safety  including:  i)  sub-criticality  of  spent  nuclear  fuel;  ii)  heat 
removal  from  the  reactor’s  core  and  spent  nuclear  fuel  pools;  and  iii)  confinement  of 
radionuclides, installation of barriers suppressing ionising radiation and control over release of 
radionuclides. 

Since  2014,  INPP  staff  has  ensured  safe  maintenance  of  Units  1  &  2  without  any  incident  as 
classified by the INES scale.24 The national nuclear safety authority, VATESI, carries out regular 
inspections and technical checks at INPP predominantly focused on safety requirements during 
maintenance,  fire  safety  and  ageing  management  of  structures,  systems  and  components 
important  to safety. VATESI also monitors INPP's safety culture through a safety culture index 
evaluating the less obvious factors that could have an impact on safety. The indicator has been 
maintained at an acceptable level during the period under evaluation. 

D&D  activities  are  progressing  well  in  the  Turbine  Hall  and  auxiliary  buildings  (Specific 
Objective 3) 

Dismantling activities are currently ahead of schedule in terms of overall number of tonnes of 
equipment  dismantled  in  the  Turbine  Hall.  By  the  end  of  the  first  semester  of  2017,  26  862 

24 The International Nuclear and Radiological Event Scale (INES) is a tool for communicating the safety 
significance  of  nuclear  and  radiological  events  to  the  public.  It  goes  from  1  (‘anomaly’)  to  7  (‘major 
accident’). 

26 

 
 
                                                            
tonnes of equipment had been dismantled in INPP  – 107% of the planned total to date as per 
the  Annual  Work  Programmes  and  66%  of  the  2020  target.  Equipment  dismantled  from  the 
Turbine  Hall  made  up  the  large  majority  of  this  tonnage  –  approximately  85%.  Work  in  the 
Turbine  Hall  is  currently  expected  to  be  completed  by  June  2019  in  line  with  the  baseline 
schedule.  

Decontamination  activities  are  progressing  well,  with  2  901  tonnes  dismantled  and 
decontaminated from 2014 to the end of 2016. Fragmentation and decontamination facilities in 
the Turbine Hall entered routine operation in 2014. Due to the higher-than-expected progress in 
dismantling,  some  challenges  were  initially  faced  with  the  quantity  of  wastes  generated.  In 
2015,  INPP  formulated  a  plan  for  the  more  efficient  use  of  space  within  the  Turbine  Hall  as 
buffer storage in order to more effectively decouple dismantling/fragmentation activities from 
the  decontamination  line.  In  addition,  the  decontamination  capacity  is  being  expanded  to 
ensure higher decontamination throughput in coming years. 

Figure 7 Ignalina Programme progress of dismantling activities 

Source: Monitoring reports 2017-H2 

As shown on Figure 7, the total amount of material is equivalent to 16 times the weight of the 
Eiffel tower. At present, over 25% has been dismantled and a large part of that material could 
be  decontaminated  to  a  level  that  allowed  its  recycling  outside  of  the  nuclear  industry  (free 
release). 

Important  achievements 
infrastructure projects underway should be monitored closely (Specific Objective 3) 

in  key  waste  management 

infrastructure,  but  other  key 

The Ignalina programme achieved important milestones with the on-going commissioning of the 
Solid Waste Management and Storage Facility (SWMSF). This progress represents an important 
achievement for the Ignalina programme having in mind the criticality of this infrastructure for 
the  decommissioning  process  and  the  level  of  difficulties  that  had  been  faced  in  previous 
programming periods with these large projects.  

A  number  of  other  key  infrastructure  projects  remain  in  early  stages  of  implementation  and 
have faced difficulties resulting in delays in their preparation. The award of the contract for the 
landfill  facility  for  short-lived  very  low  level  waste  was  delayed  in  the  tendering  process  for 
several  months.  The  schedule  for  the  Near  Surface  Repository  (NSR)  for  low  &  intermediate 
level  short-lived  waste  has  slipped  due  to  delays  incurred  during  the  design  phase  during 
previous  programming  periods  and  a  protracted  approval  process  under  the  current  MFF. 
Finally, progress on the bituminised waste storage facility remains dependent on a number of 
unknown variables due to close proximity with other facilities and upgrade works.  

While  slippage  in  project  schedules  can  be  noted,  delays  do  not  risk  creating  significant 
bottlenecks in waste streams in the medium-term at the time of the evaluation. 

27 

 
 
Challenges faced during the preparatory design activities for D&D in the Reactor Building will 
not significantly impact programme performance during the current MFF, but create the risk 
of delays after 2020 

Although  not  an  objective  included  in  this  programming  period,  the  start  of  physical  D&D 
activities in the Reactor Buildings may be delayed due to challenges faced in the preparation of 
design work 

The  Ignalina  programme  initially  called  on  external  expertise  for  the  development  of  the 
technical  design  and  safety  documentation  for  a  number  of  pilot  D&D  projects.  However  in 
2011 INPP has made the decision to conduct much of the preparatory technical design work for 
D&D in house. Since, the programme has largely used internal resources to leverage expertise 
of former plant staff and reduce the cost of this activity.  

Delays  in  preparatory  design  activities  for  D&D  in  the  Reactor  Buildings  have  resulted  from 
technical challenges and inadequate internal expertise. As a result, the programme is currently 
behind  the  projected  schedule  for  those  activities.  However,  these  delays  should  be  largely 
recovered during the current MFF once works begin given current project timelines. Preparatory 
work for  D&D  in the reactor  shaft has  lagged  behind due to  a  lack of  qualified personnel  and 
overall  rethinking  of  the  general  approach.  INPP  has  also  come  to  the  conclusion  that 
preparatory  work  for  the  dismantling  of  the  irradiated  graphite  from  the  core  cannot  be 
completed relying only on in-house resources. Technical Specifications for the procurement of 
technical  support  to  complete  this  work  is  currently  underway  over  seven  years  after  the 
procurement for the original project was cancelled. 

These challenges should have limited impact on the achievement of objectives for the current 
MFF, but may lead to a delayed start of large-scale physical works in the post-2020 period. 

5.3.3  Evaluation Question 3.2 

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

5.3.3.1  The (on-going) commissioning of key waste management infrastructure 

projects is supporting a ramping up in decommissioning activities 

The construction of waste management infrastructure is often not thought of as being part of 
the decommissioning process itself. However, this infrastructure is a necessary pre-condition for 
decommissioning to begin. As such, it is included in the detailed decommissioning plan where 
existing infrastructure is not adequate or available. The three Member States had varying level 
of  pre-existing  infrastructure  in  place.  Slovakia,  where  decommissioning  of  Bohunice  A1  had 
begun  before  Bohunice  V1  decommissioning  started,  had  a  well-developed  infrastructure 
already  in  place,  whereas  Bulgaria  had  some  existing  waste  treatment  and  disposal  facilities, 
and,  for  historical  reasons,  Lithuania  had  almost  none  of  the  required  infrastructure  on  its 
territory.  

For  this  reason,  the  three  programmes  started  in  radically  different  conditions,  with  new 
infrastructure requiring years for design, construction and commissioning. Adding to this, major 
infrastructure  projects  in  Bulgaria  and  in  particular  Lithuania  were  delayed  for  years  in  past 
programming  periods.  Notably  the  lack  of  Interim  Spent  Fuel  Storage  Facilities  contributed  to 
slowing down the overall decommissioning process at Ignalina.  

Consequently,  the  start  of  operations  of  key  waste  management  infrastructure  in  these  two 
countries  since  2014  has  had  and  will  have  a  significant  positive  impact  on  the  pace  of 
decommissioning work.  

28 

 
5.3.3.2  Recent years have seen an acceleration of organisational transformation, 
providing a strong support framework for decommissioning programmes  

The  transition  from  operation  to  shut-down  and  finally  decommissioning  requires  that  the 
necessary organisational support systems be put in place to manage these complex processes. 
This  transition,  as  with  all  organisational  transitions  requires  time,  clear  objectives  and  the 
deployment  of  effective  change  management  efforts.  Previous  audits  and  assessments25  have 
underlined 
the 
decommissioning programmes and found that organisational changes in some cases had been 
too slow. This is issue is over at this point in time. 

importance  of  organisational 

in  effectively  supporting 

issues 

the 

The  transition  process  at  Kozloduy  has  been  successfully  completed  with  the  handover  of 
ownership  of  Units  1  –  4  from  the  power  plant  operator  (KNPP)  to  the  decommissioning 
operator  (SERAW)  in  2013.  The  hand-over  of  responsibility,  including  the  transfer  of  project 
ownership and some plant personnel, was a complex and time-consuming process that diverted 
energies away from the overall programme management duties. 

At Ignalina, a new leadership team was put in place at INPP in 2013 bringing positive changes. In 
addition to quickly addressing commercial disputes that affected the construction of the Interim 
Spent  Fuel  Storage  Facility,  the  new  management  team  has  embarked  upon  a  number  of 
important  organisational  reforms.  A  Project  Management  Department  was  re-established  in 
2014  in  order  to  concentrate  decommissioning  project  management  functions  and  improve 
planning, execution and control of activities.  

At Bohunice, the share of internalised expertise had strongly increased over years. Indeed, the 
support  by  external  consultant  was  progressively  reduced;  having  successfully  transferred 
mainly the project management know-how. This was reinforced by experience gained from the 
decommissioning  of  the  Bohunice  A1  reactor  also  implemented  by  JAVYS  but  without  EU 
support. 

5.3.3.3  International experience in the decommissioning process remains low, in 

particular for the final stages of decommissioning 

As underlined in the Nuclear Illustrative Programme of the European Commission26, only three 
of  more  than  90  shut-down  reactors  in  the  European  Union  are  completely  decommissioned. 
Hence decommissioning is not considered a fully mature industry. If decommissioning has been 
proven to be entirely feasible, R&D efforts are continually leading to improvements in methods 
and technologies and hold significant potential to reduce the cost and uncertainty. Yet, many of 
these  technologies  are  starting  to  be  implemented  on  an  industrial  scale.  In  this  context,  the 
possibility of unexpected technical difficulties or project failure remains an inherent part of the 
decommissioning process.  

facilities  such  as  Greifswald,  have 

As programmes progress towards the critical step of dismantling in and around the reactors, the 
technical  challenges  become  more  complex.  The  experiences  in  the  Bohunice  programme,  as 
well  as  experiences  at  similar 
illustrated  that 
decommissioning  operators  must  be  prepared  to  rethink  or  reorganise  their  approach  when 
confronted  with  unexpected  challenges.  In  the  Kozloduy  and  the  Ignalina  programmes  the 
design  for  this  stage  of  decommissioning  is  being  formulated,  thus  important  open  questions 
remain. While the Kozloduy programme can rely on existing experience (in particular Bohunice), 
in the case of Ignalina  these challenges are further  compounded by the first-in-kind nature of 
this undertaking: no reactor of the RBMK design has yet been dismantled and open questions 
remain amongst international experts concerning processing solutions for irradiated graphite.  

25 ECA Special Report No 16/2011 and IP/D/CONT/IC/2013_054 
26 COM/2017/0237 

29 

 
                                                            
5.3.3.4  Administrative issues have also impacted programme effectiveness 

The  effectiveness  of  programme  implementation  has  also  been  impacted  by  risks  in  the 
administrative realm that could have been completely or at least partially avoided. For example 
in Bulgaria, the delay in ratification of the Nuclear Indemnity Agreement for the Plasma Melting 
Facility created a significant risk for the project. More generally the decommissioning operators 
have also had difficulties correctly anticipating some regulatory issues.  

These  challenges  reflect  in  part  the  limited  experience  with  the  regulatory  and  administrative 
aspects of decommissioning at the national level. This has entailed a strong learning curve for 
decommissioning  operators  and  national  authorities.  This  capacity  building  aspect  constitutes 
an  asset  especially  for  Slovakia  and  Bulgaria  which  will  be  faced  in  the  future  with  other 
decommissioning projects.  

5.3.4  Evaluation Question 3.3 

To what extent has the level of risk at each nuclear site been improved thanks 
to the NDAP support? 

5.3.4.1  Since reactors final shutdown, the level of risk for the general public at each 

site has been reduced in a stepwise manner. 

The  radiological  hazard  has  been  reduced  notably  with  the  defueling  of  reactors  and  the 
decontamination,  dismantling  and  disposal  of  contaminated  and  irradiated  equipment  and 
materials. The choice of an immediate dismantling strategy, made possible by the EU financial 
support, implies that the radiological hazard are being reduced without undue delay, along with 
the risks related to aging facilities after shut-down and loss of expertise at the facility. 

More  than  99%  of  the  overall  level  of  radioactivity  in  nuclear  reactors  is  associated  with  the 
spent  nuclear  fuel;  removal  of  the  spent  fuel  from  the  reactor  buildings  and  storage  into  an 
interim storage facility drastically reduces the potential impact of radiological hazards.  

Under the previous programming period, the NDAP supported the construction of interim spent 
fuel  storage  facilities  in  Kozloduy  and  Ignalina  (operational  since  2016)  utilising  the  best 
available  technology  on  the  market  to  ensure  long-term  safe  storage  until  final  disposal.  The 
NDAP supported the defueling activity in Kozloduy and Bohunice which resulted in a significant 
risk reduction. The remaining radiological hazard concerns primarily workers inside the nuclear 
facility. In comparison, a higher level of risk remains at Ignalina until the completion of defueling 
activities planned for 2022. Current defueling work, financed by the NDAP, will bring the overall 
risk levels for Ignalina in line with those that can be observed presently in Bulgaria and Slovakia. 

5.3.4.2  Monitoring of safety-related issues at EU level can be strengthened to better 

reflect the overall purpose of the programme 

The driving factor behind the NDAP from its beginning has been the reduction of the risk to the 
general population posed by these facilities. It has also sought to ensure that decommissioning 
is conducted in a safe manner. It can be noted that these aspects have not been well captured 
in  the  high  level  monitoring  framework  that  is  the  basis  for  communication  of  the  results  to 
external  parties.  High  level  safety  indicators  could  include  for  example,  the  evolution  of  the 
inventory of radiological material on site. 

30 

 
5.3.5  Evaluation Question 3.4 

To what extent are Monitoring & Control systems in place to measure the 
progress of the decommissioning programmes?  

5.3.5.1  The NDAP follows clearly defined objectives, with detailed work breakdown 

structures, schedules and costs 

In 2011 the ECA observed27 that, ‘the Commission did not ensure that the broad priorities…were 
translated into a coherent set of detailed targets and indicators….None of the [stakeholders] has 
established a system to monitor and assess the progress towards the achievement of the overall 
objectives...Monitoring and reporting on programme achievements at all levels were  therefore 
difficult’. 

in  detailed  objectives 

The  Commission  responded  to  these  findings  by  strengthening  the  clarity  of  the  general  and 
specific  objectives  for  each  programme  in  the  2013  NDAP  Regulations.  These  were  further 
elaborated 
implementation  procedures.  On  the 
operational level, all Member States have developed robust detailed decommissioning plans  – 
which also form part of the legal base of the programme. These plans are broken down to the 
level  of  decommissioning  activities,  including  a  schedule  and  corresponding  costs  structure 
based on internationally recognised standards for the estimation of decommissioning costs.  

in  the  detailed 

The decommissioning plans were reviewed by the Commission at the outset of the programme 
and  then  by  an  independent  consortium  of  consultants28.  The  critical  review  found  that  the 
detailed  decommissioning  plans  were  complete,  relevant  and  comprehensive  -  i.e.  include  all 
necessary activities to reach the defined decommissioning end-state.  

5.3.5.2  An adequate monitoring framework has been developed  

The  programme's  objectives  and  decommissioning  plans  provide  a  clear  baseline  and 
framework  for  the  monitoring  and  control  of  programme  implementation.  The  monitoring 
framework  further  includes  performance  indicators,  targets  and  milestones  for  each  of  the 
detailed objectives. In total, 37 indicators are set out in the detailed implementation procedures 
of  Kozloduy  (10),  Ignalina  (13)  and  Bohunice  V1  (14).  Besides  they  are  complemented  by  18 
other common indicators. All beneficiaries maintain detailed, activity and project-level schedule 
performance milestones and report twice per year (to the Commission) against this framework.  

This  framework  has  been  further  enhanced  since  2014  through  the  roll  out  of  the  EVM. 
Schedule Performance Indicators (SPI) are now reported systematically at the project level and 
at the global programme level. This provides for a simplified analysis of schedule performance, 
and provides useful aggregate-level indicators for strategic decision-making.  

The  performance  monitoring  framework for  the  NDAP  is  generally in line  with  best practice 
observed  in  other  EU programmes.  Result indicators  are  directly  relevant  to  the detailed  and 
specific  objectives  for  each  programme.  Their  limited  number  focuses  on  the  most  relevant 
results sought by the programme.   

