Two other questions refer to international activities. The decisions in these cases do not depend solely on Bulgarian institutions. The first issue concerns the measures related to the localization of a meltdown, which require international efforts to overcome the problems in the very design of VVER-1000 reactors (measure D-3-5). The second issue concerns international benchmarks (benchmarking with other NPP).
The fact that institutions are shifting responsibility for the measures related to NPP safety is extremely disturbing. NRA reported as completed the measure that involves maintenance of the 12-kilometer-long floodbank along the Danube River protecting Kozloduy NPP. Meanwhile, in-depth reading of the report shows that the agency is monitoring the state of the floodbank, but the Ministry of Agriculture and Food (MAF) is responsible for its maintenance. NRA refers us to MAF for details such as the project life expectancy and employability of the floodbank.
“Given a year of heavy rains on the Balkans and the devastated regions in Bulgaria due to the heavy winter snowfall, we believe that the maintenance of the floodbank protecting the NPP can not be a ‘juggling ball’ between institutions (measure B-3-1)”, said Gennady Kondarev from “Za Zemiata”.
The measure concerning the development of alternative emergency routes for access to the facilities of the NPP is also partially completed. NRA has fulfilled its responsibilities up to the fence of Kozloduy NPP and refers us to Road Infrastructure Agency, which is responsible for the maintenance of the by-road to the NPP. Implementation holdups exist in almost all plans and measures regarding emergencies and involving the Interior Ministry.
The third measure, which the NRA considers completed, but which we consider formally completed, is D-2-5. It concerns “Development of technical means to enable direct supply of water to compartments with SNF (spent nuclear fuel) in RSNF (repository for spent nuclear fuel) by mobile fire equipment and facilities in emergencies.” The measure was to be completed in December 2014. Instead, the actual execution was postponed and only an action plan was developed. The actual completion was redirected to a new measure.
We want to draw the attention of all citizens who follow the nuclear energy situation in Bulgaria to the fact that public hearings on a new regulation are expected in 2015. The regulation will reflect the lessons learned from Fukushima and will be voted by the Council of Ministers. On the eve of the fourth anniversary of the Fukushima nuclear catastrophe, we want to remind that many theoretical models cited in support of the safety of nuclear power have no reality check. According to such models, the risk rate of severe accidents at a nuclear reactor is one in 240 years. However, we have witnessed five serious accidents in only 33 years.
After Fukushima, stress tests have been conducted in a desperate attempt to comfort society and restore confidence in NPP safety, which has previously been criticized by the civil society. Stress tests do not constitute an exhaustive list of all the possible risks NPP could be subjected to – natural, manmade, or a combination of both. Stress tests do not examine problems related to ageing reactors. The only mandatory parameters in the checks include resistance to heavy rains, floods and earthquakes. Most European plants are designed and built decades ago and do not take into account climate change. Their design is based on outdated climate models. Statistics show that large and destructive floods used to occur once every 100 years in the past, however, today they happen once every 20 years. Test results have no impact on NPP, even the oldest VVER-440 reactors of some NPP (Mühleberg, Doel and Rivne) dare to apply for longer life extension. Accidents caused by humans, such as a plane crash in the power lines of a NPP, are not even discussed.
We are presenting the complete list of measures, our questions and the answers given by NRA. Measures that have not been completed and those we do not consider completed are marked in red. Completed measures are in green, and in yellow are those that civil society organizations should focus on this year.
Postponing and uncertainties regarding 12 of 20 measures included in action plan on stress tests at Kozloduy NPP