The quality and relevance of some NDAP specific indicators, including the use of targets and 
milestones, could be further improved. While no evolution in the context or decommissioning 
strategies would merit changes to the specific objectives, some of the targets, milestones and 
performance  indicators  as  they  are  presently  formulated  for  the  programmes  should  be 
adapted or updated to ensure effective monitoring until 2020 and for several years after. This 
follows  from  the  evolution  of  the  activities  organisation  within  the  scope  of  the  detailed 
decommissioning  plan;  from  the  opportunity  to  take  full  advantage  of  the  improvements 
introduced in the reporting framework and from the fact that funds committed up to 2020 will 

27 ECA Special Report No 16/2011 
28 Deloitte 2016 

31 

 
                                                            
continue to be disbursed over a period of several years following the last commitment due to 
the multi-annual nature of decommissioning projects. Additionally, further simplification in the 
comparability of the indicators throughout the three programmes is desirable.  

5.3.5.3  Adequate mechanisms have been put in place to produce monitoring data but 
reporting and programming documents can be further streamlined 

Decommissioning  operators  for  all  three  programmes  have  continued  efforts  to  enhance 
monitoring and control systems. Beneficiaries have put in place mechanisms to produce internal 
monitoring reports for the use of managers covering schedule and cost performance. They have 
also ensured adequate capacity to produce mandated EU-level monitoring reports and provide 
necessary  monitoring  information  to  the  Implementing  Bodies,  even  if  reporting  procedures 
could be further streamlined to improve efficiency according to some stakeholders.  

Programmes  have  generally  defined  adequate  performance  frameworks  and  are  capable  of 
producing  the  requisite  monitoring  data;  better  structuring  and  filtering  of  information  in 
monitoring reports would provide additional strength in a simplified manner. In particular, the 
evaluation  assessed  the  quality  of  the  bi-annual  monitoring  reports  and  the  annual  work 
programmes.  Overall,  these  documents  are  very  comprehensive  and  allow  assessing  the 
programme implementation. Nonetheless, a number of areas for improvement were identified, 
including the heterogeneity of the reports and their length.  

5.3.5.4  The rollout of EVM has contributed to strengthening programme monitoring, 

but continued efforts can be made to perfect its use in practice. 

The  use  of  EVM  represents  a  significant  progress  towards  strengthening  the  monitoring 
framework and creating a common progress measurement framework. It provides for a greater 
degree  of  objective  comparison  of  the  performance  of  the  three  programmes  and  supports 
strategic oversight at EU. 

The  implementation  has  been  gradual  from  2014  and  driven  top-down  by  the  Commission. 
Whilst all programmes are now systematically reporting using EVM, the implementation process 
has been and continues to be a learning experience and fine-tuning has been on-going. At the 
time  of  evaluation,  EVM  schedule  and  cost  performance  indicators  were  provided  by  all 
programmes for most projects and activities. Indicators are computed both against the annual 
work programmes and the detailed decommissioning plan baseline. It is thus possible in most 
cases to assess progress against annual targets, but more importantly identify any longer-term 
slippages  against  the  decommissioning  baseline  and  in  this  way  take  appropriate  and  timely 
action. 

More generally, the EVM system is not designed to function as an additional layer of reporting. 
Rather,  best  practice  is  to  fully  embed  EVM  in  the  management  system  –  e.g.  the  processes, 
tools, practices and culture – of an organisation. This is necessary to ensure the robustness of 
performance  indicators,  but  also  the  impact  of  EVM  as  a  management  tool.  In  general,  INPP 
appears  to  have  in  place  the  most  mature  level  of  implementation  of  EVM  within  the  three 
decommissioning  operators.  This  is  due  largely  to  the  fact  that  the  organisation  made  the 
decision to implement the tool independently of and previous to the Commission’s decision to 
adopt  this  tool.  Decommissioning  operators  would  derive  long-lasting  benefits  from  fully 
embedding  this  cutting-edge  tool  into  their  management  systems.  The  use  of  EVM  in  the 
decommissioning programmes and the lessons learned from its application will thus have return 
on investment beyond the scope of the NDAP.  

32 

 
5.3.6  Evaluation Question 3.5 

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

The adequacy of communication activities was assessed primarily in so far as they contributed 
to the effectiveness of the decommissioning process. The extent communication activities may 
have fulfilled other objectives was secondary. 

Communication  activities  are  primarily  undertaken  by  decommissioning  operators  as  the 
primary  stakeholders  involved  in  decommissioning  activities.  These  activities  are  focused  on 
both  local  and  national  audiences.  They  include  communication  on  safety  and  environmental 
aspects  of 
local  populations,  as  well  as  general  awareness-raising  about 
decommissioning activities.  

interest  by 

All  sites  have  close  ties  with  local  communities  and  other  relevant  stakeholders.  Local 
communities had very close ties to the plants by virtue of many (generations of) residents being 
employed by the plants. They are thus generally aware of safety aspects of nuclear power and 
used to living in the vicinity of a nuclear facility. 

Communication  activities  respected  EU  visibility  rules.  Local  populations  are  highly 
knowledgeable  of  the  EU  assistance  provided  to  decommissioning.  The  power  plants  have 
traditionally been the main employer in the surrounding areas and the population is thus well 
aware  of  developments  with  regards  to  decommissioning.  This  was  also  supported  by  the 
politically  sensitive  nature  of  the  closure  of  the  reactors  and  the  attention  received  in  the 
national press. 

Communication activities within the framework of the NDAP at EU level related to the statutory 
reporting required by the legal base (e.g. reporting to the Council and the Parliament and to the 
Member  States  through  the  NDAP  Committee).  The  Commission’s  website  provides  the 
statutory reporting documents and a brief description of the programme with little information 
beyond  this.  The  publicly  available  annual  reporting  informs  the  European  public  on  the 
progress and the state of play in the implementation of the programmes. 

5.3.7  Evaluation Question 4 

Aside from the financial assistance provided, what other types of results and 
impacts can be attributed to the NDAP? 

Going  beyond  the  effectiveness  of  the  NDAP  in  terms  of  making  progress  against  the 
decommissioning plans, this evaluation question seeks to measure other types of positive and 
negative effects and impacts that have been generated by the NDAP in each country. 

5.3.7.1  Economic impact is mainly related to the direct impact of NDAP-funded 

contracts 

As of 2017, approximately 350 procurement contracts have been signed in execution of NDAP 
financed projects, representing approximately EUR 1.1 billion injected into the decommissioning 
market.29  An  indicative  repartition  of  contract  value  has  been  made  based  on  the  simplistic 
assumptions that the contract value is equally divided amongst consortia partners, shares going 
to  subcontractors  are  ignored  and  that  the  nationality  of  the  contracting  entity  is  counted 
rather than that of the ultimate parent company. 

The  largest  beneficiaries  were  large  nuclear  consultancy  /  engineering  firms,  such  as  NUKEM 
Technologies  (Germany),  GNS  (Germany),  Iberdrola  (Spain),  Empresarios  Agrupados  (Spain)  or 

29 This excludes contracts under the annual support projects for INPP in Lithuania, mainly for maintenance 
and general running costs. This amount has been included in the overall amount reported to the European 
Commission in the context of the programme reporting, representing approximately EUR 27 million since 
2010. 

33 

 
                                                            
NNC (UK) amongst others. These firms provided extensive project management and engineering 
support  to  programmes,  in  particular  through  external  project  management  assistance 
contracts for EBRD-financed projects. 

Figure 8: Indicative repartition of contract value by Member State from programme beginning 
to present (EUR million) 

Source: EBRD, CPMA contract data 

Local  industry  in  Bulgaria,  Lithuania  and  Slovakia  has  benefited  significantly  from  contracts 
funded through NDAP. These are generally smaller companies providing works and services, as 
well  as  engineering  and  consultancy  services  to  a  smaller  extent.  Significant  amounts  of 
contracts awarded to foreign companies can actually remain in the country. Data provided by 
decommissioning  operators  provides  a  picture  of  the  significant  amount  of  benefit  sub-
contracting  represents.  For  the  Bohunice  programme,  a  total  for  EUR  54  million  from  recent 
contracts  awarded  to  foreign  companies  remained  in  the  country  –  benefiting  62  Slovak 
consortia partners. This represents approximately 28% of the total value of these contracts. A 
similar trend can be noted with some examples in Bulgaria. In Lithuania, the decommissioning 
operator conducted analysis for EUR 404 million in projects (including the ISFSF and the SWTST) 
and found that approximately 35% (EUR 136,8 million) likely benefited local contracts.  

However,  few  local  companies  in  Bulgaria,  Lithuania  or  Slovakia  took  part  in  business 
opportunities in other programmes. If Slovakia had the highest level of national participation in 
its  programme,  only  one  Slovak  company  has  won  work  in  Bulgaria  or  Lithuania  so  far.  The 
Lithuanian firm Specialus montažas-NTP was the only local companies in Lithuania to implement 
work in the other two NDAP countries to date.  

Finally,  it  can  be  noted  that  significant  business  opportunities  were  captured  by  leading  EU 
nuclear  consultancy  and  engineering  firms,  which  have  the  potential  to  serve  as  repositories 
and  transfer  mechanisms  for  knowledge  and  experience  developed  during  these  projects  as 
they assist other decommissioning projects in the future. While it is important that knowledge 
be retained and transferred in the public sphere (as an EU-financed project), private companies 
can also play a role in this process.   

5.3.7.2  Innovation gain 

The  programmes  have  allowed  showcasing  advanced  or  new  technologies,  providing  EU 
companies  with  valuable  references.  At  Kozloduy,  for  example,  the  plasma  melting  facility 
represents  only  the  second  application  of  this  technology  in  the  domain  of  nuclear  waste 
management  in  the  world.  Demand  for  such  cost-effective  technologies  can  be  expected  to 
grow in coming years with the expected growth of the wider decommissioning market.  

34 

 
 
 
The  process  of  decommissioning  is  also  an  opportunity  to  collect  knowledge  and  experience. 
There  is  a  significant  need  for  reliable  data  about  decommissioning  process  to  improve  the 
accuracy  of  plans  and  properly  assess  the  cost  of  it.  Valuable  information  includes:  the 
evaluation  and  optimization  of  decommissioning  options,  the  modelling  of  dismantling 
techniques, the evaluation of safety in decommissioning; and waste management scenarios.30 It 
allows  for  further  development  of  specific  codes  for  decision  making  process  and  planning  in 
decommissioning, which can be considered as an additional important impact of the NDAP with 
economic dimension. 

Apart from the above, no other examples were found of truly innovative technology developed 
by  companies  or  decommissioning  operators  as  part  of  NDAP;  nor  do  decommissioning 
operators conduct extensive R&D. The Ignalina programme holds the highest potential for the 
development of innovative technologies as the conditioning and storage of irradiated graphite is 
subject to extensive R&D in the world and no clear solutions are yet available. 

5.3.7.3  Experience gain 

All  three  decommissioning  operators  are  considering  leveraging  the  experience  gained  into 
future commercial opportunities. For example, JAVYS has made concrete steps in this direction 
at present. The experience and credential gained through the NDAP may thus contribute to an 
additional  return  on  investment  for  the  European  economy  through  the  emergence  of  new 
decommissioning companies active on the European and international market, in the same way 
that it has contributed to developing the expertise and experience of large engineering firms as 
previously described.  

5.3.7.4  Social impact 

The process of decommissioning is linked with a decrease in the number of employees, which 
may have a negative impact on the economic development of particular regions31. Indeed, the 
early closure of the eight units concerned by the NDAP has inevitably had some negative socio-
economic impact on the areas where these NPPs are located. The NPPs were important sources 
of employment in these regions, even the most important local employer. However significant 
differences  from  one  Member  State  to  another  can  be  noted,  depending  on  the  existence  of 
other working reactors on site (Slovakia, Bulgaria) or not (Lithuania).  

In this context, the NDAP has helped to mitigate these negative impacts, notably by influencing 
the decommissioning strategy of Member States. The NDAP exercised a strong influence on the 
choice to pursue an immediate dismantling strategy in Bulgaria and Lithuania.32 This created a 
logical opportunity for former NPP staff, with strong knowledge of the facilities, to participate in 
the  decommissioning  process.  Under  the  alternative  scenario  of  deferred  decommissioning, 
staffing requirements would have dropped much more precipitously. In these Member States, 
the decommissioning process has leveraged the skills and expertise of a significant number of 
former NPP staff. The NDAP has thus supported employment of these staff for decommissioning 
work, whereas this employment may have otherwise been lost in absence of EU support. 

However, it should also be noted that the preservation of employment to the extent that it is 
not  indispensable  to  decommissioning  and  safety  is  at  odds  with  the  objective  of  supporting 
cost-effective  programme  delivery.  Indeed,  desires  to  minimise  social  impacts  on  the  national 
level contradicts the effort for the cost-effectiveness of the decommissioning process. 

30  Innovative  and  Adaptive  Technologies  in  Decommissioning  of  Nuclear  Facilities;  Final  report  of  a 
coordinated research project 2004-2008; IAEA, 2008 
31 Managing the Socioeconomic Impact of the Decommissioning of Nuclear Facilities, IAEA 
http://www-pub.iaea.org/books/IAEABooks/7782/Managing-the-Socioeconomic-Impact-of-the-
Decommissioning-of-Nuclear-Facilities 
32 In Slovakia, this strategy had been selected independently from NDAP. 

35 

 
                                                            
 
5.3.8  Evaluation Question 5 

How effective is the governance and project management framework at EU 
and national levels? 

The  study33  of  comparator  instruments  and  programmes  allowed  taking  stock  of  some  of  the 
advantages and disadvantages of the different approaches that could be used to implement the 
NDAP.  It  concluded  that  indirect  management  is  an  appropriate  tool  and  that  changing 
management mode for delivery of the NDAP at present would induce costs not compensated by 
the expected benefits.   

Due  to  the  high  level  of  capacity  and  expertise  necessary  to  implement  the  NDAP  and  the 
historical context, indirect management was chosen and implementation tasks were delegated 
to  the  EBRD.  The  EBRD  had  a  recognised  expertise  and  experience  delivering  similar 
programmes.  Since  their  accession  and  with  the  encouragement  of  the  Commission,  two 
Member States have subsequently decided to establish national implementing channels. These 
‘national agencies’ thus coexist alongside the EBRD in Lithuania and Slovakia during a transition 
period. Indirect management has the advantage of ensuring the requisite level of expertise and 
capacity  while  avoiding  the  necessity  to  increase  headcount  in  the  Commission  and  it  is 
appropriate  for  the  size  and  type  of  the  given  programmes.  The  flexibility  offered  by  this 
management  mode  has  also  contributed  to  gradually  developing  national  ownership  of  the 
programmes through the subsequent creation of the national agencies. 

Alternatively, the Commission could have managed  the programme directly, in particular with 
the  growing  recourse  to  Executive  Agencies  to  manage  the  implementation  tasks  of  large  EU 
programmes.  While 
legally  distinct  entities,  Executive  Agencies  are  very  close  to  the 
Commission in terms of their regulatory framework, business processes and working practices. 
In-sourcing  management,  either  to  the  Commission  or  an  Executive  Agency,  could  lead  to 
reducing  some  of  the  natural  transaction  costs  of  the  indirect  management  model.  However, 
such a decision would also require the development of an adequate level of internal expertise, 
in addition to the necessary capacity.   

The  other  alternative,  shared  management,  would  offer  the  advantage  of  shifting  greater 
responsibility to the Member States and possibly increasing the level of ‘ownership’. This is the 
setup  being  used  for  the  management  of  ESIF.  However,  this  alternative  is  more  relevant  for 
large programmes and not for programmes of the size of NDAP, it would be disproportionate in 
the NDAP case. 

While  changing  management  mode  in  a  future  programme  could  potentially  lead  to  some 
benefits as discussed above, it should also be recognised that it would imply a period of overlap 
during which new projects would be implemented under the new management mode, while on-
going  projects  would  continue  to  be  implemented  under  the  previous  regulatory  framework. 
Past  experience  has  shown  that  the  co-existence  of  regulatory  frameworks  creates  significant 
administrative complexities and engenders inefficiencies in programme management. 

5.3.9  Evaluation Question 5.1 

How well are roles defined and effective at EU level in terms of planning, 
monitoring and reporting? 

5.3.9.1  The roles and responsibilities of the Commission are clearly defined and 

appropriate 

The  roles  and  responsibilities  of  the  Commission  are  clearly  set  out  and  provide  for  a  logical 
division of responsibilities when considered alongside the roles and responsibilities set out for 
other  actors.  The  evaluation  study34  considers  them  appropriate  for  supporting  effective 

33 EY 2018 
34 EY 2018 

36 

 
                                                            
programme  implementation  while  safeguarding  the  Union  interests.  The  Commission  has 
retained  largely  strategic  oversight  responsibilities  in  line  with  its  available  internal  resources, 
with administrative implementation tasks delegated to specialised bodies with strong technical 
and administrative competencies.  

5.3.9.2  The Commission fulfils obligations with regards to the annual programming 

cycle, but the time-lines have not proven realistic. 

The  Commission  plays  an  important  role  in  the  annual  programming  cycle.  It  approved  the 
decommissioning  plans  (baselines)  and  reviews  and  adopts,  after  seeking  the  opinion  of  the 
NDAP  Committee,  the  Annual  Work  Programmes.  On  this  basis,  it  adopts  annual  Financing 
Decisions and provides funding to the respective Implementing Bodies. At the end of the year, a 
Progress Report is transmitted to the European Parliament and the Council, which serves as the 
basis for the adoption of the next Annual Work Programme.  

In practice, timely delivery in this process has proven difficult. The importance of addressing the 
issue  is  recognised  by  all  actors  and  the  Commission  has  initiated  reflection  on  possible 
solutions,  notably  modifications  to  the  detailed  implementation  procedures.  Specifically,  the 
timeline  should  be  re-thought,  as  well  as  the  sequencing  of  and  linkages  in  processes  and 
streamlining or otherwise adapting the content of programming documents. 

The Commission also has the authority to decide on the eligibility of individual projects (and any 
amendment thereof) and to grant conditional approvals as it deems necessary for safeguarding 
Union  interests.  Most  projects  are  approved  within  4  to  6  weeks,  nonetheless  stakeholders 
underlined  the  need  for  clearer  timelines  for  project  approval  as  the  time  necessary  for 
approval can be prolonged in some rare cases when the Commission deems necessary to obtain 
specific guarantees before approving a project (e.g. co-financing of near surface repositories at 
Kozloduy and Ignalina). More generally, the process for approval of projects at EU level may also 
be rethought. 

5.3.9.3  The NDAP Committee is acting as defined by its mandate, but the timeliness 

and relevance of information provided to Committee members could be 
improved 

The NDAP Committee is a "comitology committee" set up in accordance with Article 291 of the 
TFEU and Regulation 182/2011, to control the Commission’s exercise of implementing powers.  

By its own account, the NDAP Committee is fulfilling its mandate as described in EU legislation. 
However,  NDAP  Committee  members  interviewed35  reported  the  issue  of  timeliness  in 
managing the programming cycle and that Monitoring Reports should focus on issues relevant 
to high level oversight.  

Beyond  its  statutory  purposes,  the  NDAP  Committee  meetings  have  also  provided  the 
opportunity  for  Member  states  to  share  their  knowledge  on  the  decommissioning  process.  In 
the first years of the programmes (before the current MFF), this flow of knowledge came from 
‘experienced’  Member  States  to  programme  beneficiaries,  whereas  now  the  flow  has  been 
reversed  and  decommissioning  operators  are  sharing  their  experiences  with  other  Member 
States.  This  is  perceived  as  a  positive  aspect  by  the  Committee  members  interviewed  and  a 
strong incentive for attendance.  

5.3.9.4  Implementing Bodies are fulfilling their responsibilities and playing a 

technical oversight role  

The  Implementing  bodies  are  responsible  for  the  proper  performance  of  activities  as  fund 
manager and the sound financial management of projects. This includes establishing thorough 

35 EY 2018 

37 

 
                                                            
monitoring  and  control  systems,  requesting  funds  from  the  Commission,  supporting  the 
development  of  programming  and  project  documentation,  monitoring  of  implementation, 
control of procurement, assessment of cost eligibility, payments and financial management and 
recovery of irregularities.  
Overall, the evaluation contractor36 found that Implementing Bodies (i.e. EBRD and CPMA, with 
SIEA having recently commenced their activities at the time of the evaluation) were effectively 
fulfilling their responsibilities as per the framework described above. These organisations have 
been  subject  to  the  required  pillar  assessments37  and  various  external  verification/audits  in 
recent years that confirm their aptitude and performance.  
In practice, Implementing Bodies were also found38 to be playing an important role in providing 
strategic  technical  oversight  to  programme  implementation. They  can rely  on  internal  nuclear 
expertise and extensive experience with implementation of complex projects.  

The transition  between implementing  bodies  –  in  this  case  from an  international  organisation 
(EBRD) to national agencies (CPMA and SIEA) – implies a transition period with multiple active 
Implementing  Bodies.  Coordination  challenges  that  have  been  observed 
in  previous 
programming periods are now being avoided with clear boundaries between projects attributed 
to  different  implementing  bodies,  adequate  integration  of  programming  activities  at  the 
monitoring  committee,  and  enhanced  cooperation  between  the  relevant  stakeholders.  The 
installation  of  a  national  agency  was  promoted  by  the  respective  Member  States  and  is 
considered a good practice for enhancing ownership of the programme and increasing capacity 
at national level. 

5.3.10  Evaluation Question 5.2 

At national level, how well are the roles of the Programme Coordinator 
defined and effective in terms of: planning; monitoring; and reporting? 

Early  political  resistance  in  Member  States  in  past  MFFs  has  given  way  to  acceptance  and 
greater  ownership  at  present.  The  political  commitment  obtained  by  the  EU  for  the  early 
closure of the reactors in the three Member States was met with some domestic resistance in 
early years, with negative impacts on both the political and technical levels. Already before the 
end  of  the  previous  programming  period,  this  resistance  had  progressively  given  way  to 
widespread  acceptance  of  the  irreversible  shutdown  of  reactors,  which  has  also  become  a 
technical reality in the present MFF. Increasingly, this has also translated into an assumption of 
greater  ownership  over  the  decommissioning  process 
itself  on  the  part  of  national 
governments.  This  process  is  recognised  by  the  Commission  as  a  necessary  condition  of 
continuing to consolidate the governance of the NDAP.  

While clear progress has been made in raising the profile and role of national governments in 
the  NDAP,  the  findings  of  the  evaluation  study39  also  point  to  the  need  for  further  progress. 
National ministries  in Lithuania  and,  in  particular,  Bulgaria,  could  continue  to  strengthen their 
levels of technical capacity in order to exercise stronger technical oversight of programmes – i.e. 
acting as informed clients. 

If  the  detailed  implementation  procedures  gives  to  the  Programme  Coordinator  overall 
responsibility for drawing up the Annual Work Programme, their role in practice mostly focuses 
on  the  administrative  aspects  of  the  programming  process  –  e.g.  coordination  and  formal 
submission of the documents. The decommissioning operators retain a large degree of influence 

36 EY 2018 
37 https://ec.europa.eu/europeaid/funding/about-funding-and-procedures/audit-and-control/pillar-
assessments_en 
38 EY 2018 
39 EY 2018 

38 

 
                                                            
on  the  programming  in  practice  –  and  subsequent  development  of  projects  -  even  if  it  is 
developed within the strategic framework of the detailed decommissioning plans.  

The case of Bulgaria merits a separate discussion as these issues have been further aggravated 
in  recent  years  by  political  instability.  At  the  time  of  the  evaluation,  a  new  government  was 
formed following several months of a caretaker government. The Bulgarian administration has 
also  had  difficulties  addressing  administrative  issues  in  a  timely  manner,  which  has  impacted 
the advancement of the programme. 

Regardless  of  the  technical  capacity  of  national  ministries  and  other  obstacles  faced,  the 
detailed  implementation  procedures  also  limit  the  extent  of  the  involvement  of  Programme 
Coordinators.  The  introduction  of  Monitoring  Committees  presided  over  by  the  Programming 
Coordinators is an important step in designating a more strategic role of national ministries in 
the NDAP governance framework. However, the role of this committee is  confined to formally 
validating  Monitoring  Reports.  While  stakeholders  participating  in  these  committees  have 
reported quality dialogue on progress and good coordination between stakeholders, the scope 
of this committee’s role is ultimately limited. Greater scope to make decisions, with regard to 
project  approval,  for  instance,  may  provide  greater  impetus  for  Programme  Coordinators  to 
make  further  investments  in  strengthening  their  role  in  the  programme.  However,  such 
procedural  changes  would  be  dependent  on  also  strengthening  the  technical  capacity  of 
Programme  Coordinators.  They  would  also  be  supported  through  continuing  to  develop  the 
financial buy-in of Member States in the programmes. 

5.3.11  Evaluation Question 5.3 

How effective is the governance system of the decommissioning programmes? 

This question addresses the effectiveness and of the governance system and extent it is fit-for-
purpose,  with  regards  in  particular  to  its  ability  to:  i)  develop  robust  and  coherent  work 
programmes, and ensure adequate ii) monitoring, iii) coordination and communication, and iv) 
project management. 

5.3.11.1 Programming documents  

The NDAP programming documents are generally robust, coherent and developed in line with 
the detailed implementation procedures. The strengthening of the clarity of objectives and the 
incorporation  of  the detailed decommissioning plan  baseline schedule has  also  contributed  to 
improving the quality of programming documents under the current programming period. The 
Annual  Work  Programmes  are  thus  by  definition  closely  aligned  with  the  detailed 
decommissioning plans developed by the Member States, helping to ensure the relevance of EU 
assistance.  

However, the timeline and process set out in the detailed implementation procedures has not 
been  tenable  in  practice  despite  the  best  efforts  of  all  stakeholders  (see  5.3.9.2).  Beyond 
modifying the detailed implementation procedures to make the process more practical, a more 
radical move could also be envisaged to adopt a multi-annual programme as is common in other 
EU programmes. 

5.3.11.2 Strengthened monitoring framework  

As  previously  discussed,  the  monitoring  of  programme  implementation  has  been  significantly 
enhanced  under  the  current  MFF  addressing  weaknesses  identified  in  previous  programming 
periods.  The  complementary  use  of  Earned  Value  Management  has  also  contributed  to 
strengthening  monitoring  and  the  overall  accountability  framework.  These  efforts  have 
contributed to strengthening the Commission’s strategic oversight role, whereas in the past the 

39 

 
European Court of Auditors40 has criticised it for focusing too much on financial implementation 
at the expense of programme effectiveness and efficiency.  

5.3.11.3 Implementing bodies and Programme coordinators 

Implementing  Bodies  have  played  a  key  role  in  supervising  day-to-day  implementation  of  the 
internal 
decommissioning  programmes.  As  noted,  they  can  notably  rely  on  extensive 
experience, relevant expertise and capacity. In this way, they also play an important technical 
oversight  role  in  the  context  of  relatively  weaker  supervision  and  oversight  by  national 
governments notably Lithuania and Bulgaria. Nonetheless, as this role is somewhat beyond their 
legal responsibilities. 

However,  Programme  Coordinators  have  increasingly  taken  a  stronger  role  in  programme 
oversight  and  ownership.  Recognising  the  importance  and  positive  impact  of  greater  national 
ownership41  on  supporting  effective  and  efficient  programme  delivery,  the  Commission  has 
encouraged  this  process  on  both  the  political  and  procedural  level.  Today,  Programme 
Coordinators  are  active  in  the  programme  governance,  but  some  still  require  additional 
technical capacity to provide stronger oversight of programmes and their role in the governance 
framework could be further enhanced to promote stronger ownership and leadership.  

5.3.11.4 Coordination and communication 

The Programme Coordinator role has also evolved to increasingly emphasise the responsibility 
for  coordination  and  communication  with  relevant  national  stakeholders,  as  well  as 
complementary  sources  of  national  financing  contributing  directly  and  indirectly  to  the 
decommissioning  programmes.  As  national  governments  have  become  more  engaged  in  the 
NDAP  governance,  this  aspect  has  been  naturally  strengthened.  As  a  positive  sign  of  this 
evolution, the participation in Monitoring Committees has widened to regularly include relevant 
national stakeholders, such as regulatory bodies and relevant sectoral ministries.  

5.3.11.5 Project management capabilities have progressively been strengthened 
Previous evaluations and audits42 have underlined the need to strengthen project management 
practices at the level of beneficiaries. Closely connected with this are the wider questions of the 
organisational transformations necessary to support the decommissioning process. As discussed 
previously  and  as  reported  in  previous  progress  reports,  decommissioning  operators  have 
progressively put in place more robust project management systems and taken steps necessary 
to  adapt  their  organisations  to  the  needs  of  the  decommissioning  process.  This  has  been 
reflected  in  the  quality  of  project  management  structures  and,  increasingly,  stronger  project 
management cultures. 

5.4  Efficiency 

5.4.1  Evaluation Question 6 

To what extent is the management of the decommissioning programmes cost 
effective and efficient? 

The objective of this question is to  measure the extent  to which the desired outcomes of the 
NDAP  are  achieved  at  a  reasonable  cost.  Efficiency  will  therefore  measure  how  the 
resources/inputs  are  converted  to  results  and  how  the  systems  in  place,  including  the 
monitoring and reporting systems and governance, assist in efficiency. 

40 ECA Special Report No 16/2011 
41 COM/2016/0405 
42 ECA Special Report No 16/2011 

40 

 
                                                            
5.4.1.1  The last revision of cost estimates (2014) resulted in small decrease for one 

programme and an increase for the two others 

At  the  outset  of  the  current  MFF,  the  concerned  Member  States  formally  submitted  updated 
nuclear  decommissioning  cost  estimates  as  part  of  their  updated  detailed  decommissioning 
plans. The new cost estimates resulted in a relative stability for the Kozloduy programme with a 
variation  of  EUR 11.1 million  (-1%),  and  an  estimated  cost  increase  for  the  Bohunice  and 
Ignalina programmes of EUR 289 million (+24%) and EUR 1 643 million (+40%) respectively. This 
comprehensive  revision  of  the  detailed  decommissioning  plans  answered  the  2011 
recommendation  of  the  ECA43  that  required  a  detailed  assessment  of  the  needs  showing  the 
progress of the programmes so far and the activities still to be performed. 

The  increase  in  cost  estimate  for  the  Ignalina  programme  came  in  the  context  of  a  nine  year 
extension  of  its  overall  duration;  not  surprisingly,  a  large  part  of  the  cost  increase  can  be 
attributed to time-dependent costs associated with project duration, such as energy resources 
and personnel costs. The cost increase also reflected project costs escalation and the inclusion 
of additional costs identified by a more detailed analysis.  

An  independent  review  was  undertaken  of  the  detailed  decommissioning  plans  and  cost 
estimations in 201644. The study confirmed that the overall base cost estimations for the three 
programmes,  as  stated  in  the  detailed  decommissioning  plans,  are  generally  appropriate. 
However,  the  report  also  underlined  that  cost  estimation  may  benefit  from  further  adopting 
cost  estimation  methodologies  in  line  with  evolving  international  experience.  In  particular,  it 
was  found  that  the  allowances  made  for  contingencies  in  the  cost  estimations  for  all  three 
programmes  did  not  entirely  follow  best  practice  methodologies.  Allowance  for  contingencies 
were consequently on the lower end of international practice for similar projects. The revised 
contingency scenarios calculated by the consultants may thus provide a more robust estimation 
of the potential total cost of the decommissioning programmes taking into account risks in line 
with best practice (see figure below). 

Figure 9: Evolution of cost estimates for decommissioning programmes and revised 
contingency scenarios (EUR million) 

The total decommissioning cost numbers include inflation and contingency or risk 

Source: Decommissioning plans, Deloitte 2016 

43 ECA Special Report No 16/2011 
44 Deloitte 2016 

41 

 
 
                                                            
5.4.1.2  All three programmes currently remain on track to implement 

decommissioning programmes according to current cost estimates 

Notwithstanding  the  independent  assessment  of  the  adequacy  of  contingencies,  the  updated 
(2014)  programme  cost  estimates  were  expected  to  be  maintained  at  the  time  of  the 
evaluation.  The  analysis  of  programme  implementation  (section  Effectiveness5.3)  would  also 
suggest  that  programmes  remain  broadly  on  track  when  compared  against  the  baseline 
schedule and that there is no major risk at present of further cost increases due to time delays, 
as  least  for  what  concerns  the  achievement  of  the  objectives  defined  under  this  MFF.  This  is 
considering that slippages against the schedule may reasonably be recovered through proactive 
and close management.   

However, Bulgarian authorities are in the process of revising the cost estimate as outcome of a 
review of their decommissioning programme. This is part of the regular three-year review cycle 
of  the  decommissioning  plan.  As  a  consequence  of  this  review,  the  total  cost  estimate  for 
completing  the  Kozloduy  decommissioning  programme  is  going  to  increase  by  23%.  However, 
the national contribution has been correspondingly increased to cover an important amount of 
the funding gap.  

5.4.2  Evaluation Question 6.1 

To what extent has the NDAP been cost-effective when considering each 
activity and cost category compared against performance indicators?  

5.4.2.1  EVM indicators point to satisfactory cost effectiveness to date 

The implementation of EVM in the three programmes has provided for the first time a means 
for  an  easier  monitoring  of  cost  performance  at  project  and  programme  level  and  for  making 
cost performance comparisons between the programmes. Since 2014, the earned value of the 
programmes has been largely aligned with or in excess of actual costs. This is usually expressed 
by  the  Cost  Performance  Index  which  is  calculated  by  dividing  the  'earned  value'  of  progress 
achieved to date by the actual costs incurred. Earned value is the baseline budget for the work 
actually completed by the specified date. In the case of the three decommissioning programmes 
the  resulting  cost  performance  indicator  is  approximately  1  or  higher.  This  demonstrates  that 
programmes  have  been  achieving  the  outputs  at  the  expected  costs  or  less.  No  other  cost-
efficiency indicators are used in programme management at programme or EU level. 

5.4.2.2  A detailed assessment of cost-effectiveness and comparison between the 

programmes is difficult 

A  previous  study45  sought  to  assess  the cost-effectiveness  of  programmes  on a more  granular 
level  considering  individual  activities  and  expense  categories  against  relevant  performance 
indicators.  However,  this  task  is  rendered  difficult  by  the  differences  in  the  approach  to 
budgeting, programming, tracking expenditure and monitoring results within each programme. 
Indeed, the budget structure for cost estimates does not always align with the work breakdown 
structure used for planning and programming, which itself is not always possible to align with 
the  headings  used  for  tracking  budget  implementation  or  results  monitoring.  It  is  thus  not 
possible to fully integrate the quantitative data from the budgeting, programming, expenditure 
or monitoring documents in any sort of robust and systematic manner.  

One can also note the inherent difficulties in comparing decommissioning programmes. Even if 
all  three  programmes  have  relied  on  the  International  Structure  for  Decommissioning  Costing 
(ISDC)  standardised  cost  structure  for  developing  their  budgets,  the  methodology  allows  for 
enough  flexibility  for  the  programmes  to  be  difficult  to  compare.  This  limitation  of  the  ISDC 

45 Deloitte 2016 

42 

 
                                                            
methodology  is  recognised  in  publications  by  its  promotor,  the  Nuclear  Energy  Agency,46  for 
example in Costs of Decommissioning Nuclear Power Plants.47 

5.4.2.3  Programmes have generally been implemented in a cost-effective manner 

To overcome the difficulty to identify univocally cost per activity and compare the programmes 
amongst  themselves  an  ad  hoc  and  qualitative  approach  has  been  adopted.  In  the  study 
supporting this evaluation48, each programme has been analysed for good practices and sources 
of  inefficiencies.  This  analysis  supported  the  overall  conclusion  that  programmes  have 
generally  been  implemented  in  a  cost-effective  manner.  However,  looking  at  the  principal 
areas of activities and cost categories, some variation can be noted in function of the different 
challenges faced. More generally, the findings also pointed to the need to continue to rebalance 
resources towards core decommissioning tasks to improve cost effectiveness. 

5.4.3  Evaluation Question 6.2 

What are the major factors impacting the efficiency of the assistance 
programmes? What are the root causes of these factors? 

As  described  in  the  previous  section,  the  cost  performance  of  all  three  programmes  has 
generally  been  satisfactory  to  date.  This  stands  in  contrasts  to  difficulties  with  some 
programmes  faced  in  the  past.  As  noted  in  ECA  audits49,  until  2013  many  of  the  key 
decommissioning  infrastructure  projects  have  experienced  delays  and  /  or  cost  increases.  The 
successful completion or current positive trajectory of projects having faced chronic problems in 
the  past,  such  as  the  Interim  Spent  Fuel  Storage  Facility  in  Lithuania  or  the  Plasma  Melting 
Facility  in  Bulgaria,  would  seem  to  suggest  that  decommissioning  operators  have  successfully 
integrated  lessons  learnt  and  built  up  internal  capacity.  Some  good  practices  have  also  been 
identified  that  are  helping  to  ensure  the  general  cost-effectiveness  of  the  programme 
implementation. Despite these positive signs, delays and budget slippages in some projects can 
still be noted since 2014. A number of different issues impacting efficiency are identified in this 
section.  

On  a  more  structural  level,  the  strength  of  the  incentive  framework  put  in  place  through  co-
financing  and  its  potential  impact  on  the  overall  cost-effectiveness  of  the  programme  is 
analysed.  The overall programme governance framework on the other hand,  can generally  be 
considered to be supporting programme cost effectiveness.  

5.4.3.1  Defining an adequate co-financing level 

The three  Member  States  have contributed  (and will continue to  contribute)  a  significantly  to 
their decommissioning programmes. At present the already disbursed and committed national 
funding represent EUR 458 million for Bulgaria, EUR 476 million for Slovakia and EUR 478 million 
for  Lithuania;  that 
is  respectively  34%,  38%  and  14%  of  the  estimated  cost  of  the 
decommissioning  programmes.  The  ECA  has  called  for  increasing  the  level  of  co-financing  in 
order  to  support  ownership  by  Member  States  and  create  a  stronger  incentive  for  cost-
effectiveness.  

All three Member States have established dedicated Funds, which provide part of the financing. 
Other national resources come from the national budgets.  

Creating  an  adequate  level  of  economic  self-interest  is  an  important  factor  in  encouraging 
economy-seeking  behaviour  in  beneficiaries  in  the  context  of  EU  assistance  programmes. 
Recognising this, the legal base notes that full financing of activities should be limited to "well-

46 https://www.oecd-nea.org/ 
47 http://dx.doi.org/10.1787/9789264255555-en 
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43 

 
                                                            
founded  exceptional  cases  and  that  every  effort  should  be  made  to  continue  the  co-financing 
practice  established  under  the  pre-accession  assistance  and  the  assistance  provided  over  the 
period 2007-2013". This brief mention in the preamble to the 2013 NDAP Regulations refers to a 
practice of co-financing that was never clearly established under previous programming periods. 
Notably,  the  NDAP  has  not  formally  set  a  maximum  level  of  EU  co-financing  or  formalised  a 
framework  defining  how  national  resources  can  or  should  contribute  (e.g.  at  project  or 
programme  level,  to  certain  types  of  projects  or  activities,  etc.).  Nonetheless  the  Commission 
has  continued  efforts  to  raise  the  level  of  national  contribution,  both  at  the  project  and 
programme levels. It has  also introduced stronger conditionalities requiring risk-sharing in  the 
event  of  increase  in  project  cost  and  requirements  to  offset  any  cost  increases  through 
reductions in other areas of the programme. These efforts have been met with varying levels of 
cooperation  on  the  part  of  the  three  Member  States.  Slovakia  has  notably  committed  to 
increase programme funding from national resources by 28% from EUR 372 million to EUR 476 
million. Similarly Bulgaria has set an amount for national contribution at EUR 458 million, and 
Lithuania at EUR 478 million. 
In order to assess this issue/aspect in a broader context, the study supporting this evaluation50 
has  considered  a  comparison  with  other  programmes.  Two  of  them,  the  Connecting  Europe 
Facility (CEF)51 and ESIF Major Projects52, have clearly defined frameworks for co-financing, with 
EU co-financing rates clearly set out in the legal base. For the CEF, grants for works included co-
financing  levels  varying  between  20%  -  75%.  For  ESIF  Major  Projects,  the  co-financing  rates 
reflect  those  defined  for  European  Structural  and  Investment  Funds  and  vary  between  50%  - 
85% (95% in exceptional cases). A comparison was also made with budget support operations53 
where  the  practice  of  ‘co-financing’  was  similar  in  some  ways  to  the  NDAP.  Budget  support 
operations  support  partner  countries’  development  strategies,  often  in  a  specific  sector,  for 
which national resources are also mobilised. However, the idea of co-financing strictly speaking 
does not exist. For budget support operations, the level of Union funding allocated is based on a 
number  of  needs  and  performance  criteria  following  a  more  qualitative  than  mechanistic 
assessment.  

The  CEF  and  ESIF  Major  Projects  thus  ensure  that  an  adequate  incentive  structure  is  in  place 
through  a  clear  framework  for  co-financing.  If  a  cost  increase  is  accepted,  the  beneficiary 
contribution  for a project  automatically increases.  On the other  hand, budget support creates 
incentives to perform through the use of variable tranches based on actual performance against 
pre-agreed performance indicators.  

5.4.3.2  Performance of co-financed projects 

Increased  levels  of  national  contribution  would  very  likely  continue  to  encourage  greater 
national  ownership  and  economy-seeking  on  the  part  of  beneficiaries.  However,  the 
performance  of  the  few  co-financed  projects  to  date  does  not  suggest  that  these  are 
consistently more efficient or effective than those financed entirely through EU support.  

A review of Grant Agreements has identified ten projects for which an explicit ‘co-financing’ has 
been  agreed.  This  includes  eight  projects  at  Bohunice  and  two  at  Kozloduy.  The  majority  of 
projects concern waste management infrastructure where the rationale for co-financing has not 
been to share responsibility and risks, but to exclude infrastructure capacity that will also serve 
other national needs from the scope of the NDAP.  

The list of co-financed projects is small in absolute terms, providing only limited evidence upon 
which to draw conclusions. Looking at the general performance of these projects, they do not 

50 EY 2018 
51 Regulation (EU) 1316/2013 
52 Regulation (EU) 1303/2013 
53 EuropeAid Guidelines N°7 

44 

 
                                                            
demonstrate  a  significantly  higher  performance  (to  the  extent  to  that  would  allow  to  infer 
causation)  than  the  general  project  portfolio.  Most  have  faced  difficulties  or  delays  at  some 
point,  and  some  have  also  faced  cost  increases.  For  example,  the  "Dismantling  of  Reactor 
Coolant  system  Large  Components"  (project  D4.2)  in  Slovakia  and  the  "Design,  Supply, 
Installation  and  associated  Services  of  Equipment  (including  EIA)  for  conditioning  of  solid 
radioactive waste with High Volume Reduction Factor" (project 5b) in Bulgaria notably saw their 
cost increase significantly from the first estimates (largely due to inadequate market analysis).  

5.4.3.3  Funding gap 

A more fundamental issue that appears to have weakened the overall accountability framework 
was  the  open-ended  nature  of  EU  assistance.  An  upfront  financial  commitment  to  the  three 
Member States as a counterpart to the closure of the units was never fixed. Until the adoption 
of  the  detailed  decommissioning  plans  as  baseline  for  the  NDAP  in  2014,  the  EU  support  has 
remained  a  de  facto  open-ended  commitment  for  the  decommissioning  programmes  and 
related  activities.  This  did  not  install  the  adequate  background  for  confronting  the  toughest 
issues immediately nor to seek the most efficient choices. 

The funding gap is the difference between the total decommissioning programme cost and the 
already  identified  funding.  This  funding  gap  is  closing  in  Slovakia  and  Bulgaria,  but  is  still 
important to Lithuania given the size and nature of the project. 

45 

 
Figure 10 Funding gap in BG, SK and LT 

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5.4.3.4  Project delays are often synonymous with cost increases 

Project  delays  can  be  cited  as  amongst  the  most  often  found  reasons  for  cost  increases  in  all 
three programmes. As in other sectors, many of the costs associated with the decommissioning 
programmes are time dependent, meaning they will automatically increase in the occurrence of 
delays.  For  example,  significant  resources  continue  to  be  allocated  to  facility  shut  down  and 
post-operation activities during the current MFF at the Ignalina programme in order to maintain 
safety systems and support the defueling process. Therefore delayed defueling had significantly 
impacted the cost of these activities by extending their duration.  

46 

 
 
 
 
 
 
 
 
 
 
 
5.4.3.5  Support tasks 

Decommissioning activities are directed towards D&D and waste management tasks (including 
defueling)  that  directly  result  in  physical  progress  towards  reduction  of  radiological  hazards. 
However they are always accompanied by enabling support tasks (management, maintenance, 
security, etc.). This includes seemingly dissociated activities, such as ‘railroad maintenance’ for 
logically  be  traced  back  to  critical 
example,  which  upon 
decommissioning activities. In this case, a short railroad network at Ignalina is used to transport 
spent fuel during defueling operations. As another example, radiation protection staff, personal 
dosimetry devices and even specialised laundry services are necessary to ensuring safe working 
conditions in Controlled Areas. 

further  examination  can 

Overall, the analysis of monitoring reports show that a significant level of resources continue to 
be  devoted  to  ancillary  decommissioning  tasks  –  or  support  tasks.  The  Commission  has 
continuously  pushed  decommissioning  operators  to  improve  the  cost-efficiency  of  support 
activities in order to direct EU support towards high value added (in terms of physical progress) 
decommissioning activities. The Commission has signalled that it will no longer finance certain 
support activities, such as energy costs, in the future. 

For example, according to INPP reporting, post-operation activities continued to consume 32% 
of  man-hours  during  the  second  half  of  2016.  Given  the  importance  of  this  activity  in  the 
budget, INPP maintains a high level of efforts to improve cost-effectiveness in this area, recently 
through  the  reorganisation  and  reduction  of  maintenance  teams  or  the  make-or-buy  strategy 
aiming to ensure costs are at market value. 

Another  interesting  approach  can  be  observed  in  the  Bohunice  programme.  Due  to  factors 
specific  to  the  programme,  output-based  contracts  have  been  used  to  finance  waste 
management  activities  (e.g.  X  euros  for  X  tonnes  of  waste  processed),  rather  than  financing 
based  on  inputs  (e.g.  salaries  of  personnel).  This  inherently  creates  greater  incentives  for  the 
operator to seek maximum efficiency to avoid potential economic losses due to cost increases. 
It also puts the financial risk of time delay on the operator. Such an approach could potentially 
be  piloted  in  other  programmes  in  order  to  create  greater  incentives  for  cost-effectiveness, 
while also focusing management activities more on outputs and inputs. 

5.4.3.6  Externalisation versus internalisation 

Due  to  the  decision  to  rely  extensively  on  internal  staff  of  the  decommissioning  operators,  in 
particular in Lithuania and Bulgaria, delays in the decommissioning programme can easily lead 
to a sub-optimal use of human resources within the organisation. This includes under-utilisation 
of resources where delays have caused a stop in works, or over-utilisation of resources (with the 
additional overtime costs entailed) in order to make up lost time.  

The limited externalisation of site maintenance activities points to some margin for enhancing 
cost effectiveness in this area. As mentioned, INPP is implementing a make-or-buy strategy  in 
order  to  identify  activities  not  part  of  its  core  business  that  it  would  be  advantageous  to 
externalise. Such measures could also be considered for the Kozloduy programme in the future.  

5.4.3.7  Technical uncertainties remain an inherent part of the decommissioning 
process, both supporting and detracting from cost-effectiveness  

The decommissioning market remains in a developmental stage due to the level of world-wide 
experience. These technical challenges are further compounded in the case of decommissioning 
early-generation  reactors.  These  characteristics  have proven  both  a  facilitator  and  obstacle  to 
cost effectiveness. New technologies and approaches that are developed in the context of such 
decommissioning  activities  can  contribute  to  significantly  reducing  costs.  On  the  other  hand, 
contractors can sometimes fail to deliver on contract deliverables due to technical difficulties.   

47 

 
The monitoring reports show several instances of contractor non-performance due to technical 
challenges.  In  addition,  decommissioning  operators  have  also  struggled  with  technical  issues 
internally. In the most high profile case to date, the initial contractor selected to implement the 
decontamination of the primary circuit of the Bohunice reactors did not have the full knowledge 
to achieve the task. In this case, JAVYS was able nonetheless to minimise cost increase through 
reuse  of  part  of  the  deliverables  of  the  first  contractor  and  rescheduling  the  wider 
decommissioning programme.  

On  the  other  hand,  the  dynamic  nature  of  the  decommissioning  market  holds  potential  for 
improving  cost  effectiveness  through  the  leveraging  of  new  or  novel  technologies  and 
approaches. For example, the market response to tendering for the Plasma Melting Facility at 
Kozloduy resulted in a significant increase in the estimated upfront cost of the project; however, 
the  volume  reduction  factor  offered  by  the  application  of  plasma  melting  technology    should 
save tens of millions in the long-term – e.g. storage costs.  

Ignalina  is  the  first  large  graphite  moderated  nuclear  reactor  to  be  decommissioned  in  the 
world.  Due  to  its  first-in-kind  nature  and  the  limited  experience  available  worldwide  on  the 
handling of irradiated graphite, larger technical uncertainties are unavoidable (see also section 
5.4.4.1).  As  the  actual  dismantling  work  will  only  be  started  after  the  end  of  the  current 
programming period, the present evaluation does not address this issue in more details. 

These factors point to the importance of a careful balancing of risks when going to market and 
making strategic decisions on internalisation vs. externalisation. It also underlines the necessity 
to  develop  strong  public  procurement  and  contract  management  capacity.  Lessons  learnt,  in 
particular  at  Kozloduy,  point  to  the  importance  of  establishing  extremely  close  working 
relationships  with  contractors,  to  navigate  technically  demanding  projects  and  address 
challenges  as  they  arise.  In  the  Kozloduy  programme,  this  has  been  achieved  through 
establishing  open  and  continuous  communication  with  contractors  and  mobilising  internal 
resources  to  support  contractors  when  necessary.  Finally,  these  lessons  also  underscore  the 
usefulness of sharing knowledge and exchanging best practices between the three programmes, 
which collectively represent Europe’s most ambitious nuclear decommissioning undertaking to 
date. A recent example concerns Slovak and Bulgarian exchanges of experience with regards to 
management of legacy (wet) radioactive waste. 

5.4.3.8  Administrative and regulatory issues 

The cost-effectiveness of programme implementation has also been impacted by issues in the 
administrative realm that could have been completely or at least partially avoided. National 
administrations,  in  particular  in  Bulgaria,  have  not  always  made  all  reasonable  attempts  to 
remove  administrative  obstacles  to  cost-effective  programme  implementation.  For  example, 
the  design  and  construction  of  the  Plasma  Melting  Facility  has  been  slowed  and  faced  with 
unnecessary  risks  due  to  administrative  capacity  and  efficacy  issues  (e.g.  complying  with 
regulations, managing contracts, administrative approvals, etc.) during the previous and current 
MFF. During the previous MFF, repeated challenges to Environmental Impact Assessments have 
also led to the accumulation of important delays in projects and the programme as a whole that 
must  now  be  made  up.  It  is  assumed  that  these  difficulties  were  mostly  due  to  the  fact  that 
these  are  new  regulatory  activities,  leading  to  an  inadequate  understanding  of  regulatory 
requirements and adequate quality control measures. 

Delays and cost increases have been noted due to inadequate anticipation of modifications to 
regulations  and  underestimation  of  the  time  necessary  for  regulatory  approval  or  fulfilling 
regulatory  requirements.  While  some  isolated  examples  were  identified  at  Ignalina  and 
Bohunice,  this  issue has  impacted  most strongly the  Kozloduy  programme. Safety  decisions  in 
the  nuclear  domain  should  always  be  made  independently  of  specific  economic  factors; 
however,  questions  can  be  raised  as  to  the  extent  that  decommissioning  operators  are 
adequately working with regulators to anticipate such evolutions in the regulatory domain and 

48 

 
adequately  account  for  regulatory  processes  in  project  planning.  At  the  same  time,  it  can  be 
acknowledged that some difficulties have been faced due to inadequate capacity on the part of 
regulators and other administrative entities involved in the regulatory approval process. 

To not overstate the problem, it can be acknowledged that the situation has shown continuous 
improvement since the beginning of the programme. Decommissioning operators are becoming 
more experienced with navigating these processes, planning accordingly and taking mitigation 
measures.  Contact  and  cooperation  between  decommissioning  operators  and  regulators  was 
generally  reported  to  be  good  (and  improving).  Moreover,  as  underlined  in  section  2.8,  the 
regulators as much as the decommissioning operators have benefited from experience, as well 
as the technical assistance provided through the NDAP.  

5.4.3.9  External technical assistance 

Expenditure on project management and technical support activities represents a significant 
portion of overall costs and number of staff. In total, this support amounts to EUR 175,7 million 
for  all  three  programmes  since  their  outset.  This  total  does  not  include  other  consultancy 
contracts outside of the Grant Agreements for PMU services. Decommissioning operators have 
made extensive use of consultancies and engineering firms for similar services through separate 
contracts or as part of large project contracts.  

Considering  issues  identified  with  regard  to  inadequate  planning  and  project  management 
capacity  in  some  programmes,  the  cost-effectiveness  of  these  investments,  in  particular  the 
large amount funnelled to external consultancies and engineering firms, can be questioned. This 
would  point  to  a  continued  need  to  ensure  the  assessment  of  the  cost  and  benefit  of 
contracting technical support (versus use of internal resources) and enhanced management of 
contract  implementation  to  ensure  consultants  are  delivering  added  value.  The  EBRD  has 
conducted  capacity  assessments  to  assist  with  decisions  on  the  sizing  of  the  PMUs.  Finally, 
continued high spending on external support contracts would point to a need to better ensure 
knowledge transfer and internal capacity building through these investments. 

5.4.4  Evaluation Question 6.3  

What factors can explain differences in costs (and possibly benefits) arising 
between Member States? 

The  table  below  provides  an  overview  of  the  current  total  estimated  costs  for  the 
decommissioning programmes, as well as the number of units, nominal capacity and duration of 
the  decommissioning  programme.  A  cursory  glance  at  the  cost  estimations  between 
programmes  will  find  the  notable  difference  in  the  overall  cost  between  the  Ignalina 
programme  and  the  Kozloduy  and  Bohunice  programmes.  However,  a  number  of  other 
variables  must  also  be taken into  account before  drawing  conclusions,  such  as  the size  of  the 
reactors, the reactor technology or duration of the decommissioning process.  

Table 4: Comparison of decommissioning programmes / plant characteristics 

Programme 

Total budget 
(EUR million) 

Units 

Kozloduy (BG) 

Bohunice (SK) 

Ignalina (LT) 

1 107 

1 245 

3 377 

4 

2 

2 

Source: Detailed decommissioning plans 

Nominal 
capacity 
(MW) 

1 760 

880 

3 000 

Reactor 
technology 

Duration 

End state 

VVER 

VVER 

27 years 

Brownfield 

22 years 

Brownfield 

RBMK 

38 years 

Brownfield 

Overall, exogenous variables can explain in large part the cost variations between the three 
MS  more  so  than  variations  in  cost  effectiveness.  Nonetheless,  an  important  nuance  to  this 
overall conclusion  can be  made for  the Ignalina  programme. The extension  of  the duration of 

49 

 
the  programme  as  a  result  of  issues  faced  with  critical  waste  management  infrastructure 
projects in the last MFF significantly contributed to the increased overall decommissioning cost. 
Combined with cost differences arising from historical factors and the innate characteristics of 
the facility itself, these increases have largely driven the rise in overall costs. 

5.4.4.1  Size of facilities and complexities for dismantling 

The primary factor explaining the differences in costs between the three programmes is the size 
of  facilities  and  complexities  for  dismantling.  Using  nominal  capacity  as  a  rough  proxy  of  the 
overall volume of equipment and civil structures it becomes clear that part of the price disparity 
can  be  attributed  to  the  larger  size  of  the  plant.  Looking  at  the  cost  of  decommissioning  per 
Megawatt of nominal capacity as a very rough indicator of cost performance, Ignalina (EUR 1.13 
million  per  MW)  fits  well  between  the  Bohunice  V1  decommissioning  programme  (EUR  1.42 
million per MW) and the Kozloduy programme (EUR 0.63 million per MW). 

Looking at some specific comparisons, one can appreciate the difference in size and its impact 
on cost. The amount of steel from equipment to be dismantled at Ignalina (157 000 tonnes), for 
example,  is  more  comparable  to  that  of  the  six  unit  2  640  MW  Greifswald  NPP  (116  000 
tonnes)54,  which  is  itself  triple  the  size  of  the  Bohunice  V1  NPP  and  50%  larger  than  the 
Kozloduy NPP. Interestingly, the cost of decommissioning at Ignalina is significantly lower than 
the  current  cost  estimates  for  the  decommissioning  of  Greifswald  (EUR 5 750 million).55 
Concerning the reactor core structures, Ignalina dwarfs the mass of VVER reactors, with 17 100 
tonnes  of  steep  graphite  and  shielding  (serpentine  /  sand)  to  be  dismantled  and  disposed  of. 
Finally, it should also be noted that the RBMK produces higher quantities of operational waste 
than its VVER counterpart. Compared to its VVER counterpart, the RBMK-type reactor can also 
be noted for the larger extension of the contamination by the water flowing through the reactor 
core. At Ignalina an estimated 91% of steel from equipment to be dismantled is contaminated, 
compared with 59% at the Greifswald plant for example. This inevitably requires greater efforts 
and planning during the decommissioning process. 

The technical challenges for the decommissioning of Ignalina are significantly more complex 
than  the  other  two  programmes  due  to  its  first-in-kind  nature  and  the  fact  that  a  larger 
percentage of the equipment is contaminated. Ignalina is the first RBMK to be decommissioned 
in  the  world.  This  means  there  is  no  precedence  or  experience  that  the  decommissioning 
operator can rely on. While technically beyond the scope of the decommissioning programme, 
open questions remain in particular with regard to the management and disposal of irradiated 
graphite  waste.  Some  useful  experience  can  potentially  be  provided  by  other  graphite 
moderated  reactors  currently  being  decommissioned;  however,  none  of  these  has  been 
completely decommissioned. Governments, such as the UK and France, have tended to favour 
SAFSTOR strategies. 

5.4.4.2  Economic factors  

One  can  also  note  that  the  cost  estimate  for  Kozloduy  is  relatively  low  compared  to  the 
estimated  cost  of  Bohunice  V1  decommissioning,  in  particular  considering  that  the  installed 
capacity of Kozloduy is double that of Bohunice V1. However, a previous analysis56 of the cost 
estimates demonstrated that correcting for the relatively lower labour costs in Bulgaria gives a 
comparable revised cost.  

54 The similar reactor technology at Greifswald makes it useful for comparison with the decommissioning 
programmes of Kozloduy and Bohunice 
55  According  to  approximate  figures  provided  by  EWN,  the  total  cost  of Greifswald  decommissioning is 
EUR  6  600.  To  make  a  rough  comparison  with  the  cost  estimate  for  Ignalina,  it  is necessary  to  subtract 
EUR 650 for the final disposal of spent nuclear fuel and 200 for the demolition of the RAW repository at 
Rheinsberg NPP (the equivalent costs are not included in the Ignalina cost estimate). 
56 Deloitte 2016 

50 

 
                                                            
Other  local  economic  factors  affect  the total  cost to  a  lesser  extent.  The attractiveness  of  the 
site for highly qualified and skilled staff, due notably to the geographic situation of the plants 
and  local  quality  of  life.  The  strength  of  the  local  (non-nuclear)  supply  chains  weighs  on  the 
prices of consumables and services.  

5.4.4.3  Pre-existing waste management infrastructure  

The construction of waste management infrastructure is often forgotten as an integral part of 
the  decommissioning  process.  However,  this  infrastructure  is  a  necessary  pre-condition  for 
decommissioning to begin. The three Member States had varying level of existing infrastructure 
in place. Slovakia, where decommissioning of Bohunice A1 had already begun before V1 & V2 
decommissioning  started,  had  a  large  part  of  the  necessary  infrastructure  already  in  place, 
whereas  Bulgaria  had  some  existing  waste  treatment  and  disposal  facilities.  Lithuania  had 
almost  none  of  the  required  infrastructure  due  to  the  fact  that  the  country  found  itself  in 
possession of the facility, which it has not been responsible for constructing or managing, at the 
moment of its independence. 

For this reason, the three programmes exhibited drastically different upfront investment costs 
before  decommissioning  activities  could  begin.  Slovak  authorities  estimated  that  national 
contributions  to  necessary  pre-existing  waste  management  infrastructure  (thus  outside  the 
decommissioning plan cost estimates), amounted to EUR 300 million. The corresponding waste 
management infrastructures had still to be built in Lithuania and partially in Bulgaria. 

5.4.5  Evaluation Question 7 

How does the governance and management system of the NDAP compare to 
other programmes managed by the Commission (or other actors)?  
Do these comparators provide any best practices in terms of governance or 
management? 

The purpose of this question was to develop comparative case studies focused on governance 
and finance structures and examine advantages and disadvantages compared to the NDAP. . 

Three  ‘comparator’  instruments  were  selected  for  analysis  as  part  of  the  benchmarking 
exercise:  Connecting  Europe  Facility  (CEF),  Budget  Support  aid  delivery  mechanism  and 
European Structural and Investment Funds (ESIF) Major Projects. 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. Nonetheless, the comparator programmes remain very different from the NDAP in terms 
of their objectives, types of projects supported and timescale (e.g. lifespan of projects is much 
shorter than decommissioning). Due to the unique nature of the NDAP, overall comparability is 
limited. 

With  comparability  limited,  rather  than  focusing  on  comparing  performance  metrics,  the 
benchmark was focused on the identification of relevant best practices. 

51 

 
Table 5: Presentation of comparator programmes / instruments 

Programme 

Short description  

Connecting  Europe 
Facility 

Facility for the delivery of large 
(energy, 
infrastructure 
transport & ICT) projects across 
Europe (direct management) 

Budget  support  aid 
delivery modality  

Instrument  primarily  used  for 
delivering  aid  and  capacity 
third 
support 
building 
countries (direct management) 

to 

ESIF 
- 
Projects57 

  Major 

Mechanism  for  approving  and 
large  projects 
implementing 
(>50M) (shared management) 

Rationale for the selection of this 
programme in the benchmark 

As  NDAP  projects,  CEF  also  finance 
large size infrastructure projects with 
large  European  budget  (including  in 
energy  sector).  Moreover  some  of 
these  projects  are  very  specific 
actions  and  include  the  development 
of  innovative  technologies.  They  are 
also  implemented  by  a  large  number 
of contractors with very specific skills 
and various areas of expertise.  

The budget support instrument has a 
number  of  potential  benefits  that 
make  it  an  interesting  comparative 
case study. While budget support has 
little  precedent  for  being  used  in  the 
'domestic'  Union 
is 
it 
for 
increasingly  being  considered 
wider, including internal, use. 

context, 

projects  with 

ESIF  Major  Projects  are  large  scale 
some 
complex 
commonalities  with  NDAP  projects 
such  as  the  part  of  innovation,  the 
involvement  of  specific  knowledge, 
the work with contractors,… Some of 
them are in energy and infrastructure 
sectors. However  ESIF  Major  Projects 
are  implemented  under  the  shared 
management  mode  and  so  are  very 
different from the NDAP projects. 

57 While ESIF Major Projects represent an interesting case study compared with NDAP, it should be noted 
that  it  is  expressly  forbidden  for  these  funds  to  be  used  for  the  purpose  of  supporting  decommissioning 
(Article 3 (3) of the ERDF Regulation & Article 2(2) of the Cohesion Fund Regulation) 

52 

 
 
                                                            
The table below provides a summary of the main findings for each of the case studies. These are 
discussed in further details below.  

Table 6: Overview of the findings of the benchmarking exercise 

Connecting Europe Facility 

Budget Support 

ESIF Major Projects 

Promotes strong national 
ownership through Member 
State approval of European 
‘corridors’ and individual 
projects 

Promotes strong national 
ownership through national 
development of strategy 

Strong focus on political & 
technical dialogue with the 
beneficiaries 

Promotes strong national 
ownership through Member 
State programme and 
implement projects in high 
autonomy 

Multi-annual framework for 
project implementation 

Multi-annual framework for 
project implementation 

Multi-annual framework for 
project implementation 

Strong, harmonised project 
management procedures 
through centralised 
management at INEA 

Strong assessment of projects 
necessary prior to approval, 
including cost estimates 

Clear co-financing framework  Use of performance 

Clear co-financing framework 

incentives  
Less burdensome financial 
management controls and 
contribution to strengthening 
national capacity 

Use of results-based 
performance indicators 

Strong incentive to ensure 
effective implementation 
through risk of 
decommitment  

Use of online system for 
production of annual 
monitoring reports 

Development of programme 
level results-based monitoring 
indicators 

Source: EY 2018 

In comparison to the NDAP, some overall interesting practices can be underlined: 

The performance monitoring framework for the 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  these  two  programmes,  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 

53 

 
 
 
programming  and  commitments  (in  contrast  to  NDAP).  Projects  are  implemented  in  line  with 
their approved work plans. For CEF and ESIF 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 ESIF 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.  

5.5  EU Added Value 

5.5.1  Evaluation Question 8 

What would be the likely result of ending the NDAP in the three Member 
States concerned? 

This transversal question sought to measure the EU added value of the NDAP. EU added value is 
additional to the value created by actions of individual Member States, which may result from 
different  factors,  such  as  coordination  gains, 
legal  certainty,  greater  effectiveness  or 
complementarities, economies of scale, promotion of best practice, benchmarking, etc. 

5.5.1.1  NDAP has contributed to facilitating the immediate and safe decommissioning 

The  NDAP  represented  an  important  commitment  by  the  EU  to  the  three  Member  States 
during  negotiations  to  shut  down  the  reactors.  EU  support  to  decommissioning  (and  to 
mitigating the impacts of closure) represented a politically and financially significant offer that 
helped  enable  the  EU  to  obtain  a  commitment  on  the  part  of  the  three  Member  States  to 
permanently  shut  down the reactors.  The shutdown of  these  reactors,  considered  unsafe  and 
un-upgradable  by  the  international  community,  was  a  politically  contentious  issue  in  all  (then 
candidate)  Member  States,  which  relied  on  these  reactors  for  a  significant  (or  in  the  case  of 
Lithuania the quasi-totality) of their electricity production needs. Moreover, the early shutdown 
before the end of their envisaged operational lifetime, combined with specific historical factors, 
meant that inadequate financial resources existed to finance decommissioning.  

Beyond obtaining the commitment to shutdown, EU support clearly influenced the timescale 
for  decommissioning.  Both  Lithuania  and  Bulgaria  had  initially  (briefly)  envisaged  pursuing  a 
strategy  of  deferred  dismantling.  The  immediate  availability  of  EU  assistance  factored 
significantly into the decision to  change to an immediate dismantling strategy. In Bulgaria, EU 
support  has  also  contributed  to  the  government’s  decision  to  further  shorten  the  duration  of 
decommissioning,  bringing  forward  the  envisaged  end-date  to  2030  from  2035  as  initially 
foreseen. Compared to deferred dismantling / safe enclosure, EU support has thus allowed for 
the level of radiological hazard to be reduced more rapidly and to avoid passing on a significant 
financial  burden  to  future  generations,  in  line  with  internationally  accepted  principles  of 
management  of  nuclear  waste  and  decommissioning.  Indeed,  deferred  dismantling  /  safe 
enclosure by its very nature entails leaving part of the radiological hazard on site for a period of 
30  years  or  longer. It also  defers  the  major  part  of  the  costs  and  the  total  costs  may  in some 
cases be higher overall. 

The  EU  added  value  of  financial  support  to  the  Ignalina  programme  appears  the  most 
is  difficult  to  confidently  predict  the 
significant  of  the  three  programmes.  While 
counterfactual, a lack of EU support for the current MFF would in all likelihood have resulted in 
a  disruption  of  programme  implementation  and  a  change  in  the  decommissioning  strategy 
(likely to deferred dismantling). The financing shortfall for Ignalina prior to the EU commitments 
for  the  current  MFF  were  significantly  higher  than  the  other  two  programmes  at  EUR  2  012 

it 

54 

 
million. The assessment by Deloitte58 found that fully funding post 2020 remaining allocation (of 
EUR 1 561 million) from state finances would entail a significant increase in Lithuania’s budget 
deficit, and either a decrease in budget spending on non-energy areas, a higher national debt 
level, or a combination thereof. At the same time, there remains a staunch public and political 
resistance in the country to supporting the costs of decommissioning without EU assistance due 
to  the  unique  historical  factors  and  perceived  promises  made  at  the  moment  of  accession. 
Recognising  these  concerns,  stakeholders  interviewed  were  unanimous  in  affirming  that  a 
disruption  of  EU  funding  would  have  entailed  a  dramatic  and  immediate  change  in  the 
decommissioning strategy for the current period.  

In  Bulgaria,  EU  support  appears  to  be  important  to  continuing  decommissioning  activities 
during  the current programming  period. The absence of such funding may  have resulted in a 
change of strategy for national authorities or an extension of the timeline. Even if the EUR 321 
million funding gap  prior to the current MFF could be considered to be reasonably within the 
limits of Bulgarian public finances, a lack of continued EU funding may have put the project at 
risk  of  political  obstacles  in  a  Member  State  that  has  been  marked  by  the  instability  of 
government and nuclear policy in particular in recent years.  

Due  to  the  relatively  advanced  nature  of  the  decommissioning  process  at  Bohunice  and the 
size  of  the  financial  shortfall,  the  current  EU  added  value  of  support  in  the  current  MFF  is 
relatively  lower  than  in  the  other  two  Member  States.  Considering  the  hypothetical  funding 
gap  of  EUR  317  million  prior  to  the  current  MFF,  full  financing  from  national  coffers  can  be 
considered  to  have  been  very  reasonably  within  the  limits  of  Slovak  public  finances.  The 
decommissioning operator is experienced and highly capable. Moreover, the operator hopes to 
leverage 
international 
decommissioning  market.  The  absence  of  EU  funding  during  the  current  programming  period 
could potentially have slowed the pace of progress, but would very likely not have significantly 
impacted progress all other things held constant. Nonetheless, Slovak authorities interviewed59 
maintain  that  EU  support  during  the  current  MFF  has  been  important  to  ensuring  that  the 
decommissioning programme continues without disruption.  

future  economic  opportunities  on 

this  experience 

into 

the 

5.5.1.2  EU added value naturally declining as programme implementation advances 

The EU added value of the NDAP from its beginning has been cast in terms of nuclear safety 
and  financial  mitigation.  The  NDAP  has  contributed  over  previous  MFFs  and  continues  to 
contribute  to  a  stepwise  decrease  in  the  level  of  radiological  hazard  and  risk  to  the  general 
public. With a finite level of radioactivity on site, however, each additional euro of investment 
provides  decreasing  rates  of  return.  The  EU  added  value  of  the  programme  is  thus  naturally 
decreasing over  time.  Moreover,  the funding gap  has  been closed  to  relatively small amounts 
for two of the three programmes.  

With  the  exception  of  Lithuania,  where  defueling  remains  ongoing,  the  level  of  radiological 
hazard  on  the  sites  has  been  reduced  to  approximately  1%  of  original  levels  and 
correspondingly the level of risk to the general public practically highly diminished. During the 
remainder  of  the  current  MFF,  the  Bohunice  programme  will  remove  much  of  the  final 
significant  sources  of  radioactivity  in  the  technically  challenging  process  of  dismantling  the 
reactor cores and the Kozloduy programme will embark upon this process.  

5.5.1.3  Knowledge sharing a source of continued added value 

Of the 90 nuclear reactors currently permanently shut down in Europe, only three have been 
completely  dismantled.  The  level  of  experience  in  the  dismantling  of  nuclear  reactors  in 
Europe (as well as internationally) is thus highly limited. The NDAP’s contribution to securing 

58 Deloitte 2016 
59 EY 2018 

55 

 
                                                            
the shutdown and immediate dismantling of these reactors has led to the generation of a highly 
significant amount of experience that can be of benefit to other decommissioning projects and 
ensure this way increased level of safety within the EU.  

First and foremost, the knowledge and experience gained can be of use to the three national 
programmes.  To  this  end,  the  Commission  has  continually  encouraged  stakeholders  to  share 
experience and best practice, in particular between Slovakia and Bulgaria due to the similarity 
of the plants.  

Beyond the three programmes, the knowledge and experience generated may also prove of 
use  to  other  decommissioning  projects  in  Europe.  However,  the  knowledge  sharing  and 
capitalisation  process  is  not  currently  structured  and  is  largely  organic.  Member  State 
representatives on the NDAP Committee noted that their attendance was in part motivated by 
this knowledge-sharing aspect, although it is not fit to this purpose. Decommissioning operators 
have  also  shared  their  experiences  in  various  international  fora,  such  as  the  IAEA  or  NEA. 
European companies benefiting from contracts through the NDAP will also serve an important 
role 
from  the  NDAP  to  other 
decommissioning  programmes.  There  thus  appears  to  be  scope  for  a  more  structured 
organisation of the knowledge sharing process. The Commission can facilitate this process, but 
Member  States  should  also  recognise  the  value  of  the  information  generated  and  ensure 
relevant stakeholders are informed and able to take part. 

in  transferring  knowledge  and  experience  accrued 

6  CONCLUSIONS 

6.1  Assessment by evaluation criteria 

6.1.1  Relevance 

As  far  as  the  MFF  2014-2020  is  concerned,  the  general  and  specific  objectives  of  the 
programmes remain highly relevant for responding to the needs that were identified during that 
MFF  preparatory  stage  (i.e.  progress  in  decommissioning  past  the  point  of  no  return  and 
accomplishment of enhanced safety). 

6.1.2  Coherence 

The  Regulations  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 
Lithuania  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  State  to  ensure  adequate  financial  resources  for  nuclear  decommissioning  and 
radioactive waste management. 

6.1.3  Effectiveness 

To date, progress has been made in all three programmes, and long-standing issues that were 
carried  over  from  the  previous  financial  framework  were  eventually  resolved.  Key 
infrastructures for managing spent fuel and radioactive waste either became operational or are 
in the final stages of commissioning, injecting fresh momentum into decommissioning activities. 

In  all  three  sites,  D&D  in  the  turbine  halls  and  auxiliary  buildings  has  progressed  well.  The 
decommissioning  operators  have  successfully  managed  to  identify  and  remove  bottlenecks  in 
the processes. 

Progress  has  been  made  on  D&D  in  the  reactor  buildings  (controlled  area)  at  the  three  sites, 
consistent with the respective programme schedules and end dates. 

The  main  outputs  of  decommissioning  programmes  are  materials  to  be  either  reused  or 
recycled  and  conditioned  radioactive  waste  to  be  either  stored  temporarily  (interim  waste 

56 

 
store) or disposed of. For the three programmes, these outputs have been lower than planned 
to  date  for  several  reasons:  (i)  inherent  uncertainties  in  the  characterisation  of  the  plants 
caused  the  target  values  to  be  overestimated;  (ii)  lower  input  to  waste  management  facilities 
from  dismantling  activities;  and  (iii)  technical  challenges  related  to  specific  legacy  waste 
streams. Nonetheless, the waste management processes have proved to be generally capable of 
providing the necessary productivity throughput with the highest safety standards. 

6.1.4  Efficiency 

 The preparation and endorsement in 2014 of the decommissioning plan was a major milestone 
and  clarified  the  scope,  schedule,  and  budget  of  the  decommissioning  programme.  Between 
2014 and 2016, the Commission has analysed this baseline and concluded that it is based on a 
complete  and  comprehensive  plan,  and  on  a  sound  overall  cost  estimate  which  could  be 
improved further by considering a higher level of contingencies 

The analysis shows that the programmes have generally been implemented in a cost-effective 
manner  in  the  current  financial  framework,  and  that  the  programming  process  has  a  much 
higher level of maturity. 

Financial  benchmarking  of  decommissioning  activities  remains  a  challenge  worldwide.  This 
limitation is reflected in the difficulties involved in comparing the three programmes with each 
other and with other decommissioning programmes despite the wider use of the International 
Structure for Decommissioning Costing. 

The analysis also identified the main factors that influence cost-effectiveness: 

  The  governance  in  place  since  2014  has  steered  the  programmes  towards  increased 
efficiency, and organisational changes have had a positive impact on cost-effectiveness. 

   The  achieved  levels  of  national  contribution  appear  fit  to  sustain  proper  efficiency; 
nonetheless,  co-financing  is  not  established  in  the  legal  basis,  thus  creating  continued 
uncertainties. Moreover, the analysis showed that an adequate level of national contribution 
is a necessary but not a 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 
Member State would have a greater impact. This practice has been already introduced to a 
certain extent under the current MFF where possible. 

  Timely implementation is key to cost-effectiveness. The removal of roadblocks carried over 
from  the  previous  financial  framework  and  the  recovery,  when  possible,  of  accumulated 
delays  has  contributed  to  cost-effectiveness  (e.g.  resolution  of  long-standing  contractual 
disputes in Ignalina).  

inherently 

  Labour  costs  are  a  substantial  and 

time-dependent  component  of 
decommissioning costs. When labour is provided mainly by the decommissioning operators’ 
staff, incurred delays may impact on the cost, especially when they affect the critical path, 
i.e.  the  programme’s  end  date.  To  mitigate  this  risk,  externalisation  strategies  provide 
adequate flexibility to adjust needs and efforts. The implementation of such strategies is well 
developed in Bohunice and is progressing in Ignalina, where a structured ‘make or buy’ plan 
was established in 2017. 

  On  the  other  hand,  the  deployment  of  plant  staff  (who  were  employed  during  the 
operational life of the reactors) is a good knowledge management practice as it ensures that 
relevant  experience  is  carried  over  to  reduce  the  time  of  implementation.  However,  this 
practice  entails  the  risk  of  having  too  much  staff  and  limiting  the  flexibility  of  the 
organisations, especially where alternative opportunities are not available. 

  Some  technical  challenges  remain  intrinsic  to  the  decommissioning  process,  and  the 
decommissioning  market  is  still  in  a  developmental  stage.  This  has  led  to  instances  of 
setbacks among contractors. 

57 

 
  Cost increases have been noted with regard to modifications in legislation, and delays have 
increased during regulatory approval processes in all three countries. Safety decisions in the 
factors;  the 
nuclear  domain  must  be  made 
decommissioning  operators  should  therefore  work  with  regulators  to  anticipate  such 
developments in the regulatory domain and adequately account for regulatory processes in 
project  planning. While some good practices  were  identified  in Lithuania  and  Slovakia,  this 
issue has impacted the Kozloduy programme. 

independent  of  specific  economic 

6.1.5  EU added value 

The added value of the programmes, as it has historically been perceived, naturally declines as 
implementation advances. From the beginning, the programmes’ added value has been cast in 
terms of financial mitigation and nuclear safety. 

  Beyond 2020, estimated financial gaps in Bulgaria and Slovakia do not endanger finalisation 

of the programmes by the planned end dates. 

  In  Lithuania,  the  financing  gap  beyond  2020  has  also  decreased  thanks  to  the  further 

engagement of Lithuania. However, the gap remains sizeable (EUR 1.331 billion). 

  While  the  three  Member  States’  economies  are  clearly  capable  of  absorbing  the  financial 
needs through national financial resources, the impact of doing so would be more significant 
for Lithuania. 

  The  programmes  have  contributed  to  a  substantial  decrease  in  the  level  of  radiological 
hazard and risk to the general public. The most important nuclear safety related risks have 
been  eliminated  in  Slovakia  and  Bulgaria.  In  Lithuania,  removal  of  spent  fuel  from  reactor 
buildings  is  ongoing  —  by  the  end  of  this  process  (scheduled  for  2022),  the  residual 
radiological  hazard  will  be  substantially  reduced  by  orders  of  magnitude  and  will  be 
represented mainly by the irradiated graphite cores. 

The EU nuclear industry is firmly moving into a new phase characterised by increased activities 
in the back-end of the lifecycle. However, only a few decommissioning programmes have made 
significant progress, including the Kozloduy, Ignalina and Bohunice programmes. It is therefore 
apparent that the decommissioning industry has not yet reached full maturity. In this context, 
EU  support  to  the  decommissioning  programmes  in  Bulgaria,  Slovakia  and  Lithuania  has 
provided additional value to the entire EU decommissioning industry in terms of knowledge and 
expertise. Knowledge sharing and capitalisation aspects of the programmes therefore serve as a 
basis  for  ensuring  continued  EU  added  value.  This  process  might  be  further  exploited  in 
managing irradiated graphite, which is a technical challenge worldwide60. 

6.2  Scope for modification of the detailed implementation procedures 

The 2013 NDAP Regulations explicitly require that the evaluation also addresses the scope for 
modification of the detailed implementation procedures. 

6.2.1  Roles and responsibilities 

In  general,  the  role  and  responsibilities  of  the  actors  are  well  defined  and  need  not  to  be 
changed. However, the tasks of the Monitoring Committee and of the Programme Coordinator 
could  be  reinforced.  That  would  reinforce  their  oversight  of  the  programme  implementation 
through the NDAP and further increase national ownership of project implementation. Further 
benefits could be obtained from this setting by extending the scope of the committee to discuss 

60  No power reactors with graphite cores have been dismantled yet, although many of them were shut 

down several years ago. Besides Lithuania, other Member States have to undertake similar projects as 
they own significant inventories of irradiated graphite: United Kingdom (86 000 t), France (23 000 t), 
Lithuania (3 800 t), Spain (3 700 t), Italy (3 000 t), Belgium (2 500 t), Germany (2 000 t). 

58 

 
                                                            
and  decide  on  programming  and  planning  aspects.  Explicitly  describing  the  role  of  the 
decommissioning  operators  would  set  clear  expectations  for  their  contribution  and  reinforce 
the accountability framework. 

6.2.2  Programming and Monitoring 

The best practice observed in all comparator programmes is a multi-annual rather than annual 
framework for programming while maintaining annual monitoring and reporting requirements. 
The role of the decommissioning plans should be more explicitly explained as it provides a point 
of reference for monitoring progress over the entire duration of the nuclear decommissioning 
assistance  programmes.  The  annual  work  programmes  serve  as  a  way  of  updating  the 
implementation  schedule  of  the  multi-annual  decommissioning  plans,  taking  into  account  the 
latest developments in the implementation of the programmes.  

Performance indicators should be improved and updated where needed in order to increase the 
level of accountability and provide a granular view of the physical progress; also taking stock of 
past accomplishments to recalibrate the indicators. 

As implementation of many projects will continue after 2020, a monitoring framework that sets 
out milestones  and  targets  for  at least five  years  following the  end of  the  current  MFF would 
thus ensure adequate monitoring of projects implementation until completion. 

The  comparability  of  indicators  across  programmes  should  be  perfected  as  all  programmes 
pursue  similar  goals,  with  some  specifics.  This  would  make  inter-comparison  across  the  three 
programmes straightforward. 

6.2.3  Simplification 

Re-designing the timeline, sequencing and linkages in processes and streamlining or otherwise 
adapting the content of programming and monitoring documents could support enhancing the 
timeliness of the yearly programming/reporting cycle. 

Most projects are approved within a short period of time nonetheless stakeholders underlined 
the need for clearer timelines and a streamlined procedure for project approval.  

Indicators  to  monitor  the  governance  system's  efficiency,  in  particular  at  the  EU  level,  would 
introduce the possibility to evaluate quantitatively margin for improvement. 

6.2.4  Co-financing 

The lack of a legal base as concerns national contributions has created residual uncertainties in 
the  past  that  should  be  mitigated  in  this  MFF  through  the  revision  of  the  implementation 
procedures.  A  solution  would  be  to  clearly  demarcate  the  boundaries  of  EU  support  (e.g. 
specific projects). The explicit transfer of risks (cost overruns, delays) to the concerned Member 
States would provide a reinforced incentive for timely and efficient decommissioning. 

6.3  Opportunities for improvement 

This  section 
Programme. 

identifies  further  opportunities  to 

improve  the  Nuclear  Decommissioning 

6.3.1  Knowledge sharing 

Reflecting the advancement of the programmes and the wider  context of  decommissioning in 
the  EU,  the  underlying  rationales  of  the  NDAP  should  be  adapted  to  provide  stronger  added 
value  in  terms  of  knowledge  generation  and  sharing  in  view  of  the  immense  financial  and 
technical challenge represented by nuclear decommissioning in the EU. 

Establishing  mechanisms  to  identify,  structure  and  disseminate  relevant  knowledge  and 
experience  gained  in  the  three  programmes  to  all  other  relevant  users  across  the  EU  would 

59 

 
provide a beneficial support in tackling the immense challenge of decommissioning, maintaining 
the  highest 
in 
decommissioning. 

levels  of  safety  and  positioning  the  EU 

internationally  as  the 

leader 

The  sharing  of  knowledge  generated  by  the  programmes  could  cover  more  widely  the 
objectives  and  achievements  of  the  NDAP.  Where  relevant,  communication  activities  should 
reach beyond the scope of the NDAP, engaging with EU-level civil society, industry and  public 
actors on questions of decommissioning in view of the expected strong increase in the number 
of  decommissioning  projects  across  Europe  in  coming  years.  It  could  also  go  beyond  the 
technical activities and extend to the positive impacts of the NDAP on the EU decommissioning 
market and local communities. 

6.3.2  Waste-led decommissioning 

Adopt a more robust “waste-led approach” to programme implementation through stronger 
prospective analysis. 

Decommissioning operators at Kozloduy and Ignalina should maintain close monitoring of waste 
management  infrastructure  projects  still  under  implementation  /  to  be  launched  in  order  to 
proactively identify and address any issues that could have an impact on the decommissioning 
process.  

A carefully examination and regular report on expected capacity levels and projected flows for 
waste  management  streams  would  allow  to  identify  risks  of  bottlenecks  and  to  proactively 
address them. 

60 

 
 
Annex 1 

Procedural information 

1. 

Lead DG, Decide Planning/Commission Work Programme references 

This  evaluation  of  Council  Regulations  1368/2013/Euratom  and  1369/2013/EU  on  Union 
support  for  the  nuclear  decommissioning  assistance  programmes  in  Bulgaria,  Slovakia  and 
Lithuania  is  led  by  DG  Energy.  It  is  recorded  in  the  Commission's  Agenda  Planning  under  the 
reference PLAN/2016/249. 

2.  Organisation and timing 

In  August  2016,  DG  Energy  invited  the  Secretariat-General,  the  Legal  Service,  DG  Budget,  DG 
Economic  and  Financial  Affairs,  DG 
International  Cooperation  and  Development,  DG 
Employment,  Social  Affairs  and  Inclusion,  DG  Environment,  DG  Internal  Market,  Industry, 
Entrepreneurship and SMEs, DG Regional and Urban Policy and the Joint Research Centre to join 
a  new  inter-service  steering  group  to  steer  the  evaluation  process.  The  group  met  five  times 
(14 September 2016, 16 May 2017, 27 July 2017, 9 February 2008 and 15 March 2018). 

In parallel the Commission informed and collected feedback from the Nuclear Decommissioning 
Assistance Programme Committee61 during the meetings organised on 23 September 2016, 12 
July  2017  and  11  October  2017  and  from  the  Monitoring  Committees  in  their  meetings  of 
October 2016, May-June 2017 and October 2017. 

The evaluation roadmap was published on 15 February 2017. 

The Open Public Consultation has been organised for an extended period of 14 weeks from 23 
June 2017 to 29 September 2017. 

The ground work of the evaluation was carried by an external consultant – Ernst & Young France 
in the period from 5 April 2017 to 11 December 2017. The key deliverables were the inception 
report (30 May 2017), the draft final report (18 December 2017) and the final report (9 March 
2018). 

3. 

Exceptions to the better regulation guidelines 

There were no exceptions to the Better Regulation Guidelines. 

4. 

Consultation of the Regulatory Scrutiny Board 

Not applicable. 

61 http://ec.europa.eu/transparency/regcomitology/index.cfm 

61 

 
 
                                                            
5. 

List of references 

IP/D/CONT/IC/2013_054 

COM(2011)432 

ECA Special Report No 
16/2011 

ECA Special Report No 
22/2016 

Deloitte 2016 

COM/2017/0328 

COM/2016/0405 

COM/2015/078 

ENER - PLAN/2016/249 

EY 2018 

SWD/2017/0159 

COM/2017/0236 

Nuclear Decommissioning: Management of Costs and Risks, Öko-Institute e.V. for the 
European Parliament 
http://www.europarl.europa.eu/RegData/etudes/etudes/join/2013/490680/IPOL-
JOIN_ET%282013%29490680_EN.pdf 

Report from the Commission to the European Parliament and the Council on the use of 
financial resources during 2004-2009 provided to Lithuania, Slovakia and Bulgaria to 
support the decommissioning of early shut-down nuclear power-plants under the Acts of 
Accession 
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52011DC0432 

EU financial assistance for the decommissioning of nuclear plants in Bulgaria, Lithuania and 
Slovakia: achievements and future challenges, European Court of Auditors 
http://www.eca.europa.eu/Lists/ECADocuments/SR11_16/SR11_16_EN.PDF 

EU nuclear decommissioning assistance programmes in Lithuania, Bulgaria and Slovakia: 
some progress made since 2011, but critical challenges ahead, European Court of Auditors 
https://www.eca.europa.eu/Lists/ECADocuments/SR16_22/SR_NUCLEAR_DECOMMISSION
ING_EN.pdf 

"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 for the European Commission 

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 
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52017DC0328 

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 
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52015DC0078 

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 
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52015DC0078 

Evaluation and Fitness Check Roadmap: Mid-term evaluation of the Nuclear 
Decommissioning Assistance Programme (NDAP) 
http://ec.europa.eu/smart-
regulation/roadmaps/docs/plan_2016_249_ndap_evaluation_en.pdf 

"Support to the mid-term evaluation of the Nuclear Decommissioning Assistance 
Programmes" Final report, Ernst & Young France for the European Commission 

Commission Staff Working Document: Progress of implementation of Council Directive 
2011/70/EURATOM Accompanying the document 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 
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=SWD:2017:159:FIN 

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 
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52017DC0236 

62 

 
 
Directive 2011/92/EU 

Directive 2011/92/EU of the European Parliament and of the Council of 13 December 2011 
on the assessment of the effects of certain public and private projects on the environment 
Text with EEA relevance 
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011L0092 

COM/2017/0237 

Communication from the Commission: Nuclear Illustrative Programme presented under 
Article 40 of the Euratom Treaty - Final (after opinion of EESC) 
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52017DC0237 

EuropeAid Guidelines N°7 

EuropeAid Tools and Methods Series Guidelines N°7, Budget Support Guidelines, 
September 2017 
https://ec.europa.eu/europeaid/eubudgetsupport_en 

Directive 
2009/71/Euratom 

Directive 
2014/87/Euratom 

Regulation (Euratom) 
1368/2013 

Regulation (EU) 
1369/2013 

C(2014)5449 

SEC(2011)1387 

COM(2011)783 

Regulation (EU) 
1316/2013 

Regulation (EU) 
1303/2013 

Council Directive 2009/71/Euratom of 25 June 2009 establishing a Community framework 
for the nuclear safety of nuclear installations 
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009L0071 

Council Directive 2014/87/Euratom of 8 July 2014 amending Directive 2009/71/Euratom 
establishing a Community framework for the nuclear safety of nuclear installations 
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0087 

Council Regulation (Euratom) No 1368/2013 of 13 December 2013 on Union support for 
the nuclear decommissioning assistance programmes in Bulgaria and Slovakia, and 
repealing Regulations (Euratom) No 549/2007 and (Euratom) No 647/2010 (OJ L 346, 
20.12.2013, p. 1) & correction (OJ L8, 11.1.2014, p.31). 
http://eur-lex.europa.eu/legal-content/FR/TXT/?uri=celex:32013R1368 

Council Regulation (EU) No 1369/2013 of 13 December 2013 on Union support for the 
nuclear decommissioning assistance programme in Lithuania, and repealing Regulation (EC) 
No 1990/2006 (OJ L 346, 20.12.2013, p. 7) & correction (OJ L8, 11.1.2014, p.30 & OJ L121, 
24.4.2014, p.59). 
http://eur-lex.europa.eu/legal-content/FR/TXT/?uri=celex:32013R1369 

Commission Implementing Decision C(2014)5449 of 7 August 2014 on the rules of 
application for the nuclear decommissioning assistance programmes for Bulgaria, Lithuania 
and Slovakia for the period 2014-2020. 

Commission Staff Working Paper: Impact assessment Accompanying document to the 
Proposal for a Council Regulation on Union support for the nuclear decommissioning 
assistance programmes in Bulgaria, Lithuania and Slovakia. 
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52011SC1387 

Proposal for a Council Regulation on Union support for the nuclear decommissioning 
assistance programmes in Bulgaria, Lithuania and Slovakia. 
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52011PC0783 

Regulation (EU) No 1316/2013 of the European Parliament and of the Council of 11 
December 2013 establishing the Connecting Europe Facility, amending Regulation (EU) No 
913/2010 and repealing Regulations (EC) No 680/2007 and (EC) No 67/2010 
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32013R1316 

Regulation (EU) No 1303/2013 of the European Parliament and of the Council of 17 
December 2013 laying down common provisions on the European Regional Development 
Fund, the European Social Fund, the Cohesion Fund, the European Agricultural Fund for 
Rural Development and the European Maritime and Fisheries Fund and laying down 
general provisions on the European Regional Development Fund, the European Social 
Fund, the Cohesion Fund and the European Maritime and Fisheries Fund and repealing 
Council Regulation (EC) No 1083/2006 
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32013R1303 

63 

 
Annex 2 

Stakeholder consultation 

1.  Open public consultation 

The  public  consultation  on  the  mid-term  evaluation  of  the  NDAP  relied  on  a  survey  available 
online on the Commission's website from 23 June 2017 to 29 September 2017.  

Identification of the respondents 

20 contributions to the open public consultation have been registered. The respondents mainly 
answer in their personal capacity (13) rather than in their professional capacity or on behalf of 
an  organisation  (7).  Most  of  the  answers  came  from  Lithuania  (11).  Regarding  the  other  two 
Member  States  which  directly  benefit  from  the  EU  support,  only  one  answer  was  registered 
form  Bulgaria  and  no  answer  from  Slovakia.  Respondents  from  other  Member  States  also 
participated in the survey: Germany (3), Spain (1), Italy (1), Austria (1), France (1) and Finland 
(1).  Among  all  respondents,  5  indicated  that  they  were  involved  in  public  authorities,  2  in 
Member States authority, 2 in private organisations, 1 in non-governmental organisation and 4 
as Citizens.  

Overall  the  participation  to  the  consultation  can  be  considered  as  very  low  which  can  be 
explained by two main factors: 

  A large part of programme stakeholders have directly been consulted during the study 

through interviews; 

  There are no strong supporters or opponents to the programme.  

The respondents are generally familiar with the NDAP (17) and only three respondents indicated 
that they are not familiar with the programme. However, few respondents are directly involved 
in the programme (3 respondents) but eight respondents learned about NDAP because they are 
working  in  the  nuclear  sector  or  interested  out  of  professional  interest.  Among  them  two 
respondents  indicated  that  they  are  also  concerned  because  they  have  a  link  with  the 
concerned geographical area. Finally, four respondents indicated that they only learned about 
NDAP out of personal interest.  

Figure 11 What is your level of awareness regarding the Nuclear Decommissioning Assistance 
programme and the nature of assistance it is providing? 

Source: Replies to the open public consultation 

Main findings of the consultation 

17  respondents  considered  that  the  general  objective  of  the  NDAP  is  still  appropriate  to  the 
current  needs.  These  needs  have  been  identified  by  the  respondents  as  the  removal  of  the 

64 

71012Very familiarSomewhat familiarNot really familiarNot at all familiar 
 
 
safety threat posed by the concerned reactors until their final safe decommissioning stage (18 
answers) and the sharing of the financial burden of the decommissioning of the nuclear power 
plants (11 answers). 

Figure 12 To what extent is the general objective of the Nuclear Decommissioning Assistance 
Programme still appropriate in relation to the current needs? 

Source: Replies to the open public consultation 

13  respondents  considered  that  the  NDAP  is  fully  coherent  with  the  Euratom  acquis  while  5 
respondents did not provide answer to this question. 

The respondents have overall a good opinion on the effectiveness of the NDAP (17 respondents) 
and most of them considered that the level of safety of the EU citizens have been improved as a 
consequence of the NDAP (14 respondents). 

Regarding  the  impacts  of  the  NDAP,  the  large  majority  of  respondents  considered  that  the 
NDAP had a positive impact on the local economy and brought a rather or very positive change 
for  local  people  and  society.  Other  types  of  impacts  at  local  or  national  level  were 
acknowledged by the respondents including two position opinions (Implementation of dialogues 
and  kind  of  responsibility  towards  European  citizens  regarding  nuclear  power,  Positive 
development for decommissioning service providers and consultants) and 2 negative opinions. 
The  respondents  also  considered  that  the  NDAP  generated  impacts  that  could  not  have  been 
achieved otherwise, according to the additional information provided by some respondents this 
is  mainly  due  to  the  fact  that  the  Member  States  concerned  would  not  have  been  able  to 
financially support the decommissioning of the nuclear power plant and so ensure the safety of 
the nuclear sites concerned. 

Diverging views 

Only  few  of  the  consultation  answers  showed  diverging  views  and  non-consistency  with  one 
another. The main points underlined by the respondents in the responses to the open questions 
are related to the following statements: 

  The main risk in the nuclear power plants was related to the spent nuclear fuel and the 

NDAP should only cover this aspect; 

  The  NDAP  conducted  to  reinforce  a  sad  image  of  the  nuclear  energy  rather  than 

encourage competitiveness of nuclear sector;  

  More national responsibility and ownership has to be taken; 
  An  increase  in  the  supervision  and  monitoring  of  the  European  Commission  and  a 
higher implication of the Member States in the decisions are needed to ensure higher 
efficiency of the programme and limit the cost increase. 

65 

12521Very appropriateAppropriateNot reallyI don't know / I can't say 
 
 
2. 

Targeted Consultation 

The  section  below  is  describing  the  results  of  the  targeted  consultation  launched  by  EY 
regarding  the  NDAP.  Invitation  was  sent  by  mail  to  approximately  90  members  of  targeted 
organisations. The survey was available online between 4 July and 15 September 

Identification of the respondents 

17 answers were registered to the online survey including 4 from Lithuania, 1 from Bulgaria and 
12 from Slovakia. 10 respondents indicated that they were familiar with the programme but 3 
indicated  not  to  be  really  familiar  with  the  NDAP  and  4  not  familiar  at  all.  Three  respondents 
only answered to the identification questions and did not provide answers to the main part of 
the survey. These answers are not included in the following analysis.  

Relevance 

Most of the respondents considered that the programme remains relevant to the needs of each 
Member State considering that:  

  EU  has  to  continue  supporting  the  decommissioning  of  the  plants  because  it  required 

their closure (9 answers),  

  National authorities do not have adequate capacities to manage the decommissioning 

safely and effectively without EU assistance (9 answers),  

  Adequate national funding is not available to ensure the timely decommissioning of the 
reactors (8 answers) and the safe decommissioning of the reactors (6 answers) creating 
a risk for the general public.  

Figure 13 To what extent do you believe that the programme remains relevant to the needs of 
Lithuania/Bulgaria/Slovakia today? 

Source: Replies to the open public consultation 

Effectiveness 

The respondents are divided regarding the fact that authorities are on the right track to achieve 
expected results in line with decommissioning plans. 

66 

941Very muchSomewhatI don't know / I can't say 
 
Figure 14 Considering the achievements since 2014, do you believe that authorities are on the 
right track to achieve expected results in line with the decommissioning plans? 

Source: Replies to the open public consultation 

However,  all  the  respondents  considered  that  nuclear  safety  has  been  adequately  taken  into 
account in the implementation of the NDAP in the three Member States. 

Efficiency 

9 respondents out of 14 considered that the efficiency of programme implementation has been 
a  primary  concern  of  national  authorities  whereas  3  assessed  that  the  programme 
implementation was not really efficient and 1 that the programme was not at all efficient. The 
respondents identified the nuclear power plant owner/operator (7 answers), the Implementing 
Bodies  (5  answers),  the  national  ministries  (5  answers)  and  the  European  Commission  (2 
implementation  of 
answers)  as  organisations  assuming  primary  responsibility  for  the 
decommissioning activities. 

Impacts 

The  respondents  considered  that  the  NDAP  implementation  had  a  positive  impact  on  the 
development of knowledge and expertise, the capacity of national authorities and operators to 
manage  decommissioning  of  spent  fuel  and  radioactive  waste.  However,  the  respondents  are 
more divided regarding the economic impacts at local and national level.  

Five respondents considered that the NDAP also led to unintended negative impacts but were 
not able to precisely describe them. 

Added Value 

All  respondents  considered  that  the  NDAP  has  provided  added  value  to  the  Member  States. 
However,  only  one  respondent  described  the  types  of  added  value  provided,  underlining  the 
experience and knowledge gain for the EU companies and positive impact on safety of people 
and environment. 

67 

4541Very much soSomewhatNot reallyNot at all 
 
Annex 3 

Methods and analytical models 

1. 

Phasing 

The Evaluation was executed under three main phases, organised as follows:  

-  Phase 1: Inception Phase. The aim of this Phase was to ensure the complete structuring 

of the Evaluation, including the evaluation framework.  

-  Phase  2:  Data  collection  Phase.  The  data  collection  phase  allowed  to  focus  on  both 

primary and secondary data research. 

-  Phase  3:  Analysis  and  reporting  phase.  This  phase  allowed  the  Evaluation  Team  to 
analyse the collected data in order to formulate answers to the Evaluation questions. 

2.  Work undertaken 

The  following  table  presents  in  detail  the  data  collection  work  undertaken  during  the  data 
collection phase.  

Task 

Documentary 
review 

Work undertaken 

 

In-depth  desk  research  was  undertaken  by  the  Study  Team  prior  to  the  field  visit  with  the 
objective  of  ensuring  a  thorough  understanding  of  the  respective  decommissioning 
programmes and better adapting the general topic guides to the context of each programme.  

  Documents  reviewed  included  the  Decommissioning  Plans,  Monitoring  Reports,  annual 
programming  documents  of  Implementing  Bodies  and  selected  project  documentation 
(Project  Identification  Fiches,  etc.).  Additional  documents  were  gathered  during  the  field 
visits and reviewed by the Study Team.  

Interview 
programme 

 

 

 

Interviews with the European Commission 

Interviews with other EU and international organisations 

Interviews with a sample of NDAP Committee members 

Field visits 

  Four field visits were organised during the month of June 2014: 

  London – United Kingdom, 12 – 14 June 2017 (Observation of the Assembly of Contributors 
meetings and a workshop hosted by the EBRD, interviews with key stakeholders of the EBRD) 

  Vilnius and Visaginas – Lithuania, 18 – 23 June 2017 (24 interviews with INPP, CPMA, national 

authorities and regulatory authorities) 

  Bratislava and Bohunice – Slovak Republic, 26 - 30 June 2017 (14 interviews with SIEA, JAVYS, 
the Nuclear Regulatory Authority of the Slovak Republic (NRA) and the Ministry of Economy 
of Slovakia) 

  Sofia and Kozloduy – Bulgaria, 27 - 30 June 2017 (12 interviews with the Ministry of Energy, 

SERAW and the Bulgarian Nuclear Regulatory Authority) 

Public consultation 

  Open public consultation launched on 23 June 2017 gathered 17 responses 

  Targeted public consultation launched on July 2017 gathered 10 Reponses 

Benchmark exercise 

 

In-depth online desk research 

  Complementary interviews undertaken with programmes stakeholders 

Expert panel 

  The  Expert  panel  was  organised  on  the  22th  September  2017  base  on  the  intermediate 
in  order  to  validate  conclusions  and  discuss 

final  report 

version  of  the  draft 
recommendations. 

68 

 
3. 

Public Consultation 

The  public  consultation  consisted  of  both  a  general  public  consultation  launched  by  the 
Commission in line with the Better Regulation Guidelines and a targeted consultation launched 
by EY through the use of the EY Online survey tool. Both are described in further detail below.   

General Public Consultation 

In  line  with  the  Commission’s  Better  Regulation  Guidelines,  a  public  consultation  of  12  weeks 
duration shall was launched between July and September. The aim of this consultation was to 
provide  an  opportunity  for  all  interested  members  of  the  public  to  provide  their  input  to  the 
Evaluation.  

Targeted Consultation  

In addition to the public consultation, EY launched an online survey through the use of the EY 
Online 
enterprises, 
regional/local/municipal  authorities  and  national  organisations  representing  not  for  profit 
interests. 

and  medium 

Tool  which 

targeted 

Survey 

small 

sized 

4. 

Benchmark  

Following  the  data  collected  through  interviews  and  on-site  visits,  a  benchmark  exercise  was 
undertaken in order to respond to questions relating to the governance structure and financial 
management  of  the  NDAP,  as  well  as  prospective  questions  on  potential  simplification.  This 
benchmarking  exercise  consisted  of  undertaking  a  comparative  analysis  of  other  comparable 
instruments  /  programmes  managed  by  the  EU.  In  particular,  analysis  focused  on  the 
governance and management structures, as well as financial management modalities.  

The benchmarking exercise was conducted on the following programmes.  

Programme 

Short description  

Rationale under the selection of this 
programme in the benchmark 

Connecting  Europe 
Facility 

Budget  support  aid 
delivery modality  

Facility for the delivery 
of  large  infrastructure 
(energy,  transport  & 
ITC)  projects  across 
Europe 
(direct 
management) 

As  NDAP  projects,  CEF  also  finance  large  size 
infrastructure  projects  with  large  European 
budget (including in energy sector). Moreover 
some  of  these  projects  are  very  specific 
include  the  development  of 
actions  and 
technologies.  They  are  also 
innovative 
implemented  by  with 
large  number  of 
contractors with very specific skills and various 
areas of expertise.  

Instrument 
primarily 
used  for  delivering  aid 
and  capacity  building 
third 
support 
countries 
(direct 
management) 

to 

that  make 

The budget support instrument has a number 
of  potential  benefits 
it  an 
interesting  comparative  case  study.  While 
budget  support  has  little  precedent  for  being 
used  in  the  'domestic'  Union  context,  it  is 
increasingly  being  considered 
for  wider, 
including internal, use. 

European  Structural 
Investment 
and 
for  Major 
Funds 
Projects 

Mechanism 
approving 
implementing 
projects 

for 
and 
large 
(>50M) 

ESIF  Major  Projects  are  large  scale  complex 
projects with some commonalities with NDAP 
projects  such  as  the  part  of  innovation,  the 
involvement  of  specific  knowledge,  the  work 

69 

 
(shared management)  with  contractors,…  Some  of  them  are 

infrastructure 

energy  and 
management  of  project 
however very different as the NDAP projects. 

implementation 

in 
sectors.  The 
is 

5. 

Expert Panel  

The Expert Panel was organised in EY Office in Paris on 22 September 2017. The objective was 
to  discuss  main  findings  and  recommendations  before  the  submission  of  the  final  report.  The 
following experts attended to this meeting: 

- 

Przemyslaw Zydak (Executive director / Nuclear expert, EY Poland) 

-  Georgij Krivosein (Senior manager / Nuclear expert, EY Ukraine) 

-  Andrzej  Strupczewski  (Chairman  of  the  Nuclear  Safety  Commission  (NCBJ)  /  Nuclear 

Safety expert) 

Birute  Bobrovaite-Jurkone  (Nuclear  Engineer,  EY  Lithuania)  also  contributed  to  the  final 
discussions on the report although she could not attend the meeting.  

70 

 
Annex 4 

Overview of the Evaluation Questions 

Proposed evaluation 
question 

Relevance 

Sub-questions (if applicable) 

EQ1.  To  what  extent  are  the  general  and  specific  objectives  of  the  NDAP  still  appropriate  in 
relation to the existing needs? Do these objectives need to evolve to take into account present 
and future needs?  

Coherence 

EQ2.  To  what extent is  the 
NDAP 
with 
coherent 
relevant EU acquis? 

Effectiveness 

EQ3.  To  what  extent  have 
the 
(general,  specific  & 
detailed)  objectives  of  the 
NDAP  been  achieved  for 
each 
three 
programmes? 

the 

of 

EQ2.1  Is  the  NDAP  coherent  with  the  Euratom  Treaty’s  acquis  in 
the  area  of  nuclear  safety  and  responsible  management  of  spent 
fuel and radioactive waste? 
EQ2.2 Is the NDAP coherent with the EU acquis in other relevant 
areas, in particular the environment? 

EQ3.1 Overall, what level of progress has been made towards the 
objectives  of  each  national  programme?  Is  the  progress  in  line 
with the decommissioning baseline adopted by the Commission? If 
not, what is the risk that objectives will not be achieved? 

EQ3.2 To what extent are control systems in place to measure the 
progress of the decommissioning programmes? 

EQ3.3  What  external  and  internal  factors  influenced  (positively 
and  negatively) 
the  decommissioning 
programmes? 

the  progress  of 

EQ3.4  To  what  extent  has  the  level  of  risk  at  each  nuclear  site 
been improved thanks to the NDAP support? 

EQ3.5  Are 
to 
stakeholders and the public effective, adequate and accurate? 

the  communication  actions  addressed 

the 

EQ4. Aside from the financial assistance provided, what other types of results and impacts can 
be attributed to the NDAP (e.g. (economic, environmental, social impacts)?  

EQ5.  How  effective  is  the 
governance  and  project 
management framework at 
EU and national levels?  

EQ5.1  How  well  is  the  Commission  supervisory  role  defined  and 
effective in terms of: planning; monitoring; and reporting 

EQ5.2 At national level, how well are the roles of the Programme 
Manager and Implementing Bodies defined and effective in terms 
of: planning; monitoring; and reporting.  

EQ5.3  How  effective 
the 
decommissioning  programmes?  In  particular  does  it  allow  to 
effectively: 

the  governance  system  of 

is 

a) prioritise measures with reference to the NDAP objectives? 

b) mitigate or avoid risk? 

c) minimise or recover from delays? 

71 

 
 
Proposed evaluation 
question 

Efficiency 

of 

EQ6.  To  what extent is  the 
management 
the 
decommissioning 
programmes  cost  effective 
and efficient? 

Sub-questions (if applicable) 

d) overcome administrative bottlenecks? 

EQ6.1  To  what  extent  has  the  NDAP  been  cost  effective  when 
considering  each  cost  category  compared  against  performance 
indicators?  Are 
for  measuring 
efficiency?  

there  adequate 

indicators 

EQ6.2 What are the major factors impacting the efficiency of the 
assistance  programmes?  What  are  the  root  causes  of  these 
factors? 

EQ6.3 What  factors can explain differences in costs (and possibly 
benefits) arising between Member States?  

EQ7.  How  does  the  governance  and  management  system  of  the  NDAP  compare  to  other 
programmes managed by the Commission (or other actors)? Do these comparators provide any 
best practices in terms of governance or management? 

EU added value 

EQ8.  What  would  be  the  likely  result  of  not  having  EU  assistance  for  decommissioning  in  the 
three Member States concerned? What is the added value resulting from the NDAP, compared 
to what could be achieved at national level without such intervention? 

72 

 
 
Earned Value Management and critical path analysis 

Annex 5 

Earned Value Management (EVM) and critical path analysis are complementary in exposing risks 
for delays in the implementation of the programme. 

Earned Value Management 

1. 
Earned  Value  Management62  (EVM)  is  a  structured  method  used  to  provide  a  performance 
measurement  system  for  review  of  past  and  forecasted  performance  of  a  project  or 
programme. It integrates scope, schedule, and resources, and for objectively measuring project 
performance and progress.  

A  central  element  of  the  EVM  implementation  is  the  performance  measurement  baseline 
providing  the  reference  points  against  which  actual  programme  progress  is  compared.  It 
includes; 

(1)  Project plan that identifies work to be accomplished in a hierarchy of activities, called the 

work breakdown structure, 

(2)  Schedule 

for  the  work  which 

identifies 

for  all  activities  their  durations  and 

interdependencies, 

(3)  Budget assigned to planned work, called Planned Value (PV), and 

(4)  Pre-defined  “earning  rules”  (also  called  metrics)  to  quantify  work  performance,  called 

Earned Value (EV), 

(5)  Accountancy and reporting of the actual expenditures, Actual Cost (AC). 

In the case of the NDAP, all these elements are included in the annual work programmes. 

Baseline schedule and current schedule 

The baseline schedule is the official plan against which schedule performance is measured and 
reported 

The  current  schedule  is  used  to  manage  all  project  activities.  It  is  used  to  enter  the  current 
status  of  schedule  performance.  This  current  schedule  provides  the  road  map  for  all  future 
activities on the project.  

When compared to the baseline schedule, the current schedule provides a measure of how well 
the project is progressing against the original plan. At the beginning of the project, the baseline 
and  current  schedules  are  the  same.  Once  the  status  update  process  begins,  the  current 
schedule reflects the current conditions on the project. 

Performance indicators 

EVM implementations generally include indicators of schedule performance (behind schedule or 
ahead of schedule) and cost performance (over budget or under budget). 

The former ones are defined as: 

  Schedule Variance, SV = EV – PV, 

  Schedule Performance Index, SPI = EV / PV.  

62 ISO 21508:2018 Earned value management in project and programme management 

73 

 
 
                                                            
The latter ones are defined as: 

  Cost Variance, CV = EV – AC, 

  Cost Performance Index, CPI = EV / AC. 

At any given point in time, reported information on the Earned Value and the Actual Cost can be 
used to calculate performance by means of the aforementioned indicators. 

Schedule 

behind of 

on 

ahead of 

SV 

< 0 

= 0 

> 0 

SPI 

< 1 

= 1 

> 1 

  Budget 

  Over 

  On 

  Under 

CV 

< 0 

= 0 

> 0 

CPI 

< 1 

= 1 

> 1 

The key feature of these indicators is their reference to value (€), so that they clearly reply to 
the questions: 

  Is the programme producing the value that was planned in a determined period of time? 

  Is the programme impacted by cost overruns? 

Finally, EVM is not intended for non-discrete (continuous) effort, so called “level of effort". If a 
project plan contains a significant portion of level of effort, and the level of effort is intermixed 
with discrete effort, EVM results will loose of their informative value. 

2. 

Critical path analysis 

Considering the planned duration of each activity and dependencies between the activities, the 
critical  path  is  the  longest  path  of  planned  activities  to  the  end  of  the  programme.  This 
determines the shortest time possible to complete the programme. 

The critical path analysis also determines the earliest and latest that each activity can start and 
finish  without  making  the  programme  longer.  This  process  determines  which  activities  are  on 
the critical path (any delay in those activities will delay the end of the programme) and which 
activities can be delayed without making the project longer.  

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